(231 days)
The F&P Evora Full Face mask is intended to be used by adults weighing ≥ 66lbs (30kgs) who have been diagnosed by a physician as requiring CPAP or Bi-Level therapy. The F&P Evora Full Face mask is intended for single patient use in the home and for multiple patient use in the hospital or other clinical setting where proper disinfection of the device can occur between patient uses.
The F&P Evora™ Full Face Mask (hereafter named "Evora Full") is a non-invasive compact full-face mask that seals underneath the patient's nose and lips. The mask connects to a single breathing tube by a 22mm male swivel adaptor to receive pressurised air from a continuous positive airway pressure device (CPAP or Bi-level). The exhaust holes on the seal of the mask allow exhaled air to be flushed out while the system is in operation. The Evora Full mask is a prescription only device, provided in non-sterile state
This document is a 510(k) summary for the F&P Evora™ Full Face Mask. It focuses on demonstrating substantial equivalence to a predicate device rather than presenting a study proving a device meets specific acceptance criteria based on its own performance metrics against expert ground truth.
Therefore, many of the requested sections (acceptance criteria table, sample sizes, number of experts, adjudication methods, MRMC studies, standalone performance, training set details) are not applicable to this document as it outlines a substantial equivalence argument for a medical device.
However, I can extract information regarding some performance data and the comparison to the predicate device.
1. Table of Acceptance Criteria and the Reported Device Performance
The document does not explicitly state acceptance criteria in the format of a requirement with a corresponding performance metric for the subject device to pass. Instead, it compares the subject device's technical specifications to those of the predicate device (F&P Vitera™ Full Face Mask, K190713). Substantial equivalence implies that the differences do not raise new questions of safety or effectiveness.
| Design / Technological Characteristic | Predicate Device (F&P Vitera™ Full Face Mask, K190713) | Subject Device (F&P Evora™ Full Face Mask) | Comments (Implying "Acceptance" through Equivalence) |
|---|---|---|---|
| Classification | 21 CFR §868.5905 | 21 CFR §868.5905 | Identical |
| Intended Use/Indications for Use | The F&P Vitera Full Face mask is intended to be used by adults weighing ≥ 66lbs (30kgs) who have been diagnosed by a physician as requiring CPAP or Bi-Level therapy. The F&P Vitera Full Face mask is intended for single patient use in the home and for multiple patient use in the hospital or other clinical setting where proper disinfection of the device can occur between patient uses. | The F&P Evora Full Face mask is intended to be used by adults weighing ≥ 66lbs (30kgs) who have been diagnosed by a physician as requiring CPAP or Bi-Level therapy. The F&P Evora Full Face mask is intended for single patient use in the home and for multiple patient use in the hospital or other clinical setting where proper disinfection of the device can occur between patient uses. | Identical |
| Availability | Prescription use only (Part 21 CFR 801 Subpart D) | Prescription use only (Part 21 CFR 801 Subpart D) | Identical |
| Patient Population | Adult (> 30kg) | Adult (> 30kg) | Identical |
| Application | CPAP or Bi-Level therapy | CPAP or Bi-Level therapy | Identical |
| Operating Environment | Home, hospital or other clinical setting | Home, hospital or other clinical setting | Identical |
| Pressure Range | 4 to 30 cmH2O | 4 to 30 cmH2O | Identical |
| Resistance to Flow (at 50 L/min) | 0.24 ± 0.15 cmH2O | 0.9 ± 0.3 cmH2O | This difference does not raise new questions of safety and effectiveness. |
| Resistance to Flow (at 100 L/min) | 0.47 ± 0.15 cmH2O | 2.2 ± 0.3 cmH2O | This difference does not raise new questions of safety and effectiveness. |
| Dead Space (Small/S-M) | Small: 245.8 cc | S-M: 162.6 cm3 | This difference does not raise new questions of safety and effectiveness. |
| Dead Space (Large/L) | Large: 321.8 cc | L: 164.1 cm3 | This difference does not raise new questions of safety and effectiveness. |
| Sound Power Level | 29.8 dBA, with uncertainty 2.5 dBA | 28.2 dBA, with uncertainty 2.5 dBA | Substantially equivalent |
| Sound Pressure Level | 21.8 dBA, with uncertainty 2.5 dBA | 20.2 dBA, with uncertainty 2.5 dBA | Substantially equivalent |
| Shelf-Life | 5 years | 2 years | This difference does not raise new questions of safety and effectiveness. |
| Breathing Circuit | Single Inspiratory Tube | Single Inspiratory Tube | Identical |
| Operating Temperature | 5 to 40°C | 5 to 40°C | Identical |
| Storage Temperature | -20 to 50°C | -20 to 50°C | Identical |
| Swivel | 22mm ISO conical connector | 22mm ISO conical connector | Identical |
| Sterility | Device not provided sterile | Device not provided sterile | Identical |
| Reusability | Reusable - Multi Patient Use | Reusable - Multi Patient Use | Identical |
| High Level Disinfection Methods | 80°C for 10 mins, 75°C for 30 mins, 90°C for 1 min | 90°C for 1 min | Equivalent. The subject device contains a subset of the high-level disinfection methods compared to the predicate. |
| Accessory (Oxygen/Pressure Port) | Available as a separate part (900HC452) | Available as a separate part (900HC452) | Identical. |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
This document is a 510(k) summary for a medical device (face mask), not an AI/software device. There is no mention of a "test set" in the context of an algorithm's performance. The "performance data" refers to non-clinical tests conducted on the physical device components. There is no information regarding country of origin or retrospective/prospective nature of any specific data beyond the general regulatory context.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
Not applicable. This document is not about an AI/software device that requires expert-established ground truth for a test set.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
Not applicable. This is not an AI-assisted device.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
Not applicable. This is not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
Not applicable. The "ground truth" for this device's performance would be engineering specifications and standards compliance, as demonstrated by the non-clinical tests listed.
8. The sample size for the training set
Not applicable. This is not an AI/software device that would have a training set.
9. How the ground truth for the training set was established
Not applicable.
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Image /page/0/Picture/0 description: The image contains two logos. On the left is the Department of Health & Human Services logo. On the right is the FDA logo, which includes the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.
March 18, 2022
Fisher & Paykel Healthcare Ltd Reena Daken Regulatory Affairs Market Manager 15 Maurice Paykel Place, East Tamaki Auckland. 2013 New Zealand
Re: K212371
Trade/Device Name: F&P Evora Full Face Mask Regulation Number: 21 CFR 868.5905 Regulation Name: Noncontinuous ventilator (IPPB) Regulatory Class: Class II Product Code: BZD Dated: February 18, 2022 Received: February 18, 2022
Dear Reena Daken:
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.
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
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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 mediation-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,
Rachana Visaria, Ph.D. Assistant Director DHT1C: Division of Sleep Disordered Breathing, Respiratory and Anesthesia Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental 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) K212371
Device Name F&P Evora™ Full Face Mask
Indications for Use (Describe)
The F&P Evora Full Face mask is intended to be used by adults weighing ≥ 66lbs (30kgs) who have been diagnosed by a physician as requiring CPAP or Bi-Level therapy. The F&P Evora Full Face mask is intended for single patient use in the home and for multiple patient use in the hospital or other clinical setting where proper disinfection of the device can occur between patient uses.
| 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) |
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510(k) Summary
As Required by 21 CFR 807.92
I. SUBMITTER
| Company Name andAddress | Fisher & Paykel Healthcare Limited15 Maurice Paykel PlaceEast TamakiAuckland 2013, New ZealandTelephone: +64 9 574 0100 |
|---|---|
| Prepared and Submitted by | Nicholas YapRegulatory Affairs Specialist |
| Contact Person | Reena DakenRegulatory Affairs ManagerTelephone: +64 9 574 0100Email: reena.daken@fphcare.co.nz |
| Date Prepared | 18 March 2022 |
II. DEVICE
| Name of Device | F&P Evora™ Full Face Mask |
|---|---|
| Common/Usual Name | Full Face Mask |
| Classification Name | Non Continuous Ventilator (IPPB) |
| Regulatory Class | Class II (21 CFR §868.5905) |
| Product Code | BZD |
PREDICATE DEVICE lll.
- Predicate device:
- F&P Vitera™ Full Face Mask, K190713
- . Reference devices:
- o F&P Evora™ Nasal Mask, K200089
- Used to support claims of substantial equivalence with respect to design and performance
- o F&P Evora™ Nasal Mask, K200089
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DEVICE DESCRIPTION IV.
The F&P Evora™ Full Face Mask (hereafter named "Evora Full") is a non-invasive compact full-face mask that seals underneath the patient's nose and lips. The mask connects to a single breathing tube by a 22mm male swivel adaptor to receive pressurised air from a continuous positive airway pressure device (CPAP or Bi-level). The exhaust holes on the seal of the mask allow exhaled air to be flushed out while the system is in operation. The Evora Full mask is a prescription only device, provided in non-sterile state
| Model | Product Code | Product Description |
|---|---|---|
| A-Model | EVF1XA | Evora Full Face Mask Extra Small A Model |
| EVF1MA | Evora Full Face Mask Small-Medium Model | |
| EVF1LA | Evora Full Face Mask Large A Model | |
| EVF1XXA | Evora Full Face Mask Double Seal XS/XS A Model | |
| EVF1MMA | Evora Full Face Mask Double Seal S-M/S-M A Model | |
| EVF1LLA | Evora Full Face Mask Double Seal Lrg/Lrg A Model | |
| Fit Pack A-Model | EVF1XMLA | Evora Full Face Mask Fit Pack A Model |
| SL A-Model | EVF1XSLA | Evora Full Mask Extra Small Sleep Lab A |
| EVF1MSLA | Evora Full Mask Small-Medium Sleep Lab A | |
| EVF1LSLA | Evora Full Mask Large Sleep Lab A | |
| Fit Pack SL A-Model | EVF1XMLSLA | Evora Full Mask Fit Pack Sleep Lab A |
A list of the subject device product codes can be found below:
INDICATIONS FOR USE V.
The F&P Evora Full Face mask is intended to be used by adults weighing ≥ 66lbs (30kgs) who have been diagnosed by a physician as requiring CPAP or Bi-Level therapy. The F&P Evora Full Face mask is intended for single patient use in the home and for multiple patient use in the hospital or other clinical setting where proper disinfection of the device can occur between patient uses.
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COMPARISON OF TECHNOLOGICAL CHARATCERISTICS WITH THE PREDICATE DEVICE VI.
The comparison of features, performance data and intended use demonstrate that the F&P Evora™ Full Face Mask is substantially equivalent to the predicate device, F&P Vitera™ Full Face Mask (K190713). Please see the table below.
| Design /TechnologicalCharacteristic | Subject Device | Predicate Device | Comments |
|---|---|---|---|
| F&P Evora™ Full Face Mask | F&P Vitera™ Full Face Mask (K190713) | ||
| Classification | |||
| LegalManufacturer | Fisher & Paykel Healthcare Ltd. | Fisher & Paykel Healthcare Ltd. | |
| Product Code | BZD | BZD | |
| DeviceClassification | 21 CFR §868.5905 | 21 CFR §868.5905 | Identical |
| Classificationpanel | Anaesthesiology | Anaesthesiology | |
| Intended Use/Indications for Use | |||
| Intended Use/Indications forUse | The F&P Evora Full Face mask is intended tobe used by adults weighing ≥ 66lbs (30kgs) whohave been diagnosed by a physician asrequiring CPAP or Bi-Level therapy. The F&PEvora Full Face mask is intended for singlepatient use in the home and for multiple patientuse in the hospital or other clinical setting whereproper disinfection of the device can occurbetween patient uses. | The F&P Vitera Full Face mask is intended tobe used by adults weighing ≥ 66lbs (30kgs) whohave been diagnosed by a physician asrequiring CPAP or Bi-Level therapy. The F&PVitera Full Face mask is intended for singlepatient use in the home and for multiple patientuse in the hospital or other clinical setting whereproper disinfection of the device can occurbetween patient uses. | Identical |
| Availability | Prescription use only(Part 21 CFR 801 Subpart D) | Prescription use only(Part 21 CFR 801 Subpart D) | Identical |
| Design /TechnologicalCharacteristic | Subject Device | Predicate Device | Comments |
| F&P Evora™ Full Face Mask | F&P Vitera™ Full Face Mask (K190713) | ||
| PatientPopulation | Adult (> 30kg) | Adult (> 30kg) | Identical |
| Application | CPAP or Bi-Level therapy | CPAP or Bi-Level therapy | Identical |
| OperatingEnvironment | Home, hospital or other clinical setting | Home, hospital or other clinical setting | Identical |
| Technical Specifications and Features | |||
| PressureRange | 4 to 30 cmH2O | 4 to 30 cmH2O | Identical. |
| Resistance toFlow | Pressure drop through the mask at 50 L/min: 0.9 ± 0.3 cmH2O Pressure drop through the mask at 100 L/min: 2.2 ± 0.3cmH2O | Pressure drop through the mask at 50 L/min: 0.24 ± 0.15 cmH2O Pressure drop through the mask at 100 L/min: 0.47 ± 0.15 cmH2O | This difference does not raise newquestions of safety andeffectiveness. |
| Dead Space | XS: 165.2 cm3 S-M: 162.6 cm3 L: 164.1 cm3 | Small: 245.8 cc Medium: 274.1 cc Large: 321.8 cc | This difference does not raise newquestions of safety andeffectiveness. |
| Sound PowerLevel | Sound Power Level of the Mask:28.2 dBA, with uncertainty 2.5 dBA Sound Pressure Level of the Mask:20.2 dBA, with uncertainty 2.5 dBA | Sound Power Level of the Mask: 29.8 dBA,with uncertainty 2.5 dBA Sound Pressure Level of the Mask: 21.8dBA, with uncertainty 2.5 dBA | Substantially equivalent |
| Shelf-Life | 2 years | 5 years | This difference does not raise newquestions of safety andeffectiveness. |
| BreathingCircuit | Single Inspiratory Tube | Single Inspiratory Tube | Identical |
| Design /TechnologicalCharacteristic | Subject Device | Predicate Device | Comments |
| F&P Evora™ Full Face Mask | F&P Vitera™ Full Face Mask (K190713) | ||
| (PAP system –external to the"mask") | |||
| Operating andStorageConditions | Operating Temperature: 5 to 40°CStorage Temperature: -20 to 50°C | Operating Temperature: 5 to 40°CStorage Temperature: -20 to 50°C | Identical |
| Design | |||
| Swivel [4] | 22mm ISO conical connector | 22mm ISO conical connector | Identical. |
| Cleaning and High-Level Disinfection | |||
| Sterility | Device not provided sterile | Device not provided sterile | Identical |
| Reusability | Reusable - Multi Patient Use | Reusable - Multi Patient Use | Identical |
| High LevelDisinfectionMethods | Thermal Disinfection:90°C for 1 min | Thermal Disinfection:80°C for 10 mins75°C for 30 mins90°C for 1 min | Equivalent.The subject device contains asubset of the high-leveldisinfection methods compared tothe predicate. |
| Accessories | |||
| Accessory | Oxygen/Pressure Port(900HC452)Available as a separate part, not provided withdevice. | Oxygen/Pressure Port(900HC452)Available as a separate part, not provided withdevice. | Identical.The Oxygen/Pressure Port wascleared under K023559. |
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F&P Evora™ Full Face Mask – Traditional 510(k)
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VII. PERFORMANCE DATA
Summary of Non-Clinical Tests
- . Cleaning Validation
- High-Level Disinfection Validation ●
- Leak
- Dead Space Analysis
- Human Factors/Usability Engineering
- Mechanical Integrity
- Shelf-Life and Storage ●
- ISO 17510:2015 Sleep apnoea breathing therapy Masks and application ● accessories
- o CO2 Rebreathing
- Pressure-Flow Curve O
- o Exhaust Flow
- Resistance to Flow (pressure drop) O
- Inspiratory and Expiratory Resistance O
- Open-to-Atmosphere and Closed-to-Atmosphere Pressures о
- O Anti-Asphyxia Valve Pressures
- o Vibration and Noise
- ASTM 1980-16 Standard Guide for Accelerated Aging of Sterile Barrier ● Systems for Medical Devices
- ISTA 2A International Safety Transit Association Guidelines Procedure 2A: ● Packaged-Products weighing 150 lb (68 kg) or less.
- . ISO 5356-1:2015 Anaesthetic and respiratory equipment - Conical connectors: Part 1: Cones and sockets
- ISO 10993-1:2018 Biological evaluation of medical devices Part 1: Evaluation ● and testing within a risk management process
- . ISO 10993-3:2014 Biological evaluation of medical devices Part 3: Tests for genotoxicity, carcinogenicity and reproductive toxicity
- 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: Tests for irritation and skin sensitization
- SIO 10993-11:2017 Biological evaluation of medical devices Part 11: Tests for systemic toxicity
- ISO 10993-12:2012 Biological evaluation of medical devices Part 12: Sample . preparation and reference materials (available in English only)
- . ISO 10993-17:2002 Biological evaluation of medical devices Part 17: Establishment of allowable limits for leachable substances
- ISO 10993-18:2020 Biological evaluation of medical devices Part 18: Chemical ● characterization of medical device materials within a risk management process
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- . ISO 10993-33:2015 Biological evaluation of medical devices Part 33: Guidance on tests to evaluate genotoxicity - Supplement to ISO 10993-3
- ISO 18562-1:2017 Biocompatibility evaluation of breathing gas pathways in healthcare applications - Part 1: Evaluation and testing within a risk management process
- ISO 18562-2 Biocompatibility evaluation of breathing gas pathways in ● healthcare applications - Part 2: Tests for emissions of particulate matter
- ISO 18562-3 Biocompatibility evaluation of breathing gas pathways in healthcare applications - Part 3: Tests for emissions of volatile organic compounds (VOCs)
- ISO 18562-4 Biocompatibility evaluation of breathing gas pathways in . healthcare applications - Part 4: Tests for leachables in condensate
CONCLUSIONS VIII.
The F&P Evora™ Full Face Mask is substantially equivalent to the predicate based on patient population, intended uses, comparison of the technological characteristics and performance. In addition, the conclusions drawn from the non-clinical tests demonstrate that the device is substantially equivalent to the legally marketed predicate device.
§ 868.5905 Noncontinuous ventilator (IPPB).
(a)
Identification. A noncontinuous ventilator (intermittent positive pressure breathing-IPPB) is a device intended to deliver intermittently an aerosol to a patient's lungs or to assist a patient's breathing.(b)
Classification. Class II (performance standards).