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510(k) Data Aggregation

    K Number
    K231754
    Manufacturer
    Date Cleared
    2023-07-13

    (28 days)

    Product Code
    Regulation Number
    880.5200
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K171109

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Praxiject™ 0.9% NaCl prefilled syringe with 0.9% Sodium Chloride Injection, USP, is intended only for flushing vascular access devices. May be placed on a sterile field.

    Device Description

    The Praxiject™ family of 0.9% NaCl prefilled syringes marketed in the U.S.A. includes the following models: 37043US (3 mL/5 cc), 3704US (5 mL/5 cc), 37053US (3 mL/10 cc), 37055 US (5 mL/10 cc), 3705CUS (10 mL/10 cc), 3705-1US (10 mL/10 cc) and 3706US (20 mL/20 cc). These devices are single use plastic piston syringes with a Luer lock connection fitting, prefilled to labeled volume with 0.9% Sodium Chloride Injection USP, with no preservatives (normal saline), and capped with a plastic tip cap. Model 3705-1US (10 mL/10 cc) is individually packaged in a heat-sealed foil pouch, all other models are individually packaged in a heat-sealed peel pouch. All Praxiject™ 0.9% NaCl prefilled syringes are terminally sterilized by gamma irradiation.

    AI/ML Overview

    The provided document is a 510(k) Pre-Market Notification for a medical device called Praxiject™ 0.9% NaCl, which is a prefilled saline flush syringe. The purpose of this notification is to demonstrate that the modified device is substantially equivalent to legally marketed predicate devices.

    The document does not describe a study involving an AI/ML device, a "test set" of data, or "ground truth" as typically understood in the context of evaluating AI/ML performance. Instead, it details the analytical and performance testing conducted for a physical medical device to ensure its safety and effectiveness.

    Therefore, many of the requested categories (2, 3, 4, 5, 6, 7, 8, 9) are not applicable to this document as they are specific to AI/ML device evaluation.

    However, I can extract information related to acceptance criteria and device performance based on the non-clinical testing summary.

    1. A table of acceptance criteria and the reported device performance

    The document provides a comprehensive table of "Device Specification," "Standard," and "Acceptance Criteria" under the "Summary of Non-Clinical Testing" section. The "reported device performance" is implicitly stated as meeting these acceptance criteria, as the conclusion states, "The conclusions drawn from the non-clinical testing demonstrate that the modified Praxiject™ 0.9% NaCl prefilled syringe, is as safe, as effective, and performs as well as or better than the legally marketed primary predicate device." This implies all listed acceptance criteria were met.

    Here is a summary of the acceptance criteria:

    Device SpecificationStandardAcceptance Criteria
    Piston Syringe Testing (Each production lot)
    Design and Performance RequirementsISO 7886-1; ISO 80369-7 (ISO 594-1 and ISO 594-2)Conformity to standards and device specifications
    Finished Device Testing (Each production lot)
    Appearance of SolutionUSP / Visual inspectionClear and colorless; Free of visible foreign solid particles
    Solution VolumeISO 7886-1, USP3 mL in 5 cc syringe: 3.0–3.4 mL
    3 mL in 10 cc syringe: 3.0-3.6 mL
    5 mL in 5 cc syringe: 5.0-5.6 mL
    5 mL in 10 cc syringe: 5.0-6.0 mL
    10 mL in 10 cc syringe: 10.0–11.0 mL
    20 mL in 20 cc syringe: 20.0-22.0 mL
    AssayUSP Sodium Chloride Injection0.855 - 0.945% (w/v)
    IdentificationUSP Sodium and ChlorideMeets USP requirements
    Bacterial EndotoxinsUSP , USP≤ 0.5 USP EU/mL
    Particulate MatterUSPParticles ≥ 10 µm: ≤ 6000/syringe;
    Particles ≥ 25 µm: ≤ 600/syringe
    pHUSP4.5 - 7.0
    Elemental ImpuritiesUSP and USP (Class I elements)Arsenic:
    Syringe Closure IntegrityISO 7886-1, ISO 594-2 (Adapted solution leakage test)No damage, no leakage past piston and syringe tip cap
    Pouch IntegrityASTM D3078 (Vacuum bubble emissions test)No stream of bubbles; no leaks
    Sterility and Shelf-life Testing (Design Verification and Validation)
    Sterility of Solution and Syringe ExteriorUSPSterile
    Sterilization Method ValidationISO 11137-1, ISO 11137-2, USP (Terminal sterilization by gamma radiation)SAL 10-6
    Shelf-life (Stability Study)FDA Guidance: Shelf Life of Medical Devices (1991); FDA Guidance: Q1D Bracketing and Matrixing Designs for Stability Testing of New Drug Substances and Products (2003)Device specifications must be maintained for the labeled shelf life
    Distribution Simulation Testing (Design Verification and Validation)
    Device & Package IntegrityASTM D4169 (Distribution Cycle 13, Assurance Level II); ISO 11607-1; ASTM F1886 (Visual seal integrity verification); ASTM D3078 (Vacuum bubble emissions test); ISO 7886-1 and ISO 594-2 (Syringe and tip cap integrity verification)No structural damage to shipping carton;
    Pouch/seal integrity - No seal defects; no stream of bubbles and no leaks during vacuum bubble emissions testing;
    Syringe integrity - No critical damage, no leaks past syringe cap or gasket;
    Luer lock (tip cap) connection - No cracks, no leaks
    Biocompatibility Testing (Design Verification and Validation)
    Biological EvaluationISO 10993-1; FDA Guidance: Use of International Standard ISO 10993-1, Biological evaluation of medical devices Part 1: Evaluation and testing within a risk management process (2020)Compliant process and evaluation for external communicating devices intended for indirect blood path contact with limited duration
    Chemical Characterization (Extractables/Leachables)ISO 10993-18, ISO 10993-17 USPAcceptable extractables/leachables profile; Negligible risk of health hazard
    CytotoxicityISO 10993-5Non-cytotoxic
    SensitizationISO 10993-10Non-sensitizer
    IrritationISO 10993-23Non-irritant
    HemolysisISO 10993-4 (ASTM F756)Non-hemolytic
    Acute Systemic ToxicityISO 10993-11Non-toxic
    PyrogenicityISO 10993-11 (USP )Non-pyrogenic

    2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    This information is not provided in a way that is applicable to an AI/ML "test set." The document describes non-clinical testing of a physical device. While specific sample sizes and testing methodologies are implied by the listed standards (e.g., ISO, ASTM, USP), the exact sample sizes for each test are not explicitly enumerated in this summary. Data provenance, in terms of country of origin or retrospective/prospective collection, is not relevant for this type of device submission.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

    Not applicable. "Ground truth" and "experts" are terms used in the context of evaluating diagnostic AI/ML models. This document describes the physical and chemical testing of a medical device.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    Not applicable. This refers to methods for resolving discrepancies in expert interpretations, which is not relevant for physical device testing.

    5. 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

    Not applicable. This is a type of study specifically for evaluating AI/ML diagnostic tools.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    Not applicable. This refers to the standalone performance of an AI/ML algorithm.

    7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)

    Not applicable. The "ground truth" for this device's performance is objective measurements against established international and USP standards for product quality, safety, and performance (e.g., pH, sterility, particle count, leakage, biocompatibility).

    8. The sample size for the training set

    Not applicable. This concept pertains to AI/ML model development.

    9. How the ground truth for the training set was established

    Not applicable. This concept pertains to AI/ML model development.

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