K211890 · Promisemed Hangzhou Meditech Co., Ltd. · MMK · Nov 17, 2021 · General Hospital
Device Facts
Record ID
K211890
Device Name
Promisemed Sharps container
Applicant
Promisemed Hangzhou Meditech Co., Ltd.
Product Code
MMK · General Hospital
Decision Date
Nov 17, 2021
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 880.5570
Device Class
Class 2
Indications for Use
It is intended to be used for health care purposes for safe disposal of hazardous sharps such as hypodermic needles, syringes, lancets and blood needles.
Device Story
Promisemed Sharps Container is a single-use, disposable, non-sterile receptacle for hazardous medical sharps; includes hypodermic needles, syringes, and lancets. Device consists of injection-molded polypropylene base, lid, closure, and handle. Used in healthcare facilities by qualified personnel to safely contain sharps during transport to disposal. Provides physical enclosure to prevent accidental injury. No patient contact. Output is a secure, puncture-resistant container.
Clinical Evidence
Bench testing only. No clinical data. Performance verified via compliance with ISO 23907-1, ASTM F2132-01(2008), 49 CFR 178.606 (Stacking), and 49 CFR 178.608 (Vibration).
Technological Characteristics
Materials: Polypropylene. Manufacturing: Injection molded. Form factor: Various capacities (0.05L to 15.142L). Non-sterile. Single-use. Standards: ISO 23907-1, ASTM F2132-01(2008), 49 CFR 178.606, 49 CFR 178.608.
Indications for Use
Indicated for safe disposal of hazardous sharps including hypodermic needles, syringes, lancets, and blood needles in healthcare facilities and other settings where medical sharps are used by qualified personnel.
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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November 17, 2021
Promisemed Hangzhou Meditech Co., Ltd. % Wei Shan Hsu Regulatory manager Vee Care (Asia) Limited 17th Chung Pont Commercial Building, 300 Hennessy Road Hong Kong, Hong Kong China
Re: K211890
Trade/Device Name: Promisemed Sharps container Regulation Number: 21 CFR 880.5570 Regulation Name: Hypodermic single lumen needle Regulatory Class: Class II Product Code: MMK Dated: May 27, 2021 Received: June 21, 2021
Dear Wei Shan Hsu:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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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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 of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely.
For Clarence W. Murray, III, Ph.D. Assistant Director DHT4B: Division of Infection Control and Plastic Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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## Indications for Use
510(k) Number (if known) K211890
Device Name Promisemed Sharps Container
Indications for Use (Describe)
It is intended to be used for health care purposes for safe disposal of hazardous sharps such as hypodermic needles, syringes, lancets and blood needles.
| Type of Use (Select one or both, as applicable) |
|-------------------------------------------------|
|-------------------------------------------------|
Prescription Use (Part 21 CFR 801 Subpart D)
X Over-The-Counter Use (21 CFR 801 Subpart C)
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# 510(k) Summary (K211890)
### Date Prepared 1
June 10th , 2021
### 2 Submitter's Information
Name of Sponsor:
Promisemed Hangzhou Meditech Co., Ltd.
Address:
No. 1388 Cangxing Street, Cangqian Community, Yuhang District, Hangzhou
City, 311121 Zhejiang, China
Contact Name:
Zearou Yang
Telephone No.:
+86 571 88772985
Fax No.:
+86 571 88772985
Email Address:
zearou.yang@promisemed.ca
## ന Trade Name, Common Name, Classification
Trade/Product Name: Promisemed Sharps Container
Common Name: Sharps container
Classification name: Container, Sharps
Regulation Number: 21 CFR 880.5570
Device Class: Class II
Product Code: MMK
## ldentification of Predicate Device ব K190240 Tiger Sharps Containers
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#### റ Description of the Device
The Sharps container is single-use, disposable, non-sterile containers intended to be used for health- care purposes for safe disposal of hazardous sharps such as needles, syringes, lancets and etc. The target population is for qualified personnel in health care facilities and other facilities in which medical sharps may be used.
It is made of injection molded polypropylene plastic, and is composed of base, lid, closure and handle (except pocket collectors). No part of the container is intended to come in contact with patients and the sharps objects that will be placed within the containers.
- 6 Indication
lt is intended to be used for health care purposes for safe disposal of hazardous sharps such as hypodermic needles, syringes, lancets and blood needles.
| Model | Capacity<br>(Total) | Capacity<br>(Full line) | Dimensions<br>LxWxH (mm) | Thickness | Empty<br>Weight<br>(grams) | Color |
|----------|---------------------|-------------------------|--------------------------|---------------------------------|----------------------------|-------------------------------------------------|
| SSC-005L | 0.05 L | 0.043 L | 60 x 27 x 87 | Base:1.3-3.2mm<br>Lid:1.2-1.5mm | 27 | Base:black<br>(opaque)<br>Lid:black<br>(opaque) |
| SSC-020L | 0.2 L | 0.17 L | 65 x 55 x 100 | Base: 1.2-4mm | 40 | Base:colorless |
| SSC-050L | 0.5 L | 0.425 L | 74 x 74 x 114 | Lid: 1.2- 3.2mm | 56 | (translucent)<br>Lid:yellow<br>(opaque) |
| SSC-100L | 1 L | 0.85 L | 100 x 100 x 155 | Base:1.3-2.6mm | 84 | Base: |
| SSC-150L | 1.5 L | 1.275 L | 539 x 248 x 381 | Lid:1.3-1.5mm | 134 | red (opaque) |
| SSC-100G | 3.785 L | 3.217 L | 546 x 536 x 393 | Base:1.3-3mm<br>Lid:1.3-2 mm | 486 | Lid: |
| SSC-200G | 7.571 L | 6.435 L | 517 x 355 x 387 | Base:1.3- 4mm<br>Lid:1.5-2.2mm | 785 | Colorless<br>(Transparent) |
| SSC-300G | 11.356L | 9.653 L | 355 x 304 x 558 | Base:1.5- 4mm<br>Lid:1.2-4mm | 953 | |
| SSC-400G | 15.142L | 12.871 L | 398 x 317 x 463 | Base:1.5- 4mm<br>Lid:1.2-4mm | 1625 | |
| SSC-100Q | 0.946 L | 0.804 L | 100 x 100 x 155 | Base:1.3-2.6mm<br>Lid:1.3-1.5mm | 84 | |
| SSC-200Q | 1.892 L | 1.608 L | 565 x 314 x 387 | Base:1.3-3mm<br>Lid:1.3-2 mm | 158 | |
| SSC-500Q | 4.73L | 4.021 L | 603 x 438 x 292 | Base:1.3- 4mm<br>Lid:1.5-2.2mm | 523 | |
#### 7 Specification
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## 8 Similarities and Differences of the Proposed Devices to the Predicate Devices
The Promisemed Sharps Container is substantially equivalent to the predicate device, the Tiger Sharps Containers (K190240) in that these devices have same intended use, technological characteristics and method of manufacturer. Both the subject and predicate devices are disposable, nonsterile, single use devices. The differences between the subject device and predicate device do not affect the basic design principle, usage of the subject device.
| | Subject Device | Predicate Device (K190240) | |
|--------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------|
| Trade Name | Promisemed Sharps<br>Container | Tiger Sharps Containers | Comments |
| Manufacturer | Promisemed Hangzhou<br>Meditech Co., Ltd | International Marketing<br>Specialists Inc. | |
| Device Class | Class II | Class II | Same |
| Product Code | MMK | MMK | Same |
| Regulation number | 880.5570 | 880.5570 | Same |
| Regulation Name | Hypodermic single lumen<br>needle. | Hypodermic single lumen<br>needle. | Same |
| Intended Use/<br>Indications for Use | It is intended to be used<br>for health care purposes<br>for safe disposal of<br>hazardous sharps such as<br>hypodermic needles,<br>syringes, lancets and<br>blood needles and so on. | Tiger Sharps Containers are<br>intended to provide a<br>receptacle for used,<br>contaminated medical sharps<br>and act as an enclosure during<br>transport to ultimate disposal.<br>The Containers are single-use,<br>disposable, non-sterile<br>containers intended to be<br>used for health-care purposes<br>for safe disposal of hazardous<br>sharps such as hypodermic<br>needles, syringes, lancets and<br>blood needles. The target | Same |
A detailed comparison to the predicate is provided in Table 1.
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| | | population is for qualified<br>personnel in health care<br>facilities and other facilities<br>in which medical sharps may<br>be used. All device models are<br>not for use in areas with<br>unsupervised patient access. | |
|-----------------------------|----------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------|
| Capacity | 0.05 litre/0.2 litre/ 0.5<br>litre/ 1 litre/1.5 litre/1<br>Quart/2 Quart/5 Quart/1<br>Gallon/2 Gallon/3<br>Gallon/4 Gallon | 1 Quart / 5 Quart / 2 Gallon /<br>2 Gallon B/ 15 Liter/ 3<br>Gallon/ 8 Gallon | Different |
| Prescribed | OTC | OTC | Same |
| Weight range (g) | 27-1625 | 109-1172 | Different |
| No. of piece | 2-3 | 2-3 | Same |
| Material | Polypropylene | Polypropylene | Same |
| Color | Base: Red or yellow or<br>black<br>Lid: Transparent or black | Base: Red<br>Lid: Transparent | Different |
| Clarity | Opaque/translucent | Opaque/translucent | Same |
| Non-sterile | Yes | Yes | Same |
| Method of<br>manufacture | Injection Molded | Injection Molded | Same |
| Performance<br>testing | Complied with ISO23907,<br>ASTM F2132 | Complied with ISO23907,<br>ASTM F2132 | Same |
| Disposable or Re-<br>usable | Disposable | Disposable | Same |
#### 9 Performance Testing Summary
The bench testing performed verifies that the performance of the subject device is substantially equivalent in terms of critical performance characteristics to the predicate device. These tests include:
- ・ASTM F2132-01(2008)
- ISO 23907-1
- 49 CFR 178.606 Stacking
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- 49 CFR 178.608 Vibration
# 10 Conclusion
Based on the information provided within this 510(k) submission, proposed subject device is substantially equivalent to the predicate device and is as safe, as effective and performs as well as the legally marketed 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.