NeoMed NeoConnect Enteral Syringes with ENFit Connector
Applicant
Neomed, Inc.
Product Code
PNR · Gastroenterology, Urology
Decision Date
Apr 9, 2015
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 876.5980
Device Class
Class 2
Attributes
Therapeutic, Pediatric
Indications for Use
The device is indicated for use as a dispenser, a measuring device. It is used to deliver fluids into the body via extension sets and feeding tubes in neonatal and small pediatric patients.
Device Story
NeoConnect™ Enteral Syringes are piston-style syringes (0.5ml to 100ml) used for dispensing and measuring fluids. The device features an integral female ENFit connector tip, designed to interface exclusively with male ENFit feeding tubes and extension sets. This dedicated connection system prevents wrong-route administration of fluids. Used in hospital settings, the device is operated by clinicians to deliver enteral nutrition or medication. The translucent barrel allows for visual verification of fluid volume. By ensuring a secure, non-interchangeable connection, the device reduces the risk of misconnection errors, thereby improving patient safety during enteral feeding or medication administration.
Clinical Evidence
Bench testing only. Testing included biocompatibility (ISO 10993-5, -10, -11), chemical extractables/leachables, and finished device verification (capacity, scale, piston fit, leakage). ENFit-specific testing included misconnection assessment, stress cracking, axial load resistance, unscrewing resistance, and overriding resistance. Human factors and usability validation were performed to confirm safe operation.
Technological Characteristics
Piston-style syringe; materials: Polypropylene (Class VI) barrel/plunger, Silicone (Class VI) gasket, Polydimethylsiloxane lubricant. ENFit connector compliant with AAMI/CN3:2014 (PS) Part 3 Table B.2. Sterilization: Ethylene Oxide (EO) to 10-6 SAL. Sizes: 0.5ml to 100ml.
Indications for Use
Indicated for neonatal and small pediatric patients requiring fluid delivery via extension sets and feeding tubes.
Regulatory Classification
Identification
A gastrointestinal tube and accessories is a device that consists of flexible or semi-rigid tubing used for instilling fluids into, withdrawing fluids from, splinting, or suppressing bleeding of the alimentary tract. This device may incorporate an integral inflatable balloon for retention or hemostasis. This generic type of device includes the hemostatic bag, irrigation and aspiration catheter (gastric, colonic, etc.), rectal catheter, sterile infant gavage set, gastrointestinal string and tubes to locate internal bleeding, double lumen tube for intestinal decompression or intubation, feeding tube, gastroenterostomy tube, Levine tube, nasogastric tube, single lumen tube with mercury weight balloon for intestinal intubation or decompression, and gastro-urological irrigation tray (for gastrological use).
Special Controls
*Classification.* (1) Class II (special controls). The barium enema retention catheter and tip with or without a bag that is a gastrointestinal tube and accessory or a gastronomy tube holder accessory is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.(2) Class I (general controls) for the dissolvable nasogastric feed tube guide for the nasogastric tube. The class I device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to § 876.9.
{0}------------------------------------------------
Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle or bird-like symbol with three curved lines representing its body and wings. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular pattern around the symbol.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
September 29, 2016
NeoMed, Inc. Melinda Harrison Smith, RAC, ASQ-CBA Director, Quality and Regulatory Affairs 100 Londonderry Court, Suite 112 Woodstock, GA 30188
K143344 Re:
Trade/Device Name: NeoMed NeoConnect™ Enteral Syringes with ENFit Connector Regulation Number: 21 CFR §876.5980 Regulation Name: Gastrointestinal tube and accessories Regulatory Class: II Product Code: PNR Dated: March 11, 2015 Received: March 13, 2015
Dear Melinda Harrison Smith,
This letter corrects our substantially equivalent letter of April 7, 2015.
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 for use bared in the 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 I he goneral ocharing 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.
{1}------------------------------------------------
## Page 2 - Melinda Harrison Smith, RAC, ASQ-CBA
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 contact the Division of Industry and Consumer Education 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. 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 Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely,
For Division
Douglas Silverstein -S 2016.09. -04'00'
Benjamin R. Fisher, Ph.D. Director Division of Reproductive, Gastro-Renal, and Urological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
{2}------------------------------------------------
# Indications for Use
510(k) Number (if known) K143344
### Device Name
NeoMed NeoConnect™ Enteral Syringes with ENFit Connector
Indications for Use (Describe)
The device is indicated for use as a dispenser, a measuring device. It is used to deliver fluids into the body via extension sets and feeding tubes in neonatal and small pediatric patients.
| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------|--|
|-------------------------------------------------|--|
X Prescription Use (Part 21 CFR 801 Subpart D)
| Over-The-Counter Use (21 CFR 801 Subpart C)
## CONTINUE ON A SEPARATE PAGE IF NEEDED.
This section applies only to requirements of the Paperwork Reduction Act of 1995.
## *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.*
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
> Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov
"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."
{3}------------------------------------------------
# TRADITIONAL 510(K) SUMMARY (21 CFR § 807.92)
| I. SUBMITTER | NeoMed, Inc.<br>100 Londonderry Court<br>Suite 112<br>Woodstock, GA 30188<br>Tel: 770-516-2225<br>Fax: 770-516-2448 |
|---------------------------------------|---------------------------------------------------------------------------------------------------------------------|
| Contact: | Melinda Harrison Smith, RAC, CBA<br>mharrison@neomedinc.com |
| Date Prepared: | 18 November 2014 |
| Establishment<br>Registration Number: | 3006520777 |
#### ll. DEVICE
| Trade Name: | NeoConnect™ Enteral Syringes |
|----------------------|-----------------------------------------------------------|
| Common Name: | Enteral Syringe |
| Classification Name: | Gastrointestinal tube and accessories (21 CFR § 876.5980) |
| Regulatory Class: | II |
| Product Code : | PIF |
#### lll. PREDICATE DEVICE
NeoMed Oral / Enteral Syringe (0.5ml to 100ml) (K122373) This predicate had not been subject to a design-related recall.
#### IV. DEVICE DESCRIPTION
The NeoMed NeoConnect™ Enteral Syringes are standard piston style syringes consisting of a syringe barrel with integral ENFit syringe tip, syringe plunger, syringe gasket, and supplied with a syringe tip cap. They are provided in varying sizes ranging from 0.5ml to 100ml nominal capacity. The integral syringe tip is a female ENFit connector which is compatible only with feeding tubes and extension sets that have ENFit male connectors to form a dedicated system that prevents wrong-route administration of fluids. They possess translucent barrels to provide visualization of fluid contents and volume.
#### V. INDICATIONS FOR USE
The device is indicated for use as a dispenser, a measuring device and a fluid transfer device. It is used to deliver fluids into the body via extension sets and feeding tubes in neonatal and small pediatric patients.
{4}------------------------------------------------
### VI. COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE
| Feature | PREDICATE DEVICE | SUBJECT DEVICE |
|-----------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Indications for Use /<br>Intended Use<br>Statement | The device is indicated for use as<br>a dispenser, a measuring device<br>and an oral fluid transfer device. It<br>is used to inject fluids into the body<br>via extension sets and feeding<br>tubes in neonatal and small<br>pediatric patients. | The device is indicated for use as a<br>dispenser, a measuring device and<br>a fluid transfer device. It is used to<br>deliver fluids into the body via<br>extension sets and feeding tubes in<br>neonatal and small pediatric<br>patients. |
| Patient Population /<br>Environment of Use | Neonates and Small Pediatrics/<br>Hospital, Disposable and for single<br>patient use only | Neonates and Small Pediatrics/<br>Hospital, Disposable and for single<br>patient use only |
| Description of Device | An oral / enteral syringe consisting<br>of a syringe barrel with integral tip<br>(tapered), plunger, gasket, barrel<br>lubricant and supplied with a<br>syringe tip cap. | An enteral syringe consisting of a<br>syringe barrel with integral tip<br>(ENFit), plunger, gasket, barrel<br>lubricant and supplied with a<br>syringe tip cap. |
| Syringe Type | Oral / Enteral Syringe | Enteral Syringe |
| Principle of Operation | Piston Style Syringe | Piston Style Syringe |
| Syringe Tip Type | Tapered | ENFit<br>(Dimensional compliance to<br>AAMI/CN3:2014 (PS) Part 3 Table<br>B.2 Female Enteral Small-Bore<br>Connector). |
| Syringe Sizes<br>(nominal volumes) | 0.5ml to 100ml sizes | 0.5ml to 100ml sizes |
| Syringe Barrel with<br>integral syringe tip and<br>volume graduations | Barrel - Polypropylene, class VI<br>Graduation Ink - Orange | Barrel - Polypropylene, class VI<br>Graduation Ink - Orange or Purple |
| Integral Syringe Tip<br>Flexural Modulus | 9500 Kg/cm² (932 MPa) | 9500 Kg/cm² (932 MPa) |
| Syringe Plunger | Inert Polypropylene, class VI<br>White Colorant | Inert Polypropylene, class VI<br>White Colorant |
| Syringe Gasket | Silicone, Class VI, Black Colorant | Silicone, class VI, Black Colorant |
| Syringe Tip Cap | Inert Polypropylene, class VI<br>Orange Colorant | Inert Polypropylene, class VI<br>Orange or Purple Colorant |
| Barrel Lubricant | Polydimethylsiloxane class VI | Polydimethylsiloxane class VI |
| Packaging Material | Tyvek or medical grade paper /<br>film primary pouch, Double Flute<br>paper corrugate case box | Tyvek or medical grade paper / film<br>primary pouch, Double Flute paper<br>corrugate case box |
| Sterilization Method,<br>SAL | Ethylene Oxide (EO), 10-6 SAL | Ethylene Oxide (EO), 10-6 SAL |
| Human Factors and<br>Usability | Design Validation | Design Validation<br>Device Master File #MAF2258 |
| Risk Analysis | Device Risk Assessment including<br>Design and User FMEA | Device Risk Assessment including<br>Design and User FMEA<br>Device Master File #MAF2258 |
{5}------------------------------------------------
#### VII. PERFORMACE DATA (BENCH)
The following performance testing was conducted on the NeoConnect™ Enteral Syringe:
- . Finished Device
O
- Risk Analysis including design, user and process FMEA (Failure Modes and o Effects Analysis) in accordance with EN ISO 14971:2012
- o Human Factors and Usability Validation
- Biocompatibility o
- · ISO 10993-5: Cytotoxicity
- ISO 10993-10: Irritation and sensitization .
- . ISO 10993-11: Acute Toxicity
- Chemical Testing o
- Extractables and Leachables .
- Finished Device Verification Testing
- Critical Dimension verification .
- . Ink Adhesion
- =
- Capacity Tolerance ●
- Graduated Scale ●
- Piston Fit in Barrel .
- Air and Liquid Leakage Testing ●
- Syringe Tip (ENFit connector) ●
- Enteral Connector Misconnection Assessment o
- ENFit Connector Risk Management Report (including misconnections FMEA) O
- Human Factors Validation Study o
- Dimensional verification O
- Liquid Leakage Testing O
- O Stress Cracking
- Resistance to separation from axial load O
- Resistance to separation form unscrewing O
- Resistance to overriding O
- Disconnection by unscrewing o
#### CONCLUSIONS VIII.
The NeoMed NeoConnect™ Enteral Syringes are substantially equivalent to the NeoMed Oral / Enteral Syringe (K122373).
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.