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510(k) Data Aggregation
(105 days)
The DANA 3cc Syringe Insulin Reservoir is an accessory to the DANA Diabecare® Insulin Pumps. The DANA 3cc Syringe Insulin Reservoir is intended for the delivery of insulin from the DANA Diabecare® Insulin Pumps using specified insulin administration sets.
The DANA 3cc Syringe Insulin Reservoir is intended exclusively for use with the DANA Diabecare® Insulin Pumps. The DANA Diabecare® Insulin Pumps are external programmable syringe infusion pumps used for the subcutaneous delivery of insulin for the treatment of diabetes mellitus. The pumps are not intended for use with blood or blood products.
The DANA 3cc Syringe Insulin Reservoir is a sterile, single-use, non-pyrogenic, syringe that is designed for use with all versions of the DANA Diabcare® Insulin pump that have been cleared for marketing in the U.S. (K001604, K022317, and K063126). The syringe reservoir is a 3 ml polypropylene syringe with a 300 unit insulin capacity that is supplied with a 22 gauge, 12.7 mm straight needle. The reservoir is filled similarly to filling an insulin syringe. Once filled and inspected for entrapped air, the needle is removed and the syringe reservoir is inserted into the distal end for attachment to the linking screw that connects the syringe reservoir to the DANA Diabecare® Insulin pump. The syringe has groves cut into the distal end for attachment to the linking screw that connects the syringe reservoir to the DANA Diabecare® Insulin Pump.
The proposed DANA 3cc Syringe Insulin Reservoir is a modification of the insulin reservoir accessory described in K001604, the original 510(k) premarket notification for the DANA Diabecare® Insulin Pump. The modification was limited to a change in the gasket configuration and material. The proposed DANA 3cc Syringe Insulin Reservoir has a ring shape gasket that is manufactured from silicone.
The provided text describes a 510(k) submission for the DANA 3cc Syringe Insulin Reservoir, focusing on its substantial equivalence to predicate devices and performance testing. However, it does not explicitly detail specific, quantified acceptance criteria or a comprehensive study report with detailed methodologies and results as one might expect from a formal performance study section.
Based on the provided information, here's a breakdown of the requested elements:
1. Table of Acceptance Criteria and Reported Device Performance
The submission does not explicitly state quantified acceptance criteria with pass/fail thresholds for specific performance metrics. Instead, it broadly states that "Design verification activities... included evaluation of physical and functional characteristics, and shelf-life testing. The results confirm that the DANA 3cc Syringe Insulin Reservoir showing to may insulin reservoir for all legally marketed versions of the DANA Diabecare® Insulin Pumps and support the claimed shelf life."
This indicates that the device met internal performance standards, but those specific standards and their numerical results are not provided in this summary. The "Comparison Chart for Determination of Substantial Equivalence" focuses on shared design features rather than performance metrics.
Performance Metric/Characteristic | Acceptance Criteria (Not explicitly quantified in text) | Reported Device Performance |
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Physical Characteristics | (Implied: Meet design specifications) | |
e.g., integrity of syringe, gasket fit, needle attachment. | Confirmed to meet design specifications during "evaluation of physical and functional characteristics." | |
Functional Characteristics | (Implied: Proper insulin delivery, no leakage, compatibility with DANA Diabecare® pumps) | Confirmed through "evaluation of physical and functional characteristics" to function as an insulin reservoir for DANA Diabecare® Insulin Pumps. |
Shelf-life | (Implied: Maintain integrity and function for claimed shelf-life duration) | "Support the claimed shelf life." (Specific duration not provided in this snippet). |
Sterility Status | Supplied Sterile | "Supplied sterile" |
Single Use | Designed for single use | "Single use" |
Capacity | 3ml syringe | |
300 unit capacity | "3 ml syringe" | |
"300 unit capacity" |
2. Sample Size Used for the Test Set and Data Provenance
The document does not provide specific details on the sample sizes used for the design verification tests (physical, functional, shelf-life). It also does not specify the data provenance (e.g., country of origin, retrospective or prospective nature of the test data). The tests were conducted internally by Sooil Development Co., Ltd. as part of their "Design verification activities."
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
This type of information is not applicable and not provided in the context of this device. The "ground truth" for an insulin reservoir's performance would typically be established through engineering tests measuring physical and functional attributes against predefined specifications, rather than expert consensus on subjective assessments.
4. Adjudication Method for the Test Set
Not applicable. Adjudication methods (like 2+1, 3+1) are typically used in studies involving human interpretation or subjective assessment where discrepancies need resolution, such as in image analysis or clinical trials. Performance testing for a medical device like an insulin reservoir involves objective measurements, not human adjudication of subjective data.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No. An MRMC study is not relevant for this type of device. MRMC studies are used to evaluate the diagnostic performance of human readers (e.g., radiologists) in interpreting medical images, often comparing performance with and without AI assistance. This device is an insulin reservoir, not a diagnostic imaging AI.
6. Standalone Performance Study (Algorithm Only Without Human-in-the-Loop Performance)
Yes, a "standalone" performance evaluation was conducted in the sense that the device's physical and functional characteristics were tested independently. The "Design verification activities" were focused on the device itself. While the device is an accessory intended for human use with an insulin pump, the performance reported here is of the reservoir itself, not an AI algorithm.
7. Type of Ground Truth Used
The "ground truth" for the performance testing would be established by predefined engineering specifications, design requirements, and recognized industry standards for insulin delivery devices and sterile medical components. For example, a "ground truth" for capacity would be 300 units as measured by calibrated equipment, or for sterility, it would be the absence of microbial growth as per validated sterilization methods.
8. Sample Size for the Training Set
Not applicable. This device is a physical medical device (an insulin reservoir), not an AI algorithm or a diagnostic tool that requires a "training set" of data in the machine learning sense.
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there is no training set for this type of device.
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(16 days)
The DANA Diabecare® II external programmable syringe infusion pump and the SUPERLINE-EasyRelease, Soft-Release-ST, and Soft-Release-R Infusion Sets are indicated for the subcutaneous delivery of insulin for the treatment of diabetes mellitus. The pump and administration sets are not intended for use with blood or blood products.
The DANA Diabecare® II insulin pump, SUPERLINE-EasyRelease (EasyRelease) Infusion Set, and Soft-Release Infusion Sets are modifications of the DANA Diabecare® insulin pump and SUPERLINE infusion set that were described in K001604, the 510(k) premarket notification for the DANA Diabecare® insulin infusion pump. The modifications made to the parent DANA Diabecare® insulin pump to produce the modified DANA Diabecare® II Insulin Pump were limited to software modifications including changes to the basal and bolus insulin delivery modes. features accessed via the password-protected (lock-out) mode, and the addition of alarms, a fail-safe function, and the ability to store and retrieve information (alarm, bolus dose, daily insulin dose). The overall design of the proposed EasyRelease, Soft-Release-ST, and Soft-Release-R Infusion Sets is identical to the design of the parent SUPERLINE Infusion Set. The design modifications are limited to the following: - Addition of a site for disconnecting the insulin pump from the infusion set . without removing the needle from the abdomen - Replacement of the infusion needle with an indwelling soft cannula (Soft-. Release-R and Soft-Release-ST only) The two versions of the Soft-Release Infusion Sets differ in the design of the detachment site and cannula assembly. The Soft-Release-R Infusion Set has a sliding lock detachment site and a "rectangular" cannula oriented perpendicular to the infusion tubing axis. The Soft-Release-ST has a turning screw lock detachment site that uses a conical fitting and a straight cannula oriented parallel to the infusion tubing axis. There are minor differences in the materials used for the construction of the proposed EasyRelease, Soft-Release-ST, and Soft-Release-R Infusion Sets as compared to the parent SUPERLINE.
Here's an analysis of the provided text regarding the DANA Diabecare® II Insulin Pump and SUPERLINE Infusion Sets, focusing on acceptance criteria and supporting studies:
It's important to note that the provided text is a 510(k) summary, which typically focuses on demonstrating substantial equivalence to a predicate device rather than presenting a full, detailed study report with extensive acceptance criteria and performance statistics like a PMA. Therefore, some of the requested information (especially quantitative data, training set details, or complex study designs like MRMC) is not explicitly present or as detailed as one might expect in a scientific publication.
Acceptance Criteria and Reported Device Performance
The document describes several performance tests and their outcomes, which serve as the acceptance criteria for ensuring the modifications made to the device still meet safety and effectiveness standards.
Acceptance Criteria / Performance Test | Reported Device Performance |
---|---|
Biocompatibility | Sooil has conducted the necessary testing to satisfy the biocompatibility requirements of ISO 10993-1 for use as an insulin administration set. (Implies compliance with ISO 10993-1 standards) |
Burst Testing | Confirms that the detachment sites incorporated in the EasyRelease and Soft-Release Infusion Sets do not leak. (Implies meeting a no-leakage standard) |
Bioburden Testing | Confirms that the fluid path remains sterile following repeated detachment/reattachment procedures. (Implies meeting sterility standards, likely below a certain bioburden limit for medical devices) |
Unexpected Detachment | Confirms that the detachment sites incorporated in the EasyRelease and Soft-Release Infusion Sets do not unexpectedly detach. (Implies meeting a standard for secure attachment/detachment) |
Insulin Potency Assay (Stability) | Indicates that insulin remains stable for up to 120 hours in the EasyRelease and Soft-Release Infusion Sets. (Implies no significant degradation or loss of potency of insulin over this period, meeting a pre-defined stability threshold) |
Shelf-Life Testing | Supported a three-year shelf life for the EasyRelease and Soft-Release Infusion Sets. (Implies meeting stability, sterility, and functional requirements over a three-year period) |
Software Modifications | Changes to basal/bolus delivery, password-protected modes, addition of alarms, fail-safe function, and data storage/retrieval. (Implies successful implementation and intended functionality of these changes; specific acceptance criteria for each software feature are not detailed but would typically involve functional testing). |
Additional Information on the Study (if available)
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Sample size used for the test set and the data provenance:
- The document does not explicitly state the sample sizes for the burst, bioburden, insulin potency, or shelf-life testing. These would typically be determined by statistical methods or regulatory guidance for such tests.
- The data provenance (e.g., country of origin, retrospective/prospective) is not specified. Given the manufacturer is from Korea, it's likely the testing was performed there or by a contract lab; however, this is not confirmed in the text. This is a design verification activity, not a clinical trial.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- This question is not applicable to the described performance testing. The "ground truth" for burst, bioburden, and insulin stability tests is typically established through objective measurements against defined chemical, physical, and microbiological standards, not relying on expert interpretation in the same way as, for example, image interpretation in a diagnostic device.
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Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- This question is not applicable. Adjudication methods are typically used in studies involving human interpretation or clinical outcomes, where there might be disagreement. These are objective engineering and laboratory tests.
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If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:
- This is not applicable as this device is an insulin pump and infusion set, not an AI-powered diagnostic or assistive tool for human readers. No MRMC study was mentioned or would be relevant.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable as this is a medical device (pump and infusion sets), not a standalone algorithm or AI. While the pump has software with algorithms, the "standalone" performance here relates to the device's functional integrity (e.g., accurate insulin delivery, absence of leaks), not an AI's interpretative power.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- For the described tests:
- Biocompatibility: Ground truth is established by adherence to ISO 10993-1 standards and validated laboratory test results (e.g., cytotoxicity assays, sensitization tests).
- Burst Testing: Ground truth is the physical presence or absence of leakage under specified pressure.
- Bioburden Testing: Ground truth is the microbiological count meeting sterility assurance levels.
- Insulin Potency Assay: Ground truth is the measured concentration/activity of insulin remaining relative to a control or baseline, determined by validated chemical assays.
- Shelf-Life Testing: Ground truth is the maintenance of all specified performance criteria (e.g., sterility, dimensional stability, material integrity, functional operation) over the stated period.
- These are all objective, laboratory-based measurements against established scientific and regulatory standards.
- For the described tests:
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The sample size for the training set:
- Not applicable. This is not a machine learning model, so there is no "training set." The development of the device involves engineering design, material selection, and verification testing.
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How the ground truth for the training set was established:
- Not applicable, as there is no training set for this type of device.
In summary: The provided 510(k) summary focuses on demonstrating the safety and effectiveness of the physical device modifications through performance testing against established engineering and regulatory standards (e.g., biocompatibility, physical integrity, stability). It does not involve AI or diagnostic interpretations, thus many of the questions related to AI/algorithmic performance, human readers, and ground truth in that context are not relevant to this submission.
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