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510(k) Data Aggregation

    K Number
    K090157
    Date Cleared
    2009-05-04

    (102 days)

    Product Code
    Regulation Number
    880.5570
    Reference & Predicate Devices
    Predicate For
    N/A
    Why did this record match?
    Reference Devices :

    K943626

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

    The Isolyser Sharps Management Systems SMSm is a single-use, disposable, over-the-counter sharps container intended for use in clinical and non-clinical settings for the disposal of contaminated sharps and/or medical/red-bag wastes. The SMSm is marketed in five (5) different models: (1) Home Sharps Management (HSM) 800m, .98 liters, 3.45 x 2.72 x 7.29 (in.); (2) Sharps Management System (SMS) 2400m, 3.3 liters, 5 x 5x 10 (in.); (3) Sharps Mariagement System (SMS) 4000m, 5.97 liters, 8.47 x 5.99 x 8.87 (in.); (4) Sharps Management System (SMS) 10000m, 10.47 liters, 8.51 x 5.99 x 14.32 (in.); and (5) Sharps Management System (SMS) 5.3m, 21.1 liters, 11.93 x 9.87 x 14.68 (in.). Each SMSm model is designed to safely and securely contain used medical sharps and/or medical/red-bag wastes prior to removal and subsequent disposal. The SMS 5.3m is intended only for the storage and disposal of filled approved sharps containers and/or medical/red-bag wastes. Once an empty SMSm container has been filled with used medical sharps and/or medical/red-bag wastes, the entire SMSm container is intended to be packaged and mailed-back to WCM Waste and Compliance Management, Inc. for proper disposal. The HSM 800m, SMS 2400m, SMS 4000m, SMS 10000m, and SMS 5.3m are intended for home use by home health care providers and for use by small quantity health care providers such as dentists, medical doctors, veterinarians, and laboratories. The SMSm sharps containers are not intended for reuse.

    Device Description

    The Isolyser Home Sharps Management (HSM) 800m; Sharps Management System (SMS) 2400m; Sharps Management System (SMS) 4000m; Sharps Management System (SMS) 10000m are disposable non-reusable sharps containers that are intended to provide for safe and effective disposal of medical sharps and/or medical/red-bag wastes. The Isolyser Sharps Management System (SMS) 5.3m is intended only for the storage and disposal of filled approved sharps containers and/or medical/red-bag wastes. The SMS 5.3m is not intended for the direct disposal of used medical sharps. The HSM 800m, SMS 2400m, SMS 4000m, SMS 10000m, and SMS 5.3m are marketed for home use by home healthcare providers and for use in the offices, exam. and patient rooms of small quantity generators such as medical doctors, dentists, veterinarians, and laboratories.

    The SMSm container is stable, puncture resistant (SMS 5,3m not tested) and leak-proof on the sides and bottom. Used medical sharps and/or medical/red-bag wastes are placed vertically into the opening on the top of the container. Once placed into the container, the SMSm does not require users to reach by hand into the container to retrieve contaminated sharps and/or medical/red-bag wastes. Once the container is full, the SMSm is intended to be mailed back to WCM Waste and Compliance Management, Inc. for proper disposal. The overall design and specifications for the Isolyser SMSm meet OSHA Bloodborne Pathogens Standard as well as the American Society for Testing and Materials Standard F2132-01(2008) (SMS 5.3m not tested). All SMSm containers have BIOHAZARD warning labels clearly visible with lettering in contrasting color and are affixed by adhesives to the sides of the SMSm container.

    AI/ML Overview

    The provided text describes a 510(k) submission for Isolyser SMSm Sharps Containers. This is a premarket notification for a medical device and, as such, focuses on demonstrating substantial equivalence to predicate devices rather than proving device performance through a detailed clinical study with acceptance criteria.

    Therefore, many of the requested elements (acceptance criteria, specific study design, sample sizes, ground truth establishment, MRMC studies, standalone performance) are not applicable in the context of this 510(k) application. This submission aims to show that the new device is as safe and effective as a legally marketed predicate device, primarily through descriptive data and compliance with standards, rather than generating new performance data in a clinical trial setting.

    Here's a breakdown of the information that is available and a clear statement regarding what is not applicable:


    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance CriteriaReported Device Performance
    Not Applicable (N/A): As a 510(k) submission, the primary goal is to demonstrate substantial equivalence to a predicate device, not to meet specific quantitative performance acceptance criteria from a primary clinical study. The device is assessed against existing standards and the characteristics of the predicate.Meets OSHA Bloodborne Pathogens Standard: The overall design and specifications meet this standard.
    Meets American Society for Testing and Materials Standard F2132-01(2008): (SMS 5.3m not tested against this specific standard). This standard likely relates to sharps container design and performance characteristics.
    Stable: (Implied by design and compliance with standards).
    Puncture Resistant: (SMS 5.3m not tested).
    Leak-proof on the sides and bottom.
    Does not require users to reach by hand into the container to retrieve contaminated sharps and/or medical/red-bag wastes.
    Has BIOHAZARD warning labels clearly visible with lettering in contrasting color and affixed by adhesives.
    Identical technological characteristics to predicate Isolyser SMS containers (K943626) for HSM 800m, SMS 2400m, SMS 4000m, and SMS 10000m in terms of size, composition, and design.
    Similar technological characteristics to predicate Sharps Disposal by Mail 15000 for SMS 5.3m (receptacle for filled sharps containers and/or medical/red-bag wastes).

    2. Sample size used for the test set and the data provenance

    • Not Applicable (N/A): This submission does not describe a traditional "test set" from a clinical or performance study with a defined sample size. The substantial equivalence is based on engineering design, material properties, and comparison to predicate devices and standards.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    • Not Applicable (N/A): No ground truth establishment by experts for a test set is described. The evaluation is based on design specifications, material properties, and compliance with recognized standards.

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

    • Not Applicable (N/A): No test set requiring expert adjudication is described.

    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 (N/A): This device is a physical sharps container, not an AI-powered diagnostic tool. Therefore, no MRMC study, human reader improvement, or AI assistance is relevant.

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

    • Not Applicable (N/A): This device is a physical sharps container, not an algorithm, so standalone performance in this context is irrelevant.

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

    • Not Applicable (N/A): As explained, traditional "ground truth" derived from clinical data is not applicable here. The "truth" or validation relies on:
      • Compliance with recognized industry standards: OSHA Bloodborne Pathogens Standard and ASTM F2132-01(2008).
      • Comparison to predicate device characteristics: Identity or similarity in intended use, function, basic composition, size, and design.

    8. The sample size for the training set

    • Not Applicable (N/A): There is no "training set" as this is not an AI/machine learning device. The development process would have involved engineering design, prototyping, and testing of physical units to ensure compliance with standards, but not a data-driven training set in the computational sense.

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

    • Not Applicable (N/A): No training set as per explanation in point 8.
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