K Number
K013280
Device Name
STERILOX LIQUID CHEMICAL STERILANT SYSTEM
Date Cleared
2002-09-18

(351 days)

Product Code
Regulation Number
880.6885
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Sterilox is a high level disinfectant system intended for processing heat-sensitive medical devices when used according to the User Manual with an immersion time of ten (10) minutes at 25°C. Sterilox is a single use product generated on site for use at its MRC of 650-675 ppm (AFC). Sterilox is intended for use with manual or automatic endoscope reprocessing protocols. Sterilox High Level Disinfectant system is intended for use by qualified health care personnel trained in its use.
Device Description
The Sterilox Liquid Chemical High Level Disinfectant System is an apparatus that produces a single use High Level Disinfectant by on-site electrochemical activation (electrolysis) of a dilute aqueous solution of sodium chloride (NaCI). The germicide is then circulated through and about reusable heat-sensitive medical devices either in a manual system or within a typical washer-disinfector used in hospitals, clinics and various other health care settings. It is a device intended for use by qualified healthcare personnel trained in its use.
More Information

No
The device description and performance studies focus on the electrochemical generation and germicidal efficacy of a disinfectant solution. There is no mention of AI, ML, image processing, or any data-driven decision-making components.

No.
The device is a high-level disinfectant system used for processing heat-sensitive medical devices, not for treating or diagnosing a medical condition in a patient.

No

This device is a high-level disinfectant system used for processing heat-sensitive medical devices, not for diagnosing medical conditions.

No

The device description explicitly states it is an "apparatus that produces a single use High Level Disinfectant by on-site electrochemical activation (electrolysis)". This describes a physical hardware system, not a software-only device.

Based on the provided text, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use is for "processing heat-sensitive medical devices" as a "high level disinfectant system." This is a function related to the sterilization or disinfection of medical equipment, not for performing diagnostic tests on biological samples.
  • Device Description: The description details a system that produces a germicide for circulating through and about reusable medical devices. This aligns with disinfection/sterilization processes, not diagnostic testing.
  • Lack of IVD Indicators: The text does not mention any of the typical characteristics of an IVD, such as:
    • Analyzing biological samples (blood, urine, tissue, etc.)
    • Detecting or measuring substances in biological samples
    • Providing information for diagnosis, monitoring, or prognosis of a disease or condition
    • Use in a laboratory setting for diagnostic purposes

The device's function is clearly focused on the reprocessing of medical devices to prevent the spread of infection, which falls under the category of disinfection or sterilization equipment, not in vitro diagnostics.

N/A

Intended Use / Indications for Use

Sterilox is a high level disinfectant system intended for processing heat-sensitive medical devices when used according to the User Manual with an immersion time of ten (10) minutes at 25°C. Sterilox is a single use product generated on site for use at its MRC of 650-675 ppm (AFC). Sterilox is intended for use with manual or automatic endoscope reprocessing protocols.

Sterilox High Level Disinfectant system is intended for use by qualified health care personnel trained in its use.

Product codes

MED

Device Description

The Sterilox Liquid Chemical High Level Disinfectant System is an apparatus that produces a single use High Level Disinfectant by on-site electrochemical activation (electrolysis) of a dilute aqueous solution of sodium chloride (NaCI). The germicide is then circulated through and about reusable heat-sensitive medical devices either in a manual system or within a typical washer-disinfector used in hospitals, clinics and various other health care settings. It is a device intended for use by qualified healthcare personnel trained in its use.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

qualified health care personnel trained in its use.

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Microbiological Efficacy:

  • Sporicidal Activity of Disinfectants; AOAC Official Method 966.04: Test Organisms: Bacillus subtilis, Clostridium sporogenes. Results: Meets liquid chemical Sterilant efficacy requirements.
  • Confirmatory Sporicidal Activity of Disinfectants; AOAC Official Method 966.04: Test Organisms: Bacillus subtilis, Clostridium sporogenes. Results: Meets liquid chemical Sterilant efficacy requirements.
  • Fungicidal Activity of Disinfectants (AOAC 6.3.02:1995, Official Method 955.17): Test Organisms: Trichophyton mentagrophytes. Results: Solution is fungicidal.
  • Use-Dilution Method (AOAC 6.2.01:1995, Official Methods 955.14, 955.15, 964.02): Test Organisms: Salmonella choleraesuis, Staphylococcus aureus, Pseudomonas aeruginosa. Results: Solution is bactericidal.
  • EPA Virucidal Testing (DIS/TSS-7, Nov. 1981): Test Organisms: Herpes Simplex I, Poliovirus II, Human Immunodeficiency Virus Type I. Results: Solution is virucidal.
  • Quantitative Tuberculocidal Test: Test Organisms: Mycbacterium bovis. Results: Solution is tuberculocidal.
  • Simulated Use Test: Test Organisms: Bacillus subtilis, Clostridium sporogenes, Mycobacterium terrae. Results: Meets efficacy requirements.
    • Details: Simulated use testing was conducted using actual used flexible fiber optic endoscopes whose external surfaces and internal channels were contaminated with >10 cfu Bacillus subtilis and Clostridium sporogenes spores. The inoculated scopes were processed in Sterilox manually for 30 minutes at 23° C. Simulated use testing was conducted using actual used flexible fiberoptic endoscopes whose external surfaces and internal channels were contaminated with >10^6 cfu Mycobacterium terrae. The inoculated scopes were processed in Sterilox manually for 10 minutes at 28° C. This testing was conducted in accordance with AOAC Offficial Method 966.04, except that polyester loops (instead of silk loops) were used as a carrier.
  • Clinical In-Use: Test Organisms: Organisms remaining on flexible endoscopes after clinical use. Results: No surviving microorganisms on any of the endoscopes tested.

Residue Data:
Residue testing was performed to quantify any residuals remaining after disinfection with Sterilox above MRC and rinsing according to the label claims. The endoscope was then extracted and the eluates analyzed for residual Sterilox components. The results showed that Sterilox germicide well above its maximum use concentration is effectively removed from a complex device such as a flexible endoscope by the rinse cycle after disinfection and therefore poses no additional risk to the patient or user of the device.

Toxicological Evaluation of Sterilox:

  • Skin Irritation (Rabbits): Non-irritating
  • Skin Sensitization (Guinea Pig): Non-sensitizing
  • Acute Dermal Toxicity (Rabbits): Dermal LD50 > 2 g/kg body weight
  • Acute Oral Toxicity (Rats): Dermal LD50 > 5 g/kg body weight
  • Primary Eye Irritation (Rabbits): Non-irritating
  • Bacterial Mutation Assay: Non-mutagenic

Materials Compatibility:
The material compatibility of the Sterilox germicide was evaluated by subjecting a variety of metallic, plastic, adhesive and rubber endoscope components to continuous immersion in Sterilox. The samples were inspected for visible change, visible evidence of damage or any other change in appearance. Sterilox germicide does not produce any corrosion or other visible damage in the majority of endoscope components. Color chanqes and the "tack" of the coating of the outer endoscope sheaths were noted on some endoscopes. Corrosion was noted on anodized aluminum.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s)

K923744, K924334, K924434

Reference Device(s)

K972708, K875280

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 880.6885 Liquid chemical sterilants/high level disinfectants.

(a)
Identification. A liquid chemical sterilant/high level disinfectant is a germicide that is intended for use as the terminal step in processing critical and semicritical medical devices prior to patient use. Critical devices make contact with normally sterile tissue or body spaces during use. Semicritical devices make contact during use with mucous membranes or nonintact skin.(b)
Classification. Class II (special controls). Guidance on the Content and Format of Premarket Notification (510(k)) Submissions for Liquid Chemical Sterilants/High Level Disinfectants, and user information and training.

0

510(k) Summary 1

1.1Date of Summary Preparation:Wednesday, September 18, 2002
1.2Manufacturers Contact Person:Howard Mann
VP U.S. Operations, QA/RA
TEL (610)-341-1899
FAX (610)-341-0503
Sterilox Technologies Inc
320 King of Prussia Road, Suite 200
Radnor, PA 19087
1.3Trade Name:Sterilox Liquid Chemical High Level
Disinfectant System

1.4 Classification Name, Product Code, Class, Classification Reference:

Classification NameProduct CodeClass21CFR §
High Level DisinfectantMEDII880.6885

1.5 Special Controls:

Guidance on the Content and Format of Pre-market Notification [510(k)] Submissions for Liquid Chemical Sterilant/ High Level Disinfectants; user information and training.

1.6 Indications for Use:

Sterilox is a high level disinfectant system intended for processing heat-sensitive medical devices when used according to the User Manual with an immersion time of ten (10) minutes at 25°C. Sterilox is a single use product generated on site for use at its MRC of 650-675 ppm (AFC). Sterilox is intended for use with manual or automatic endoscope reprocessing protocols.

Sterilox High Level Disinfectant system is intended for use by qualified health care personnel trained in its use.

1.7 Device Description:

The Sterilox Liquid Chemical High Level Disinfectant System is an apparatus that produces a single use High Level Disinfectant by on-site electrochemical activation (electrolysis) of a dilute aqueous solution of sodium chloride (NaCI). The germicide is then circulated through and about reusable heat-sensitive medical devices either in a manual system or within a typical washer-disinfector used in hospitals, clinics and various other health care settings. It is a device intended for use by qualified healthcare personnel trained in its use.

1

The Sterilox device is similar in design, materials and intended use to other 510(k) cleared devices/instruments which are in commercial distribution.

Substantially Equivalent Commercially Available Devices: 1.8

The Sterilox Liguid Chemical High Level Disinfectant System is substantially equivalent to the products described herein with respect to indications for use, device design, materials, and method of manufacture. Section 4 and Appendix A contains all relevant and available information for the following commercially available predicate devices:

Cidex liquid chemical sterilants/disinfectants ~ (K923744, K924334, K924434) Endo-Spor Plus/Hyprocide Liquid Chemical Sterilants ~ (K972708) Steris 20™ Sterilant/Steris System 1™ Processor ~ (K875280)

These predicate devices are commercially available and marketed Unclassified and Class II devices indicated for use as liquid chemical sterilants/high level disinfectants.

1.9 Substantial Equivalence Comparison:

The Sterilox Liquid Chemical High Level Disinfectant System is similar to commercially available devices with respect to intended use, material, design and operational principles as follows:

1.9.1 General:

| | Sterilox Liquid
Chemical High Level
Disinfectant System
(System and Germicide) | Steris
(System and Germicide) | Endo-Spor
Plus/Hyprocide
(Germicide) | Cidex
(Germicide) |
|--------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Labeling | High Level Disinfectant | Liquid Chemical sterilant | Liquid Chemical
Sterilant/High Level
Disinfectant | Liquid Chemical
Sterilant/High Level
Disinfectant |
| Intended Use | Disinfect reusable heat-
sensitive medical devices
which contact normally
sterile areas of the body

Intended for use by
qualified healthcare
personnel trained in its
use. | Disinfect reusable heat-
sensitive medical devices
which contact normally
sterile areas of the body

Intended for use by
qualified healthcare
personnel trained in its
use. | Disinfect reusable
heat-sensitive
medical devices
which contact
normally sterile
areas of the body

Intended for use by
qualified healthcare
personnel trained in
its use. | Disinfect reusable
heat-sensitive
medical devices
which contact
normally sterile
areas of the body

Intended for use by
qualified healthcare
personnel trained in
its use. |
| | | | | |

2

| | Sterilox Liquid
Chemical High Level
Disinfectant System
(System and Germicide) | Steris
(System and Germicide) | Endo-Spor
Plus/Hyprocide
(Germicide) | Cidex
(Germicide) |
|----------------------------------------|-----------------------------------------------------------------------------------------|---------------------------------------------------------------------------------|-----------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------|
| Human
Factors | Dispensed ready to use | Dispensed ready to use | Dispensed ready to
use | Needs
activation |
| Design,
Construction,
Components | Aqueous solution
Used in a standalone
container or
Washer/Disinfector | Aqueous solution
Must be used in a
dedicated sterile
processing system | Aqueous solution
Used in a
standalone
container or
Washer/Disinfector | Aqueous solution
Used in a
standalone
container or
Washer/Disinfector |
| Process
Monitors | Pre-programmed
colorimeter for direct-
reading of chlorine
concentration | Chemical reaction on
indicator pad to produce
color change | None | Chemical Indicator
Chemical reaction
on indicator pad to
produce color
change |
| Reuse | Single use | Single use | 14 days | 14 days |
| Software
Controls | Yes | Yes | N/A | N/A |
| Process Parameters | | | | |
| Liquid
Chemical
Sterilant | N/A | 12 min at 50-56°C | 180 min at 20°C | 10 hr at 25°C |
| High Level
Disinfectant | 10 min at 25°C | N/A | 15 min at 20°C | 45 min at 25°C |

1.9.2 Operational Principles:

The basic operational principles of the Sterilox Liquid Chemical High Level Disinfectant System and the predicate devices are similar in that they result in high level disinfection of reusable medical equipment that is heat sensitive by putting their germicides in contact with the devices for a specified period of time and temperature, in either static or dynamic conditions. The operating principles are compared as follows:

| | Sterilox Liquid
Chemical High Level
Disinfectant System
(System and Germicide) | Steris
(System and Germicide) | Endo-Spor
Plus/Hyprocide
(Germicide) | Cidex
(Germicide) |
|---------|-----------------------------------------------------------------------------------------|----------------------------------|--------------------------------------------|----------------------|
| Form | Inputs of water &
germicide | Inputs of water &
germicide | germicide | germicide |
| Control | Software controlled | Software controlled | N/A | N/A |

3

| | Sterilox Liquid
Chemical High Level
Disinfectant System
(System and Germicide) | Steris
(System and Germicide) | Endo-Spor
Plus/Hyprocide
(Germicide) | Cidex
(Germicide) |
|-------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact | Liquid contact | Liquid contact | Liquid contact | Liquid contact |
| Purpose | To achieve high level
disinfection by
destroying viable
forms of microbial life,
when used according
to labeling | To achieve liquid
chemical sterilization
by destroying viable
forms of microbial life,
when used according
to labeling | To achieve liquid
chemical
sterilization or
high level
disinfection by
destroying viable
forms of microbial
life, when used
according to
labeling | To achieve liquid
chemical
sterilization or
high level
disinfection by
destroying viable
forms of microbial
life, when used
according to
labeling |
| Mode of
Action | Sterilox exerts its
germicidal effect by
attacking the surface
and plasma
membrane proteins,
impairing transport of
solutes and the salt
balance of bacterial
cells (Pieterson et al,
Water SA (1996)
22(1); 43-48) | It is believed that
peracetic acid exerts
its germicidal effect by
oxidizing sulfhydryl
and sulfur bonds in
proteins and
enzymes, particularly
in the cell walls
(Block, 1991) | It is believed that
hydrogen
peroxide and
peracetic acid
exert their
germicidal effect
by oxidizing
sulfhydryl and
sulfur bonds in
proteins and
enzymes,
particularly in the
cell walls (Block,
1991) | Strong interaction
with outer cell
layers; cross
linking of amino
groups in proteins
and inhibition of
transport
processes into
cell (McDonell,
Clin. Microbiol.
Rev., 1999 147-
179) |

The parameters that are measured and displayed are generally the same as those for the predicate devices

Indications and Contraindications: 1.10

Relative indications and contraindications for the Sterilox Liquid Chemical High Level Disinfectant System and commercially available devices for similar intended uses are the same.

4

Microbiological Efficacy: 1.11

The Sterilox germicide is a single use solution and all efficacy testing was conducted at the MRC of 650 ppm AFC.

Test MethodTest OrganismsResults
Sporicidal Activity of
Disinfectants; AOAC Official
Method 966.04Bacillus subtilis
Clostridium sporogenesMeets liquid chemical
Sterilant efficacy
requirements3
Confirmatory Sporicidal
Activity of Disinfectants; AOAC
Official Method 966.04Bacillus subtilis
Clostridium sporogenesMeets liquid chemical
Sterilant efficacy
requirements3
Fungicidal Activity of
Disinfectants (AOAC
6.3.02:1995, Official Method
955.17)Trichophyton mentagrophytesSolution is fungicidal
Use-Dilution Method (AOAC
6.2.01:1995, Official Methods
955.14, 955.15, 964.02)Salmonella choleraesuis
Staphylococcus aureus
Pseudomonas aeruginosaSolution is bactericidal
EPA Virucidal Testing
(DIS/TSS-7, Nov. 1981)Herpes Simplex I
Poliovirus II
Human Immunodeficiency
Virus
Type ISolution is virucidal
Quantitative Tuberculocidal
TestMycbacterium bovisSolution is tuberculocidal
Simulated Use TestBacillus subtilis1
Clostridium sporogenes1
Mycobacterium terrae2Meets efficacy
requirements
Clinical In-UseOrganisms remaining on flexible
endoscopes after clinical useNo surviving
microorganisms on any of
the endoscopes tested.

'Simulated use testing was conducted using actual used flexible fiber optic endoscopes whose external surfaces and internal channels were contaminated with >10 cfu Bacillus subtilis and Clostridium sporogenes spores. The inoculated scopes were processed in Sterilox manually for 30 minutes at 23° C. 2Simulated use testing was conducted using actual used flexible fiberoptic endoscopes whose external

surfaces and internal channels were contaminated with >10°cfu Mycobacterium terrae. The inoculated scopes were processed in Sterilox manually for 10 minutes at 28 C

"This testing was conducted in accordance with AOAC Offficial Method 966.04, except that polyester loops (instead of silk loops) were used as a carrier.

5

Residue Data: 1.12

Residue testing was performed to quantify any residuals remaining after disinfection with Sterilox above MRC and rinsing according to the label claims. The endoscope was then extracted and the eluates analyzed for residual Sterilox components. The results showed that Sterilox germicide well above its maximum use concentration is effectively removed from a complex device such as a flexible endoscope by the rinse cycle after disinfection and therefore poses no additional risk to the patient or user of the device.

1.13 Toxicological Evaluation of Sterilox:

Testing was performed to determine the potential toxicological effects of exposure to Sterilox liquid chemical High Level Disinfectant. The results are summarized as follows:

Skin Irritation (Rabbits)Non-irritating
Skin Sensitization (Guinea Pig)Non-sensitizing
Acute Dermal Toxicity (Rabbits)Dermal LD50 > 2 g/kg body weight
Acute Oral Toxicity (Rats)Dermal LD50 > 5 g/kg body weight
Primary Eye Irritation (Rabbits)Non-irritating
Bacterial Mutation AssayNon-mutagenic

In section III.I.3 'Evaluation of toxicity' of the guidance for industry and FDA reviewers indicates the tests that should be considered when evaluation the biocompatibility of the germicidal product or the individual ingredients.

1.14 Patient toxicity:

Skin irritation and skin sensitization maximization test have been conducted on the product, Sterilox germicide. The test reports indicate that the studies were conducted properly. There were no indications of irritation or sensitization. Although positive results of studies on cytotoxicity and on haemocompatibility might be predicted from knowledge of the effects of hypotonic aqueous solutions generally, these results would also be expected of any suitably disinfected water used to rinse equipment.

As the toxicity of the product is essentially similar to that of chlorine based disinfectants, it is unlikely that any useful information will be obtained from further studies and it is therefore undesirable on the grounds of animal welfare to conduct these studies.

1.15 User toxicity:

An acute oral toxicity test (by the OECD 'fixed dose' procedure), a primary eve irritancy study and a bacterial mutagenicity study in Salmonella typhimurium (the 'Ames' test) have been conducted on the product, Sterilox germicide. The test reports indicate that the studies were conducted properly. The results of these tests indicated that Sterilox germicide is non-mutagenic and non-irritating to the eye.

As, for toxicological purposes, the product is essentially equivalent to chlorine disinfectant, the conclusion reached by the International Program on Chemical Safety in Environmental Health Criteria 216 (2000) concerning the toxic effects of these disinfectants in drinking water that:

6

"Evidence from animal and human studies suggests that exposure to chlorine, chlorite solutions, chloramine and chlorine dioxide themselves probably do not contribute to the development of cancer or any toxic effects".

This also applies to the Sterilox germicide solution, thus undertaking additional testing is scientifically unnecessary and, on animal welfare grounds the studies should be omitted.

Toxicological Conclusion: 1.16

For all practical purposes the health risks to patient and to operator arising from exposure to Sterilox germicide and diluted Sterilox germicide are minimal. The principal potential effect of the chemicals present in Sterilox would be irritation, but Sterilox does not exhibit this effect in tests. Sterilox is unlikely to pose a significant risk to either patient or user.

1.17 -Materials Compatibility:

The material compatibility of the Sterilox germicide was evaluated by subjecting a variety of metallic, plastic, adhesive and rubber endoscope components to continuous immersion in Sterilox. The samples were inspected for. visible change, visible evidence of damage or any other change in appearance. Sterilox germicide does not produce any corrosion or other visible damage in the majority of endoscope components. Color chanqes and the "tack" of the coating of the outer endoscope sheaths were noted on some endoscopes. Corrosion was noted on anodized aluminum. Refer to User Manual for materials compatibility information.

Assessment of non-clinical performance data for equivalence: 1.18

Currently there are no FDA standards for this device. However, the Sterilox Liquid Chemical High Level Disinfectant System complies with:

The Essential Requirements of Annex I of the Medical Device Directive 93/42/EEC and is manufactured under a Quality System approved by LRQA (Notified Body No. 0088) complying with Annex VII & V of the Directive.

The Sterilox Liquid Chemical High Level Disinfectant System intends to comply with the FDA guidance document "Content and Format of Premarket Notification [510(k)] Submissions for Liquid Chemical Sterilants/High Level Disinfectants," dated January 3, 2000, where applicable.

1.19 Conclusion:

In accordance with the Federal Food, Drug and Cosmetic Act and 21 CFR Part 807, and based on the information provided in this pre-market notification, Sterilox Technologies concludes that the new device, the Sterilox Liquid Chemical High Level Disinfectant System, is safe, effective and substantially equivalent to the predicate device as described herein.

7

DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/7/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circle with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" arranged around the circumference. Inside the circle is a stylized image of an eagle's head with three wavy lines extending from the back of the head, resembling feathers or streams.

Public Health Service

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

SEP 1 8 2002

Sterilox Technologies, Incorporated C/O Mr. Robert Mosenkis Responsible Third Party Official CITECH 5200 Butler Pike Plymouth Meeting, Pennsylvania 19462-1298

Re: K013280

Trade/Device Name: Sterilox Liquid Chemical High Level Disinfectant System Regulation Number: 880.6885 Regulation Name: Liquid Chemical Sterilants/High Level Disinfectants Regulatory Class: II Product Code: MED Dated: September 5, 2002 Received: September 6, 2002

Dear Mr. Mosenkis:

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.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such 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.

8

Page 2 - Mr. Mosenkis

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); 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.

This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and additionally 21 CFR Part 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4618. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html

Sincerely yours,

Timothy A. Ulatowski

Timothy A. Ulatowski Director Division of Anesthesiology, General Hospital, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

9

Page 1 of 1

510(k) Number:

Device Name : Sterilox Liquid High Level Disinfectant System

Indications for Use:

Sterilox is a high level disinfectant system intended for processing heat-sensitive medical devices when used according to the User Manual with an immersion time of ten (10) minutes at 25°C. Sterilox is a single use product generated on site for use at its MRC of 650-675 ppm (AFC). Sterilox is intended for use with manual or automatic endoscope reprocessing protocols.

This device is intended for use by qualified healthcare personnel trained in its use.

R. Culleton A.

Division Sign-Of ivision of Anesthesidlogy, General Hospital, Infection Control. Denta 510(k) Number:

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)