(151 days)
The Qora AIM™ Stool Management Kit is indicated for fecal management by diverting and collecting liquid or semi- formed stool to minimize skin contact in bedridden patients. The device is for use in patients 18 years and older only. The uninterrupted use for this device, including replacement with other same devices, should not exceed 29 days.
The Qora Aeon™ Stool Management Kit is indicated for fecal management by diverting and collecting liquid or semi- formed stool to minimize skin contact in bedridden patients. The device is for use in patients 18 years and older only. The uninterrupted use for this device, including replacement with other same devices, should not exceed 29 days.
The Qora Arida™ Stool Management Kit is indicated for fecal management by diverting and collecting liquid or semi- formed stool to minimize skin contact in bedridden patients. The device is for use in patients 18 years and older only. The uninterrupted use for this device is intended to be until the collection pouch is filled or until it has been utilized for 72 hours, whichever comes first. The replacement with other same devices should not exceed 29 days.
The Qora AIM™, Qora Aeon™, and Qora Arida™ Stool Management Kits are non-sterile, single-use devices packaged in a product box. Each kit contains one hygienic device applicator that houses a soft indwelling fecal diverter. The Qora AIM™ and Qora Aeon™ kits contain an additional two odor-proof collection bags.
The primary component of the device is the fecal diverter. It consists of soft, pliable, and self-expanding indwelling diverter that remains apposed to the rectal wall and the transit sheath. The indwelling diverter is sufficiently compliant to collapse and expand with the adjacent anatomy during peristaltic contractions of the rectum. This pliancy within the rectum is designed to help reduce abrasion and subsequent clinical complicator is used to hygienically insert and deploy the indwelling diverter at the intended location inside the rectum.
The Qora Arida™ collection pouch is a thin, biocompatible conduit that facilitates the transfer and collection of fecal material from the indwelling diverter. The use of thin material is engineered to reduce the foreign body sensation and risk of anal sphinction. Furthermore, the Qora Arida™ kit offers a single port attached to the side of the collection pouch. The port is used to withdraw the device in a trauma-free way from the patient.
The Qora AIM™ and Qora Aeon™ kits utilize a transit sheath that is a thin, biocompatible conduit that facilitates the transfer fecal material from the indwelling diverter to the collection bag. The use of thin sheath is designed to reduce the foreign body sensation and risk of anal sphinction. The bag connection interface at the end of the transit sheath prevents accidental soiling of bed sheets, garments, etc. during the exchange of a collection bag or other regular maneuvers during patient handling. Furthermore, the Qora AlM™ and Qora Aeon™ kits offer three ports attached to the side of the transit sheath. One port is used to irrigate the indwelling diverter if needed. The second port is used to collect samples from within the transit sheath if desired. The third and final port is used to withdraw the device in a trauma-free way from the patient.
This document is a 510(k) premarket notification for the Qora AIM, Qora Aeon, and Qora Arida Stool Management Kits. It establishes substantial equivalence to a predicate device (Consure 120 SMS, K133465) rather than providing a study demonstrating performance against specific acceptance criteria. Therefore, the requested information (table of acceptance criteria, sample sizes, expert qualifications, adjudication, MRMC studies, standalone performance, ground truth details, and training set information) cannot be fully extracted from this document as it describes a different type of regulatory submission.
However, based on the provided text, here is what can be inferred and what information is explicitly missing:
1. Table of Acceptance Criteria and Reported Device Performance:
The document does not provide a table of acceptance criteria with numerical performance targets and reported device performance against those targets. Instead, it focuses on demonstrating substantial equivalence to a predicate device in terms of design, materials, and intended use. The performance data section describes general non-clinical testing.
| Acceptance Criteria (Not explicitly stated with numerical targets) | Reported Device Performance (Summary of non-clinical testing) |
|---|---|
| Structural and Functional Use Characteristics (e.g., lumen size, device dimensions, functional strength, simulated use) | Found to be substantially equivalent to the predicate device for dimensional, functional, and structural integrity testing. |
| Biocompatibility (according to ISO 10993, Part 1) | Devices are considered non-sensitizing, non-cytotoxic, and non-irritating, and found safe for intended use. |
2. Sample Size Used for the Test Set and Data Provenance:
The document describes non-clinical testing, but it does not specify sample sizes for any "test set" in the context of clinical performance or human subject data. The testing mentioned (structural, functional, biocompatibility) would typically involve laboratory or animal testing, not human test sets. Data provenance is not applicable in this context as it's not a clinical study.
3. Number of Experts Used to Establish Ground Truth and Qualifications:
Not applicable. This document does not describe a study involving expert review or ground truth establishment for a test set, as it is not a clinical performance study.
4. Adjudication Method:
Not applicable, as no expert review or human subject test set is described.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:
No, an MRMC comparative effectiveness study was not done or reported in this document. This submission focuses on substantial equivalence based on technical characteristics and non-clinical testing, not on comparative clinical effectiveness with human readers or AI assistance.
6. Standalone (Algorithm Only) Performance:
No, a standalone performance study was not done or reported. These devices are physical medical products (Stool Management Kits), not AI algorithms or software with standalone performance.
7. Type of Ground Truth Used:
Not applicable. The performance data detailed within this document pertains to non-clinical testing (dimensional, functional, structural integrity, and biocompatibility), not clinical outcomes or expert consensus on a disease state. Therefore, "ground truth" in the context of clinical diagnostics or outcomes data is not relevant here.
8. Sample Size for the Training Set:
Not applicable. As described in point 6, these are physical medical devices, not AI algorithms requiring a training set.
9. How the Ground Truth for the Training Set Was Established:
Not applicable. This is not an AI algorithm, so there is no training set or ground truth establishment process for a training set.
Summary of what the document focuses on:
The document is a 510(k) submission seeking clearance for medical devices (Stool Management Kits). Its primary goal is to demonstrate substantial equivalence to an already legally marketed predicate device (Consure 120 SMS). This is achieved by comparing:
- Intended Use and Indications for Use: The new devices have largely the same indications for use as the predicate, with minor variations in usage duration for one model.
- Technological Characteristics: Detailed comparison of parameters like intended users, patient population, environment of use, condition of use, insertion method, diverter outer diameter, detachable collection bag, irrigation port, sampling port, retrieval method, closed waste bag volume, interface port, odor protection, and materials.
- Performance Data (Non-Clinical): Testing confirmed the new devices are substantially equivalent to the predicate in terms of structural and functional integrity. Biocompatibility testing (in accordance with ISO 10993) also confirmed safety.
The conclusion is that the line extensions do not raise any new issues of safety or effectiveness, thus proving substantial equivalence to the predicate device. This is a common path for medical device clearance and differs from the type of study that would involve clinical acceptance criteria, human reader studies, or AI algorithm performance mentioned in your prompt.
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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 circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is a stylized image of three human profiles facing to the right, with flowing lines connecting them.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
May 6, 2016
Consure Medical Pvt Ltd. % Alan Donald President Matrix Medical Consulting, Inc. 8880 Rio San Diego Drive, Suite 800 San Diego, CA 92108
Re: K153506
Trade/Device Name: Qora AIM™ Stool Management Kit, Qora Aeon™ Stool Management Kit, Qora Arida™ Stool Management Kit Regulation Number: 21 CFR 876.5980 Regulation Name: Gastrointestinal Tube and Accessories Regulatory Class: Class II Product Code: KNT Dated: March 23, 2016 Received: April 4, 2016
Dear Alan Donald,
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
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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 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" (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.
for
Sincerely yours.
Herbert P. Lerner -S
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
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| DEPARTMENT OF HEALTH AND HUMAN SERVICESFood and Drug Administration | Form Approved: OMB No. 0910-0120Expiration Date: January 31, 2017See PRA Statement below. |
|---|---|
| ------------------------------------------------------------------------- | --------------------------------------------------------------------------------------------------- |
| 510(k) Number (if known) | K153506 | ||
|---|---|---|---|
| Device Name | Qora AIM Stool Management KitQora Aeon Stool Management KitQora Arida Stool Management Kit | ||
| Indications for Use ( Describe ) | |||
| The Qora AIM Stool Management Kit is indicated for fecal management by diverting and collecting liquid or semi- formed stool to minimize skin contact in bedridden patients. The device is for use in patients 18 years and older only. The uninterrupted use for this device, including replacement with other same devices, should not exceed 29 days. | |||
| The Qora Aeon Stool Management Kit is indicated for fecal management by diverting and collecting liquid or semi- formed stool to minimize skin contact in bedridden patients. The device is for use in patients 18 years and older only. The uninterrupted use for this device, including replacement with other same devices, should not exceed 29 days. | |||
| The Qora Arida Stool Management Kit is indicated for fecal management by diverting and collecting liquid or semi- formed stool to minimize skin contact in bedridden patients. The device is for use in patients 18 years and older only. The uninterrupted use for this device is intended to be until the collection pouch is filled or until it has been utilized for 72 hours, whichever comes first. The replacement with other same devices should not exceed 29 days. | |||
| Type of Use (Select one or both, as applicable) | |||
| Prescription Use (Part 21 CFR 801 Subpart D) Over-The-Counter Use (21 CFR 801 Subpart C) | Prescription Use (Part 21 CFR 801 Subpart D) | Over-The-Counter Use (21 CFR 801 Subpart C) | |
| Prescription Use (Part 21 CFR 801 Subpart D) | Over-The-Counter Use (21 CFR 801 Subpart C) |
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Image /page/3/Picture/1 description: The image shows the logo for Consure Medical. The word "consure" is written in teal, with a red curved line running vertically through the middle of the word. Below the word "consure" is the word "MEDICAL" in gray.
SECTION 5 510(k) Summary
| Device/Trade Name(s): | Qora AIMTM Stool Management KitQora AeonTM Stool Management KitQora AridaTM Stool Management Kit |
|---|---|
| Device Type/Common Name: | Rectal Tube |
| 510(k) Submitter: | Consure Medical Pvt. Ltd5L, Third FloorShahpur JatNew Delhi, Delhi 110049INDIAContact: Mr.Nishith Chasmawala, CEOPhone: +91 99 1002 8379, +91 11 4161 7344 |
| Establishment RegistrationNumber: | 3011802696 |
| Address OfManufacturing/PackagingFacility: | Contract Medical International GmbH.Lauensteiner Strasse 37Dresden 01277GermanyContact: Mr. Jan Kloboucnik, QA/RA DirectorTelephone: +42 494 949 564 |
| Authorized Contact Person: | Alan Donald, PresidentMatrix Medical Consulting, Inc.8880 Rio San Diego Drive, Suite 800San Diego, California 92108Phone: +1 619 359 4103Fax: +1 858 753 1801 |
| Recommended Regulation: | 21 CFR 876.5980 |
| Device Classification Name: | Gastrointestinal Tube and Accessories |
| Device Class: | Class II |
| Panel: | Gastroenterology-Urology Devices |
| Product Code: | KNT |
| Predicate Device: | Consure 120 SMS |
| Predicate Device Product Code: | KNT, 510(k) K133465 |
| Date Summary Prepared | May 4, 2016 |
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Image /page/4/Picture/1 description: The image shows the logo for Consure Medical. The word "consure" is written in teal, with the "s" being a red, curved line. Below the "ure" in "consure" is the word "MEDICAL" in gray, in a smaller font size than the rest of the logo.
Device Descriptions
Fecal incontinence (FI) is the inability to control bowel movements resulting in the involuntary and untimely release of feces or flatus. Although FI is a benign condition, its clinical sequelae are often devastating to both the patient and the health system. The condition is believed to affect 8-15 percent of the general population, with the highest prevalence among the elderly and in acute care settings.
The Qora AIM™, Qora Aeon™, and Qora Arida™ Stool Management Kits are non-sterile, single-use devices packaged in a product box. Each kit contains one hygienic device applicator that houses a soft indwelling fecal diverter. The Qora AIM™ and Qora Aeon™ kits contain an additional two odor-proof collection bags.
The primary component of the device is the fecal diverter. It consists of soft, pliable, and self-expanding indwelling diverter that remains apposed to the rectal wall and the transit sheath. The indwelling diverter is sufficiently compliant to collapse and expand with the adjacent anatomy during peristaltic contractions of the rectum. This pliancy within the rectum is designed to help reduce abrasion and subsequent clinical complicator is used to hygienically insert and deploy the indwelling diverter at the intended location inside the rectum.
The Qora Arida™ collection pouch is a thin, biocompatible conduit that facilitates the transfer and collection of fecal material from the indwelling diverter. The use of thin material is engineered to reduce the foreign body sensation and risk of anal sphinction. Furthermore, the Qora Arida™ kit offers a single port attached to the side of the collection pouch. The port is used to withdraw the device in a trauma-free way from the patient.
The Qora AIM™ and Qora Aeon™ kits utilize a transit sheath that is a thin, biocompatible conduit that facilitates the transfer fecal material from the indwelling diverter to the collection bag. The use of thin sheath is designed to reduce the foreign body sensation and risk of anal sphinction. The bag connection interface at the end of the transit sheath prevents accidental soiling of bed sheets, garments, etc. during the exchange of a collection bag or other regular maneuvers during patient handling. Furthermore, the Qora AlM™ and Qora Aeon™ kits offer three ports attached to the side of the transit sheath. One port is used to irrigate the indwelling diverter if needed. The second port is used to collect samples from within the transit sheath if desired. The third and final port is used to withdraw the device in a trauma-free way from the patient.
Indications for Use
The Indications for Use for the three products are as below:
The Qora AIM" Stool Manaqement Kit is indicated for fecal manaqement by diverting and collecting liquid or semiformed stool to minimize skin contact in bedridden patients. The device is for use in patients 18 years and older only. The uninterrupted use for this device, including replacement with other same devices, should not exceed 29 days.
The Qora Aeon™ Stool Management Kit is indicated for fecal management by diverting and collecting liquid or semi-formed stool to minimize skin contact in bedridden patients. The device is for use in patients 18 years and older only. The uninterrupted use for this device, including replacement with other same devices, should not exceed 29 days.
The Qora Arida'" Stool Management Kit is indicated for fecal management by diverting and collecting liguid or semi-formed stool to minimize skin contact in bedridden patients. The device is for use in patients 18 years and older only. The uninterrupted use for this device is intended to be until the collection pouch is filled or until it has been utilized for 72 hours, whichever comes first. The replacement with other same devices should not exceed 29 days.
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Image /page/5/Picture/1 description: The image shows the logo for Consure Medical. The word "consure" is written in teal, with a red curved line in the middle of the word. Below the word "ure" is the word "MEDICAL" in gray. The logo is simple and modern.
Substantial Equivalence
A summary of the equivalence between the Qora AIM™ Stool Management Kit, Qora Aeon™ Stool Management Kit, and Qora Arida™ Stool Management Kit and the predicate device is given in the following table.
| MODIFIED DEVICES | PREDICATE | |||
|---|---|---|---|---|
| Parameter | Qora AIMTM SMK | Qora AeonTM SMK | Qora AridaTM SMK | Consure 120 SMS(K133465) |
| Intended Use | Fecal management | Fecal management | Fecal management | Fecal management |
| Intended Users | Bedridden patients | Bedridden patients | Bedridden patients | Bedridden patients |
| Indications ForUse | The Qora AIMTM StoolManagement Kit isindicated for fecalmanagement bydiverting andcollecting liquid orsemi-formed stool tominimize skin contactin bedriddenpatients. The deviceis for use in patients18 years and olderonly. Theuninterrupted use forthis device, includingreplacement withother same devices,should not exceed 29days. | The Qora AeonTMStool ManagementKit is indicated forfecal management bydiverting andcollecting liquid orsemi-formed stool tominimize skin contactin bedriddenpatients. The deviceis for use in patients18 years and olderonly. Theuninterrupted use forthis device, includingreplacement withother same devices,should not exceed 29days. | The Qora AridaTMStool ManagementKit is indicated forfecal management bydiverting andcollecting liquid orsemi-formed stool tominimize skin contactin bedriddenpatients. The deviceis for use in patients18 years and olderonly. Theuninterrupted use forthis device isintended to be untilthe collection pouchis filled or until it hasbeen utilized for 72hours, whichevercomes first. Thereplacement withother same devicesshould not exceed 29days. | The Consure 120 SMSis indicated for fecalmanagement bydiverting andcollecting liquid orsemi-formed stool tominimize skin contactin bedriddenpatients. |
| PatientPopulation | 18 years and older | 18 years and older | 18 years and older | 18 years and older |
| Environment OfUse | Hospitals and nursinghomes | Hospitals and nursinghomes | Hospitals and nursinghomes | Hospitals and nursinghomes |
| Condition Of Use | Single use | Single use | Single use | Single use |
| Period Of Usage | 29 days | 29 days | 29 days | 5 days |
| Insertion Method | Hygienic Applicator | Hygienic Applicator | Hygienic Applicator | Hygienic Applicator |
| Diverter OuterDiameter | 55mm | 55mm | 55mm | 55mm |
| DetachableCollection Bag | Yes | Yes | No | Yes |
| Irrigation Port | Yes | Yes | No | Yes |
| Sampling Port | Yes | Yes | No | No |
| Retrieval By | Collapsing diverter | Collapsing diverter | Collapsing diverter | Collapsing diverter |
| Closed Waste BagVolume | Approximately 1 liter | Approximately 1 liter | Approximately 1.5liter | Approximately 1 liter |
| Interface Port | Side catheterconnector port | Side catheterconnector port | Side catheterconnector port | Side catheterconnector port |
| Odor Protection | Yes | Yes | No | No |
| Materials | Diverter: Urethanebased TPU thatcushions stainlesssteel wire formlattice that is MRISafe. Urethane baseTPU film to divertfecal matter intocollection bag.Collection Bag:HypoallergenicEVA/PVDC odorbarrier film. | Diverter: Urethanebased TPU thatcushions stainlesssteel wire formlattice. Urethanebase TPU film todivert fecal matterinto collection bag.Collection Bag:HypoallergenicEVA/PVDC odorbarrier film. | Diverter: Urethanebased TPU thatcushions stainlesssteel wire formlattice. Urethanebase TPU film todivert fecal matterinto collection bag.Collection Bag:Urethane based TPUfilm | Diverter: Urethanebased TPU thatcushions stainlesssteel wire formlattice. Urethanebase TPU film todivert fecal matterinto collection bag.Collection Bag:Urethane based TPU. |
| Sterility | Supplied non-sterile,disposable, singlepatient use. | Supplied non-sterile,disposable, singlepatient use | Supplied non-sterile,disposable, singlepatient use | Supplied non-sterile,disposable, singlepatient use. |
| Packaging | Device tray in tamperproof duplex box. | Device tray in tamperproof duplex box. | Device in tamperproof duplex box. | Cardboard tray inTyvek Pouch. |
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Image /page/6/Picture/1 description: The image shows the logo for Consure Medical. The word "consure" is written in teal, with a red curved line in place of the "s". Below the word "ure" is the word "MEDICAL" in gray. The logo is simple and modern, and the colors are eye-catching.
Summary of Performance Data (Non-Clinical Testing):
Non-clinical testing of the subject devices for structural and functional use characteristics has been performed (lumen size, device dimensions, functional strength, simulated use, etc.). In this testing, the subject devices were found to be substantially equivalent to the predicate device for dimensional, functional, and structural integrity testing.
The components of the Qora AIM™, Qora Aeon™, and Qora Arida™ Stool Management Kits have been evaluated for biocompatibility in accordance with the U.S. Food and Drug Administration's guidance entitled Use of International Standard 180 -10993, "Biological Evaluation of Medical Devices Part 1: Evaluation and Testing', issued May 1, 1995. The results of this testing demonstrate that the Qora AIM™, and Qora Arida™ Stool Management Kits are considered to be non-sensitizing, non-cytotoxic, and non-irritating, and has been found safe in such respect for its intended use.
This 510(k) submission for the Qora AlM™ Stool Management Kit, Qora Aeon" Stool Management Kit, and the Qora Arida"" Stool Management Kit is intended to address line extensions to the previously FDA cleared Consure 120 SMS (K133465). Based on the comparison of intended use, indications for use, and technological characteristics, the three line extensions are substantially equivalent to the Consure 120 SMS (K133465), with respect to intended use, indications for use, performance, and technological characteristics. The line extensions do not raise any new issues of safety or effectiveness.
§ 876.5980 Gastrointestinal tube and accessories.
(a)
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).(b)
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.