K Number
K221186
Device Name
TC Gloves
Date Cleared
2022-06-16

(52 days)

Product Code
Regulation Number
880.6250
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

TC Gloves- Powder Free Nitrile Examination Gloves is a disposable device intended for medical purpose that is worn on the examiner's hand to prevent contamination between patient and examiner.

Device Description

TC Gloves- Powder Free Nitrile Examination Gloves is a Class I device bearing the product code LZA (21CFR 880.6250). They meet all the current specifications listed under the ASTM D6319 -19, Standard Specification for Nitrile Examination Gloves for Medical Application. They are made from acrylonitrilebutadiene copolymer dispersion. These gloves are blue in color having Finger Texture, Ambidextrous, Single use and are powder free. The product is non-sterile. Sizes available - S, M, L and XL.

AI/ML Overview

The provided document is a 510(k) Summary for TC Gloves - Powder Free Nitrile Examination Gloves. It focuses on demonstrating substantial equivalence to a predicate device, rather than detailed performance proof for a novel AI/software medical device. Therefore, the requested information, which is highly specific to the acceptance criteria and study design for AI-based medical devices, cannot be fully extracted from this document.

However, I can provide the acceptance criteria and reported device performance for the physical and biological characteristics of the gloves as detailed in the document, which serves as the "acceptance criteria" against which the device's performance is measured for this type of medical device (physical examination gloves).

Here's an attempt to answer the questions based on the provided document, acknowledging the limitations due to the nature of the device:

1. A table of acceptance criteria and the reported device performance

For a physical medical device like examination gloves, the "acceptance criteria" are defined by relevant ASTM standards and the "performance" is the actual test data.

SI No.Test Performed & Acceptance Criteria (ASTM D6319-19 unless specified)Reported Device Performance (Actual Data)
Dimension
1.Length: 230mm min (all sizes)S: 241.4 mm, M: 240.6 mm, L: 243.2 mm, XL: 242.7 mm
Width: S: 80 mm±10, M: 95 mm ±10, L: 110 mm ±10, XL: 120 mm ±10S: 86.6 mm, M: 96.5 mm, L: 106.4 mm, XL: 113.8 mm
Thickness (Palm): 0.05 mm min (all sizes)S: 0.14 mm, M: 0.14 mm, L: 0.14 mm, XL: 0.13 mm
Thickness (Finger): 0.05 mm min (all sizes)S: 0.16 mm, M: 0.15 mm, L: 0.15 mm, XL: 0.16 mm
Physical Property
2.Tensile Strength (Before Aging): 14 MPa Min for all sizesS: 15.7 MPa, M: 15.5 MPa, L: 15.4 MPa, XL: 15.2 MPa
Tensile Strength (After Aging): 14 MPa Min for all sizesS: 15.0 MPa, M: 15.3 MPa, L: 14.9 MPa, XL: 15.3 MPa
Ultimate Elongation (Before Aging): 500% Min for all sizesS: 515.8%, M: 514%, L: 512%, XL: 511.2%
Ultimate Elongation (After Aging): 400% Min for all sizesS: 469.2%, M: 510%, L: 510%, XL: 468.9%
Barrier Property
3.Detection of Holes (ASTM D6319-19 / ASTM D5151-19): Passes AQL 2.5S: AQL 2.5, M: AQL 2.5, L: AQL 2.5, XL: AQL 2.5
Powder Free Residue
4.Residual Powder Content (ASTM D6124-06): ≤2 mg/Glove MaxS: 0.41 mg, M: 0.23 mg, L: 0.57 mg, XL: 0.37 mg
Biocompatibility
1.In Vitro Cytotoxicity (ISO 10993-1:2018): Under the conditions of the study, not cytotoxic.Under the conditions of the study, cytotoxic to L-929 cells. Additional Testing was performed to determine if this was a systemic toxicity concern.
2.Skin Sensitization (ISO 10993-1:2018): Under the conditions of the study not a sensitizer.Under the conditions of the study not a sensitizer. (Pass)
3.Skin Irritation (ISO 10993-1:2018): Under the condition of study not an irritant.Under the condition of study not an irritant. (Pass)
4.Acute Systemic Toxicity (ISO 10993-1:2018): Under the conditions of the study, the device extracts do not pose a systemic toxicity concern.Under the conditions of the study, the device extracts do not pose a systemic toxicity concern. (Pass)
5.Material Mediated Pyrogenicity (ISO 10993-1:2018): Under the conditions of the study, the device did not demonstrate a material mediated pyrogenicity response.Under the conditions of the study, the device did not demonstrate a material mediated pyrogenicity response. (Pass)

2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

The document does not specify the exact sample sizes used for each of the performance tests (Dimension, Physical Property, Detection of Holes, Powder Free Residue, Biocompatibility). The testing is standard for manufacturing quality control of examination gloves and would typically involve sampling from production batches.

  • Sample Size: Not specified in the document.
  • Data Provenance: The tests were conducted by the manufacturer, Thanh Cong Pharmaceutical And Trading Company Limited, located in Bac Ninh province, Vietnam. The tests are non-clinical, likely prospective (testing newly manufactured gloves), and carried out to demonstrate compliance with ASTM standards.

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)

This is not applicable to the evaluation of medical examination gloves. The "ground truth" for the performance of these gloves is established through physical and chemical testing against recognized national and international standards (e.g., ASTM, ISO), not through expert consensus on medical images or clinical outcomes.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

Not applicable. This concept (adjudication for ground truth establishment) is relevant for clinical studies, particularly in image interpretation or diagnostic performance, not for the physical and chemical testing of medical gloves.

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 a physical medical device (examination gloves), not an AI/software device. No MRMC study was performed as it is not relevant to the device's function or regulatory requirements.

6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

Not applicable. This is a physical medical device. The "performance" is inherent to the glove's material properties and manufacturing.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

The "ground truth" for this device is the defined specifications within universally recognized standards like ASTM D6319-19 and ISO 10993-1:2018. Compliance with these physical, chemical, and biological properties serves as the benchmark for safety and effectiveness for examination gloves.

8. The sample size for the training set

Not applicable. There is no "training set" as this is not an AI/machine learning device.

9. How the ground truth for the training set was established

Not applicable. There is no "ground truth for a training set." The regulatory pathway for this device relies on demonstrated compliance with established performance standards and substantial equivalence to a predicate device.

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Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: a symbol on the left and the FDA name on the right. The symbol on the left is a stylized image of a human figure, while the FDA name on the right is written in blue letters. The words "U.S. FOOD & DRUG ADMINISTRATION" are written in a clear, sans-serif font.

June 16, 2022

Thanh Cong Pharmaceutical and Trading Company Limited % Manoj Zacharias US Agent Liberty Management Group Limited 75 Executive Drive, Suite 114 Aurora, Illinois 60504

Re: K221186

Trade/Device Name: TC Gloves - Powder Free Nitrile Examination Gloves Regulation Number: 21 CFR 880.6250 Regulation Name: Non-Powdered Patient Examination Glove Regulatory Class: Class I, reserved Product Code: LZA Dated: March 29, 2022 Received: April 25, 2022

Dear Manoj Zacharias:

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

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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,

Bifeng Qian, M.D., Ph.D. Acting 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) K221186

Device Name

TC Gloves- Powder Free Nitrile Examination Gloves

Indications for Use (Describe)

TC Gloves- Powder Free Nitrile Examination Gloves is a disposable device intended for medical purpose that is worn on the examiner's hand to prevent contamination between patient and examiner.

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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Image /page/3/Picture/0 description: The image shows the logo for TC Pharma. The logo features the text "TC Pharma" in green, with a stylized image of three green leaves above the text. The leaves are arranged in a cluster, with the central leaf slightly taller than the two flanking leaves. A curved, green line partially encircles the leaves and text, creating a sense of enclosure and unity.

510(k) SUMMARY (K221186)

[AS REQUIRED BY 21CFR807.92]

SUBMITTER DETAILS I.

510(k) Owner's NameTHANH CONG PHARMACEUTICAL AND TRADING COMPANYLIMITED
AddressKM 6+ 200 National Road No.38, Hap Linh, Bac Ninh City, BacNinh province, Vietnam
Contact personMs. Nguyễn Thi Tú Anh
Contact DesignationDirector of Production
Contact Phone Number098 171 2992
Contact Emailtuanhnquyentcpharma@gmail.com
Date of Summary Prepared15-06-2022

DEVICE DETAILS II.

Brand NameTC Gloves
Device Common NamePowder Free Nitrile Examination Gloves
Device Classification nameNon-powdered patient examination glove
Regulation Number21 CFR 880.6250
ClassI
Product CodeLZA

III. PREDICATE DEVICE DETAILS

Predicate Device NameJr Medic Blue Nitrile Examination Gloves Powder Free
510(k) NumberK192333
Regulation Number21 CFR 880.6250
ClassI
Product CodeLZA

Image /page/3/Picture/9 description: The image shows the word "Manufacturer:" in green font. To the left of the word is a green icon of a factory. Below the word "Manufacturer:" is the word "THANH CONG PHARMACEUTICAL" in green font.

THANH CONG PHARMACEUTICAL AND TRADING CO., LTD Km 6 + 200 National Road No.38, Hap Linh, Bac Ninh City, Bac Ninh province, Vietnam Tel: (+84) 222 3720031, (+84) 24 38563948 Email: support@tcpharma.vn * Website: http://www.tcpharma.vn

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Image /page/4/Picture/0 description: The image shows the logo for TC Pharma. The logo features a green plant with three leaves at the top, symbolizing nature and growth. Below the plant, the text "TC Pharma" is written in a bold, green font, indicating the company's name and its association with pharmaceuticals.

IV. DEVICE DESCRIPTION

TC Gloves- Powder Free Nitrile Examination Gloves is a Class I device bearing the product code LZA (21CFR 880.6250). They meet all the current specifications listed under the ASTM D6319 -19, Standard Specification for Nitrile Examination Gloves for Medical Application. They are made from acrylonitrilebutadiene copolymer dispersion. These gloves are blue in color having Finger Texture, Ambidextrous, Single use and are powder free. The product is non-sterile. Sizes available - S, M, L and XL.

V. INDICATION FOR USE

TC Gloves- Powder Free Nitrile Examination Gloves is a disposable device intended for medical purpose that is worn on the examiner's hand to prevent contamination between patient and examiner.

VI. COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE DEVICE

SI.NoFeatures comparedProposed DevicePredicate DeviceResult
General Information
1.510(k) NumberK221186K192333-
2.ManufacturerThanh Cong Pharmaceutical AndTrading Company LimitedJR Engineering & MedicalTechnologies-
3.ClassificationIISame
4.Regulation number21 CFR 880.625021 CFR 880.6250Same
5.Product CodeLZALZASame
6.Indication For UseTC Gloves-Powder Free NitrileExamination Gloves is adisposable device intended formedical purpose that is worn onthe examiner's hand to preventcontamination between patientand examiner.Jr Medic Blue Nitrile ExaminationGloves Powder Free are intendedfor medical purposes that is wornon the examiner's hands toprevent contamination betweenpatient and examiner.Same
7.MaterialNitrileNitrileSame
8.ColorBlueBlueSame
9.TextureFinger TextureFinger textureSame
10.AmbidextrousYesYesSame
11.SizeS, M, L, XLXS, S, M, L, XLSimilar-1
SI.NoFeatures comparedProposed DevicePredicate DeviceResult
12.OTC UseYesYesSame
13.ReusabilitySingle useSingle useSame
14.SterilityNon- sterileNon- sterileSame
15.Shelf Life3 yearsData Not available-
16.DimensionsLength Min 230 mmWidth Min 95+/-10 mm (formedium size)Length Min 230 mmWidth Min 95±10 mm(for medium size)Same
17.ThicknessPalm min 0.05 mmFinger min 0.05 mmPalm min 0.05 mmFinger min 0.05 mmSame
18.Physical PropertiesBefore AgingTensile Strength min 14 MpaUltimate Elongation Min 500%After AgingTensile Strength min 14 MpaUltimate Elongation Min 400%Before AgingTensile Strength min 14 MpaUltimate Elongation Min 500%After AgingTensile Strength min 14 MpaUltimate Elongation Min 400%Same
19.Detection of HolesPasses AQL 2.5Passes AQL 1.5Different-1
20.Powder Free Residue≤2 mg/glove≤2 mg/gloveSame
21.Biocompatibility StudyIn Vitro CytotoxicityUnder the conditions of thestudy, cytotoxic to L-929 cells.Additional Testing was performedto determine if this was asystemic toxicity concern.Under the conditions of thestudy, cytotoxic to L-929 cells.Additional Testing was performedto determine if this was asystemic toxicity concern.Same
Skin SensitizationUnder the conditions of the studynot a sensitizerUnder the conditions of the studynot a sensitizerSame
Skin IrritationUnder the condition of study notan irritantUnder the condition of study notan irritantSame
Material mediatedpyrogenicityUnder the conditions of thestudy, the device did notdemonstrate a material mediatedPyrogenicity response.Under the conditions of thestudy, the device did notdemonstrate a material mediatedPyrogenicity response.Same
Acute systemictoxicityUnder the condition of study, thedevice extracts do not pose asystemic toxicity.Under the condition of study, thedevice extracts do not pose asystemic toxicity.Same

Table 1: General Comparison

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Image /page/5/Picture/0 description: The image shows the logo for TC Pharma. The logo features the text "TC Pharma" in a bold, green sans-serif font. Above the text is a stylized green plant with three leaves, and the plant is encircled by two curved green lines, creating a sense of growth and nature.

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Image /page/6/Picture/0 description: The image shows the logo for TC Pharma. The logo features the text "TC Pharma" in a stylized font, with the "TC" in a darker green and "Pharma" in a lighter green. Above the text is a graphic of three green leaves, arranged in a cluster. The entire logo is encircled by a curved, light green line, giving it a natural and organic feel.

There are no significant differences between the two products and are identical in terms of intended use, materials, design, manufacturing methods. Both devices meet the ASTM standard D6319-19.

PERFORMANCE DATA VII.

  • A. Non- Clinical Data

Performance Tests

TC Gloves- Powder Free Nitrile Examination Gloves is subjected to the following performance tests according to the requirements of Guidance for Industry and FDA Staff - Medical Glove Guidance Manual and found to be safe and efficient with respect to its intended use:

  • . Dimension
  • . Physical property
  • Barrier property tests- Detection of Holes in Medical Gloves .
  • Powder Free Residue

Table 2: Performance Testing Summary

SINo.TestsProposed Device actual DataAcceptance Criteria
SizeLengthWidthSizeLengthWidth
1.DimensionLength, Width andThicknessASTM D6319-19StandardSpecification forNitrile ExaminationGloves for MedicalApplicationS241.4 mm86.6 mmS230mm min80 mm±10
M240.6 mm96.5 mmM95 mm ±10
L243.2 mm106.4 mmL110 mm ±10
XL242.7 mm113.8 mmXL120 mm ±10
ThicknessThickness
SizePalmFingerSizePalmFinger
S0.14 mm0.16 mmS0.05 mm min0.05 mm min
M0.14 mm0.15 mmM
L0.14 mm0.15 mmL
XL0.13 mm0.16 mmXL
Tensile strengthTensile strength
SizeBefore ageingAfter ageingSizeBefore ageingAfter ageing
2.Physical propertyTensile strengthand UltimateElongationASTM D6319-19StandardSpecification forNitrile ExaminationGloves for MedicalApplicationS15.7 MPa15.0 MPaS14 MPa Min for allsizes14 MPa Min for allsizes
M15.5 MPa15.3 MPaM
L15.4 MPa14.9 MPaL
XL15.2 MPa15.3 MPaXL
Ultimate elongationUltimate elongation
SizeBefore ageingAfter ageingSizeBefore ageingAfter ageing
S515.8%469.2%S
M514%510%M500% Min for allsizes400%Min for allsizes
L512%510%L

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Image /page/7/Picture/0 description: The image shows the logo for TC Pharma. The logo features the text "TC Pharma" in a stylized, green font. Above the text, there are three green leaves arranged in a cluster, suggesting a connection to nature or plant-based products. The leaves and text are encircled by a curved, green line, creating a sense of unity and completeness.

SI No.TestsProposed Device actual DataAcceptance Criteria
Detection of Holesin Medical GlovesSizeSize
3.ASTM D6319-19/ASTM D5151-19Standard TestMethod forDetection of Holesin Medical GlovesSAQL 2.5SAQL 2.5
MM
LL
XLXL
Powder FreeResidueSizeResidual powder contentSizeResidual powder content
4.ASTM D6124-06(Reapproved 2017)Standard TestMethod for ResidualPowder on MedicalGlovesS0.41 mgS
M0.23 mgM<= 2 mg/Glove Max
L0.57 mgL
XL0.37 mgXL

Biocompatibility B.

The materials used in the TC Gloves- Powder Free Nitrile Examination Gloves are biocompatible based on the biocompatibility tests mentioned in the Guidance for Industry and FDA Staff - Medical Glove Guidance Manual:

  • . Invitro Cytotoxicity
  • . Skin Sensitization
  • . Skin Irritation
  • Acute Systemic Toxicity ●
  • . Material-Mediated Pyrogenicity

These tests are performed according to ISO 10993-1:2018, Biological Evaluation of Medical Devices - Part 1, Evaluation and Testing within a Risk Management Process.

Table 3: Biocompatibility Test Summary

SI.NoTest PerformedProposed DeviceAcceptance CriteriaResult
1.In Vitro CytotoxicityUnder the conditions of thestudy, cytotoxic to L-929 cells.Additional Testing wasperformed to determine if thiswas a systemic toxicity concernUnder the conditions of thestudy, not cytotoxic.-
2.Skin SensitizationUnder the conditions of thestudy not a sensitizerUnder the conditions of thestudy not a sensitizerPass
3.Skin IrritationUnder the condition of study notan irritantUnder the condition of study notan irritantPass

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Image /page/8/Picture/0 description: The image shows a logo for TC Pharma. The logo is green and features a stylized plant with three leaves sprouting from a central point. The text "TC Pharma" is written in a bold, sans-serif font below the plant. The plant is encircled by a curved line.

4.Acute Systemic ToxicityUnder the conditions of thestudy, the device extracts do notpose a systemic toxicity concernUnder the conditions of thestudy, the device extracts do notpose a systemic toxicity concernPass
5.Material MediatedPyrogenicityUnder the conditions of the study,the device did not demonstrate amaterial mediated pyrogenicityresponse.Under the conditions of thestudy, the device did notdemonstrate amaterialmediated pyrogenicity response.Pass

C. Shelf Life Study

Expiration Date: Three years from the date of Manufacture

A provisional expiration date of three years from the date of manufacturing is provided based on the shelf life study conducted as per ASTM D7160-16 Standard Practice for Determination of Expiration Dating for Medical Gloves.

D. Clinical Test Data

The clinical study was not conducted as clinical data is not needed for TC Gloves- Powder Free Nitrile Examination Gloves.

VIII. CONCLUSION

The conclusion drawn from the non-clinical tests demonstrates that the subject device, TC Gloves-Powder Free Nitrile Examination Gloves are as safe, as effective and perform as well as or better than legally marketed predicate device in K192333.

§ 880.6250 Non-powdered patient examination glove.

(a)
Identification. A non-powdered patient examination glove is a disposable device intended for medical purposes that is worn on the examiner's hand or finger to prevent contamination between patient and examiner. A non-powdered patient examination glove does not incorporate powder for purposes other than manufacturing. The final finished glove includes only residual powder from manufacturing.(b)
Classification. Class I (general controls). The device, when it is a finger cot, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 880.9.