K152877 · Shina Med Corporation · FMI · Jun 7, 2016 · General Hospital
Device Facts
Record ID
K152877
Device Name
SureFine Pen Needle
Applicant
Shina Med Corporation
Product Code
FMI · General Hospital
Decision Date
Jun 7, 2016
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 880.5570
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
SureFine Pen Needle is intended for use with a pen injector for the subcutaneous injection of insulin.
Device Story
SureFine Pen Needle is a sterile, single-use, disposable hypodermic needle assembly consisting of a needle, hub, and protective shield. It is designed to be screwed onto a compatible pen injector for subcutaneous insulin delivery. The device is used in clinical or home settings by patients or healthcare providers. It provides a fluid path for insulin from the pen cartridge to the patient. The device is offered in various gauges (29G-32G) and lengths (4mm-12.7mm) to accommodate different injection requirements. It is sterilized via ethylene oxide gas.
Clinical Evidence
No clinical data. Bench testing only. Performance testing conducted per ISO 7864:1993, ISO 9626:1991, and ISO 11608-2:2012. Biocompatibility testing performed per ISO 10993-1 (cytotoxicity, irritation, sensitization, systemic toxicity, blood interaction) and USP <151> (pyrogen test). Sterilization validated per ISO 11135.
Indicated for patients requiring subcutaneous insulin injection via a pen injector.
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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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
June 7, 2016
Shina Med Corporation % Priscilla Chung Regulatory Affairs Consultant LK Consulting Group USA, Inc. 2651 East Chapman Avenue, Suite 110 Fullerton, California 92831
Re: K152877
Trade/Device Name: SureFine Pen Needle Regulation Number: 21 CFR 880.5570 Regulation Name: Hypodermic Single Lumen Needle Regulatory Class: Class II Product Code: FMI Dated: February 29, 2016 Received: March 9, 2016
Dear Priscilla Chung:
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.
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 devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in
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the quality systems (OS) 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" (21 CFR 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/ResourcesforYou/Industry/default.htm.
Sincerely yours,
Susan Runno DDS, MA
Erin I. Keith, M.S. 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)
K152877
Device Name
SureFine Pen Needle
Indications for Use (Describe)
SureFine Pen Needle is intended for use with a pen injector for the subcutaneous injection of insulin.
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)
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# 510(K) SUMMARY (K152877)
#### 1. Submitted by:
June 5, 2016
Il-hwan, Jeong / Quality Management Representative SHINA MED CORPORATION 455-30, Bogaewonsam-ro, Bogae-myun, Anseong-si, Gyeonggido, 456-871, Republic of Korea Phone: +82 31 8057 2125 Fax : + 82 31 8057 2150
#### 2. US Agent/Contact Person:
Priscilla Chung LK Consulting Group USA, Inc. 2651 E Chapman Ave Ste 110, Fullerton CA 92831
### 3. Device Name:
- Trade Name : SureFine Pen Needle • Classification : Class II · Classification Name : Needle, Hypodermic, Single Lumen • Product Code : FMI • Regulation Number : 21 CFR 880.5570 · Review Panel : General Hospital
## 3. Predicate Device:
ShinaPen® (K113186) manufactured by SHINA CORPORATION
#### Device Description: 4.
The SureFine Pen Needle is designed for use with a pen injector for the subcutaneous injection of insulin. The pen needle consists of a needle, hub, and shield assembly. Blister paper covers primary container. The primary container maintains sterility of the needle because primary container covers the hub and the needle tube with blister paper sealed on the opening hole of primary container.
The needle hub can be connected with the pen. The hub has internal threads, which allows it to be screwed onto the pen. The needle shield is intended to provide physical protection to the needle tube.
The SureFine Pen Needle is offered in various gauges sizes (29G, 30G, 32G) and Lengths (4mm, 6mm, 8mm, 12.7mm). These are sterile (Eo gas sterilization) and non-pyrogenic. The pen needles are disposable, single use devices.
#### 5. Intended For Use:
The SureFine Pen Needle is intended for use with a pen injector for the subcutaneous injection of insulin.
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# 6. Technological Characteristics:
The SureFine Pen Needle is substantially equivalent to previously marketed device, ShinaPen® (K113186) manufactured by SHINA CORPORATION. The device design, materials of construction and performance specifications are substantially equivalent to the predicate device.
| Device Name | | Subject Device | Predicate Device |
|-----------------------------------------------------------|----------------------|------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------|
| Manufacturer | | SHINA MED CORPORATION | SHINA CORPORATION |
| 510(k) Number | | K152877 | K113186 |
| Device Name | | SureFine Pen Needle | ShinaPen® |
| Intended for use | | The SureFine Pen Needle is intended<br>for use with a pen injector for the<br>subcutaneous injection of insulin. | The ShinaPen® is designed<br>for use with a pen injector for the<br>subcutaneous injection of insulin. |
| Gauge | | 29G, 30G, 31G, 32G | 29G, 30G, 31G, 32G |
| Raw<br>Material | Needle<br>tube | STS304 | STS304 |
| | Hub | Polypropylene | Polypropylene |
| | Primary<br>container | Polyethylene | Polyethylene |
| | Silicone | Poly di-methylsiloxane | Poly di-methylsiloxane |
| Sterilization | | Ethylene oxide gas<br>(SAL 10-6) | Ethylene oxide gas<br>(SAL 10-6) |
| Tip configuration<br>(The patient-end<br>of the needle) | | Image: Tip of needle | Image: Tip of needle |
| Tip configuration<br>(The cartridge-end<br>of the needle) | | Image: Cartridge end of needle | Image: Cartridge end of needle |
| | Min | -27.2g | -27.2g |
| Needle<br>Sharpness | Average | -29.20g | -29.20g |
| | Max | -31.1g | -31.1g |
| Length | | 4mm, 6mm, 8mm, 12.7mm | 4mm, 6mm, 8mm, 12.7mm |
| Gauge | | 29G, 30G, 31G, 32G | 29G, 30G, 31G, 32G |
| Needle shield color | | Red / Yellow / Colorless /<br>Blue / Blue / Violet Green Grey | Red / Yellow / Colorless /<br>Blue / Blue / Violet Green Grey |
| Needle shield<br>dimensions | | I.D(2.7mm), O.D(4mm), L(19.35mm) | I.D(2.7mm), O.D(4mm), L(19.35mm) |
| | Min | 5.8N | 5.8N |
| Needle<br>shield<br>strength | Average | 8.16N | 8.16N |
| | Max | | |
| Hub/needle<br>bond<br>strength | Max | 9.8N | 9.8N |
| | Min | 47.5N | 47.5N |
| | Average | 58.02N | 58.02N |
| | Max | 61.9N | 61.9N |
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# 7. Testing
The SureFine Pen Needle has been designed and tested to meet the applicable requirements of voluntary standards and FDA Guidance documents applicable to the subject and predicate devices. The results of the non-clinical testing supported the conclusion of substantial equivalence.
### Performance Testing
SureFine Pen Needle has been designed and successfully tested to meet the applicable requirements outlined in ISO 7864:1993, ISO 9626:1991 and ISO 11608-2:2012.
- Tests performed per ISO 7864:1993:
- · ISO 7864:1993 Clause 4 Cleanliness
- · ISO 7864:1993 Clause 5 Limits for acidity or alkalinity
- · ISO 7864:1993 Clause 6 Limits for extractable metals
- · ISO 7864:1993 Clause 7 Size designation
- · ISO 7864:1993 Clause 11.3 Freedom from defects
- · ISO 7864:1993 Clause 11.4 Lubricant
- · ISO 7864:1993 Clause 12 Needle point
- · ISO 7864:1993 Clause 13.1 Bond between hub and needle tube
- · ISO 7864:1993 Clause 13.2 a) Patency of lumen
- Tests performed per ISO 9626:1991 Amd1:2001 (Stainless tubing for SureFine Pen Needle)
- · ISO 9626:1991 Amd1:2001 Clause 3 Materials
- · ISO 9626:1991 Amd1:2001 Clause 4 Surface finish
- · ISO 9626:1991 Amd1:2001 Clause 5 Cleanliness
- · ISO 9626:1991 Amd1:2001 Clause 6 Limits for acidity and alkalinity
- · ISO 9626:1991 Amd1:2001 Clause 7 Size designation
- · ISO 9626:1991 Amd1:2001 Clause 8 Dimensions
- · ISO 9626:1991 Amd1:2001 Clause 9 Stiffness
- · ISO 9626:1991 Amd1:2001 Clause 10 Resistance to breakage
- · ISO 9626:1991 Amd1:2001 Clause 11 Resistance to corrosion
- Tests performed per ISO 11608-2:2012
- · ISO 11608-2:2012 Clause 4.2 Dimensions / Clause 4.2.2 Dimensions for needles
- · ISO 11608-2:2012 Clause 4.3 Determination of flow rate through the needle
- · ISO 11608-2:2012 Clause 4.4 Bond between hub and needle tube
- · ISO 11608-2:2012 Clause 4.5 Needle point
- · ISO 11608-2:2012 Clause 4.6 Freedom from defects
- · ISO 11608-2:2012 Clause 4.7 Lubrication
- · ISO 11608-2:2012 Clause 4.8 Dislocation of measuring point at patient end
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- · ISO 11608-2:2012 Clause 4.9 Determination of functional compatibility with needle-based injection systems
- · ISO 11608-2:2012 Clause 4.10 Ease of assembly and disassembly
And the following insulin injectors are successfully tested and found to be functionally compatible with the following insulin pen-injectors according to ISO 11608-2:2012 section 4.9.
- · HUMULIN PEN (3ml) Eli Lilly
- LANTUS SOLOSTAR (3ml) Sanofi Aventis
- FlexPen (3ml) Novo Nordisk
# Biocompatibility Testing
The material of the SureFine Pen Needle has successfully passed testing as outlined in ISO 10993-1 for devices categorized as External communicating devices, Limited exposure.
- · ISO 10993-5:2009 Biological evaluation of medical devices -- Part 5: Tests for in vitro cytotoxicity
- · ISO 10993-10: 2010 Biological evaluation of medical devices Part 10: Test for Irritation and Sensitization 5.4 Intracutaneous reactivity test
- · ISO 10993-10 2010 Biological evaluation of medical devices Part 10: Teat for Irritation and Sensitization 6.2 Maximization sensitization test
- · ISO 10993-11 2006 Biological evaluation of medical devices -- Part 11: Tests for systemic toxicity 6.5 Acute systemic toxicity
- · ISO 10993-4:2002 Biological evaluation of medical devices-Part 4: Selection of tests for interactions with blood.
- · The United States Pharmacopeia <151> (Pyrogen test)
# Sterilization and Shelf-life Testing
Sterilization of the SureFine Pen Needle has been validated using the half-cycle method as outlined in ISO11135. Testing demonstrated maximum levels of residues of ethylene chlorohydrins do not exceed the limits presented in IS010993-7. LAL testing was performed to demonstrate that bacterial endotoxins are adequately mitigated. Shelf-life testing supports a shelf-life of 3-years after sterilization.
## Clinical Data
No prospective clinical trials were conducted in support of this Traditional 510(k).
## 8. Discussion
SureFine Pen Needle has the same intended use, technological characteristics, materials of construction and performance specifications as the predicate K113186 (Shina Pen Needle) and thus it performs in a substantial equivalent manner to the predicate device.
# 9. Conclusion
Based on the information provided in this premarket notification, SHINA MED CORPORATION concludes that the SureFine Pen Needle is substantially equivalent to predicate device.
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.