K123300 · Becton, Dickinson & CO · FMI · Jan 18, 2013 · General Hospital
Device Facts
Record ID
K123300
Device Name
BD PEN NEEDLE
Applicant
Becton, Dickinson & CO
Product Code
FMI · General Hospital
Decision Date
Jan 18, 2013
Decision
SESE
Submission Type
Special
Regulation
21 CFR 880.5570
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
BD Pen Needle is intended for use with pen injector device for subcutaneous injection of drugs, including insulin and exenatide.
Device Story
BD Pen Needles are single-use, sterile, hypodermic needles designed for attachment to pen injectors for subcutaneous drug delivery (e.g., insulin, exenatide). The device consists of a double-ended cannula assembled into an injection-molded hub with internal threads for secure attachment to a pen cartridge. The non-patient end penetrates the cartridge septum, while the patient end delivers the medication. The device features PentaPoint bevel geometry and Extra Thin Wall (XTW) construction. It is used by patients, caregivers, or clinicians in home or clinical settings. The needle is protected by an inner shield and outer cover, which also facilitates removal from the pen. The device benefits patients by providing a sterile, reliable interface for self-administered subcutaneous injections.
Clinical Evidence
Bench testing only. Performance evaluated against ISO 11608-2 and ISO 7864 standards, including tubing dimensions, lumen patency, needle point sharpness, cannula load testing (with and without pre-conditioning), lubrication, compatibility (torque), and penetration testing.
Technological Characteristics
Single-lumen hypodermic needle; 31G and 32G gauges; Extra Thin Wall (XTW) cannula; PentaPoint bevel geometry; silicone-based lubricant; injection-molded hub and shields; gamma irradiation sterilization (SAL 10^-6); conforms to ISO 11608-2 and ISO 7864.
Indications for Use
Indicated for subcutaneous injection of drugs, including insulin and exenatide, using a pen injector device. Suitable for use by consumers, caregivers, and healthcare professionals.
Regulatory Classification
Identification
A hypodermic single lumen needle is a device intended to inject fluids into, or withdraw fluids from, parts of the body below the surface of the skin. The device consists of a metal tube that is sharpened at one end and at the other end joined to a female connector (hub) designed to mate with a male connector (nozzle) of a piston syringe or an intravascular administration set.
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K123300
1 Becton Drive Franklin Lakes, New Jersey 07417 tel: 201.847.6800 www.bd.com
1.
# JAN 1 8 2013
Image /page/0/Picture/3 description: The image shows the BD logo, which consists of a stylized sun and a person with outstretched arms inside a circle, followed by the letters "BD" in bold, sans-serif font. Below the logo, there is the text "Helping all people". The logo is black and white.
Helping all people live healthy lives
## 510(K) SUMMARY OF SAFETY AND EFFECTIVENESS
Date of Summary Preparation: November 08, 2012
- Submitted By: Pasquale Amato
Staff Regulatory Affairs Specialist
Becton, Dickinson and Company 1 Becton Drive Franklin Lakes, NJ 07417
201-847-4513 Phone: Fax: 201-848-8830
## Contact Person:
Eileen Hiller Director, Regulatory Affairs 201-847- 4570 Phone: 201-847- 5307 Fax: Email: Eileen Hiller@BD.com
#### 2. Device Name:
Trade Name:
BD 31G and 32G Extra Thin Wall (XTW) Pen Needles with PentaPoint™
Common Names:
Insulin Pen Needle
Classification Name: Needle, Hypodermic, Single Lumen
Classification:
Class II, 21 CFR 880.5570 FMI
#### 3. Predicate Device:
BD Pen Needle- K100005 and K051899 Manufactured by: Becton, Dickinson and Company
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#### 4. Device Description:
BD pen needles are single use, sterile, medical devices designed to be used in conjunction with pen injectors and pen cartridges. Pen needles are used by consumers, caregivers and health care professionals. They are offered in various gauge sizes (29G, 30G, 31G and 32G) and lengths (4mm, 5mm, 8mm and 12.7mm). BD Pen Needles are sterile (gamma irradiation sterilization), non-toxic and non-pyrogenic.
The pen needle assembly consists of a doubled-ended cannula that is assembled into an injection-molded hub using adhesive. The hub has internal threads, which allow it to be screwed onto the pen-injector device. This allows the Non Patient (NP) end of the cannula to penetrate through the rubber septum of the cartridge. The Patient end and NP end of the cannula are lubricated using silicone based lubes for ease of injection and rubber septum penetration. An injection-molded inner shield is assembled over the Patient end of the Cannula to protect the point from damage and accidental needle-sticks. This needle assembly is inserted into a protective injection-molded outer cover and sealed with a peel-away (tear drop) label to provide sterile barrier and tamper evidence. The outer cover is also used to remove the hub and cannula from the pen. The peel-away label is pre-printed with information, which includes the lot number and needle gauge / length. The individual needle assemblies are packaged in polybags and / or cartons, and placed into shippers with appropriate labeling. The shipper cases are palletized and sterilized to an SAL 10 by gamma irradiation.
The purpose of this Special 510(k) is to expand the needle range to include the 31G and 32G Extra Thin Wall (XTW) pen needles with PentaPoint™ design. The intended use for the modified device remains the same as the predicate devices.
Also it is BD's intent to notify the Agency of a non-significant change to the cannula point bevel geometry from 3 bevels (PentaPoint™).
#### 5. Statement of Intended Use/Indications for Use:
BD Pen Needle is intended for use with pen injector device for subcutaneous injection of drugs, including insulin and exenatide.
#### Technological Characteristics: 6.
The principal device of this premarket notification is the result of a design change to the predicate devices conducted in accordance with Quality System Regulations. The BD 31G and 32G XTW Pen Needle with PentaPoint™, modified, is equivalent to the predicate devices, given that:
- Has the same intended use and indications for use as the predicate . devices
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- Uses the same operating principles .
- Incorporates the same basic design .
- Is manufactured from the same materials ●
- Is sterilized using the same mode .
- Is sterilized with SAL of 106 .
- Is packaged using same unit and case materials ●
- Same fundamental scientific technology .
The only design differences between the modified BD 31G and 32G XTW Pen Needles with PentaPoint™ and the predicate devices are the inner diameter and needle point.
#### 7. Performance:
Bench tests relating to the performance of the BD 31G and 32G XTW Pen Needle with PentaPoint™ were conducted.
The principal device demonstrated equivalent performance to the predicate devices during bench testing. Bench testing consisted of:
| Tubing diameters | Per ISO 11608-2, section 4.3.1 (tubing<br>dimensions meet OD and ID requirement). | |
|----------------------------------------------|---------------------------------------------------------------------------------------------------------------------------|--|
| Patency of lumen | Per ISO 11608-2, section 4.4 (stylet, having a<br>diameter equivalent to 80% ±2% of lumen ID<br>passes through freely). | |
| Needle points | Per ISO 11608-2, section 4.5 (visually sharp at<br>2.5X magnification, designed to minimize<br>coring and fragmentation). | |
| Type A Needle (length) | Per ISO 11608-2, section 4.3.2 (patient end<br>within indicated length ± 1.25 mm) | |
| Cannula load test<br>(No pre-conditioning) | Per ISO 11608-2, section 4.9 and 9.<br>ISO 7864 Section 13.1(cannula holds force of<br>22N for 5 seconds). | |
| Cannula load test<br>(with pre-conditioning) | Per ISO 11608-2, section 4.9 and 9.<br>ISO 7864 section 13(cannula holds force of<br>22N for 5 seconds). | |
| Lubrication | Per ISO 11608-2, section 4.7 (no visible<br>droplets inside/outside surfaces of cannula). | |
| Compatibility Testing | Per ISO 11608-2, section 4.10 (connectivity<br>(torque). | |
| Penetration Testing | Per BD Test Method TP700279 | |
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#### 8. Substantial Equivalence:
The vast similarities of the BD 31G and 32G XTW Pen Needles with PentaPoint™ to the predicate devices support the substantial equivalence in intended use, function and basic composition. The testing to voluntary standards, ISO 11608-2 and ISO 7864 provides additional evidence that the BD 31G and 32G XTW Pen Needles with PentaPoint™ is substantially equivalent to the predicate devices in terms of safety, efficacy and performance.
The differences between the BD 31G and 32G XTW Pen Needles with PentaPoint™ and the predicate devices do not raise new issues of safety or effectiveness.
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### DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/4/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized depiction of an eagle or bird-like figure with three curved lines representing its wings or body. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular fashion around the bird-like figure.
### Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
### January 18, 2013
Becton Dickinson & Company Ms. Pasquale Amato BD Medical Diabetes Care 1 Becton Drive MC 372 Franklin Lakes NJ 07417-1880
Re: K123300
Trade/Device Name: BD 31G and 32G XTW Pen Needles Regulation Number: 21 CFR 880.5570 Regulation Name: Hypodermic Single Lumen Needle Regulatory Class: II . Product Code: FMI Dated: December 18, 2012 Received: December 19, 2012
Dear Ms. Amato:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
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Page 2 - Ms. Amato
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled. "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely yours,
Anthong ls min
Anthony D. Watson, B.S., M.S., M.B.A. Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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## Indications for Use
510(k) Number (if known): K | 2 Z3 OD
Device Name: BD 31G and 32G XTW Pen Needles
Indications For Use:
BD Pen Needle is intended for use with pen injector device for subcutaneous injection of drugs, including insulin and exenatide.
Prescription Use (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use X (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED) : 上一篇: 上一篇:
Concurrence of CDRH, Office of Device Evaluation (ODE)
| | | Page 1 of <u>1</u> |
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|--|--|--------------------|
| Date: | 2013.01.18 |
|-------|-----------------------------------|
| | for Rick Chapman 14:27:04 -05'00' |
(Division Sign-Off)
Division of Anesthesiology, General Hospital
Infection Control, Dental Devices
| 510(k) Number: | K123300 |
|----------------|---------|
|----------------|---------|
0 4 0
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.