(88 days)
The surgical glove is a device made of natural rubber latex intended to be worn by surgeons and/or operating room personnel to protect a surgical wound from contamination.
The device in this 510(k) submission is the Powdered Brown Latex Surgical Gloves. Sterile which is made of natural rubber latex. These gloves are intended to be worn by surgeons and/or operating room personnel to protect a surgical wound from contamination.
This document describes the 510(k) submission for "Powdered Brown Latex Surgical Gloves, Sterile" by WRP Asia Pacific Sdn Bhd. The submission focuses on claims related to expiration date and protein content.
Here's an analysis of the acceptance criteria and supporting study information, based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria | Reported Device Performance |
|---|---|
| Barrier properties, physical and mechanical properties, packaging integrity, and sterility of the gloves maintained for the duration of the claimed shelf-life (i.e., 5 years). | "Based on the results obtained through out the Stability Test, it can be concluded that the Powdered Brown Latex Surgical Gloves, Sterile produced by WRP Asia Pacific Sdn Bhd has demonstrated that the barrier properties, physical and mechanical properties, packaging integrity and sterility of the gloves are maintained for the duration of the claimed shelf-life (expiration date, i.e. 5 years)." |
| Protein content level below 50 µg/g. | "Also, based on the protein content test report, the protein level of the gloves is well below 50 us/g and supports our protein content labeling claim." |
Note: While the company claims the device meets the 5-year shelf life, a later FDA letter (Page 4) indicates that the data submitted was "inadequate to support a 5 year shelf life" and that including this claim would result in the products being considered "misbranded." This highlights a discrepancy between the sponsor's claims and the FDA's assessment regarding the shelf-life acceptance criterion.
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: The document does not specify the exact sample size used for the Stability Test or the Protein Content Test. It only refers to "results obtained through out the Stability Test" and a "protein content test report."
- Data Provenance: The tests were conducted by WRP Asia Pacific Sdn Bhd, a company located in Malaysia. The stability study and protein content tests would be considered prospective as they are performed to gather data to support specific claims over time or at the time of manufacturing.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
This information is not provided in the document. The tests performed (stability, protein content) are laboratory-based and do not typically involve human expert adjudication in the way medical imaging or diagnostic devices would. The "ground truth" for these tests would be established by the standardized testing protocols and measurements themselves, not expert consensus.
4. Adjudication Method for the Test Set
This is not applicable as the tests are laboratory-based measurements (e.g., tensile strength, barrier integrity, protein quantification) and do not involve human interpretation or adjudication in the context of diagnostic performance.
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
This is not applicable. This submission is for medical gloves, a physical device, not an AI-powered diagnostic or assistive technology. Therefore, an MRMC study related to AI assistance would not be relevant.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done
This is not applicable. This submission is for medical gloves, a physical device, and does not involve an algorithm.
7. The Type of Ground Truth Used
- For the Shelf-Life Claim (Barrier Properties, Physical & Mechanical Properties, Packaging Integrity, Sterility): The ground truth is based on objective measurements and standardized tests defined by relevant industry standards (e.g., ASTM, ISO for glove properties and sterility testing) conducted over the stated shelf-life duration. The document states "results obtained through out the Stability Test" are the basis.
- For the Protein Content Claim: The ground truth is based on objective laboratory quantification of protein levels using a specific test method. The document mentions a "protein content test report."
8. The Sample Size for the Training Set
This is not applicable. This device is a physical product and does not involve a "training set" in the context of machine learning or AI development. The "training" for such a product would be its manufacturing process and quality control, not data-driven model training.
9. How the Ground Truth for the Training Set was Established
This is not applicable for the same reasons as point 8.
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Image /page/0/Picture/0 description: The image shows the logo for WRP Asia Pacific Sdn Bhd. The logo consists of the letters "WRP" in a bold, sans-serif font, enclosed in a black, rounded shape. To the right of the logo is the text "WRP Asia Pacific Sdn Bhd" in a similar bold, sans-serif font. Below the text is the number 147817V.
JUL 0 5 2002
510 (K) SUMMARY OF POWDERED BROWN LATEX SURGICAL GLOVES, STERILE
The device in this 510(k) submission is the Powdered Brown Latex Surgical Gloves. Sterile which is made of natural rubber latex. These gloves are intended to be worn by surgeons and/or operating room personnel to protect a surgical wound from contamination.
The Powdered Brown Latex Surgical Gloves, Sterile are substantially equivalent to Microptic, Brown Beaded Surgeon's Gloves (Powdered, Hypoallergenic) submitted and cleared under 510(k) number K960416. The only difference in this submission is to include the Expiration Date Labeling Claim and Protein Content Labeling Claim with no changes in product design. The results of stability study and protein content test conducted on Powdered Brown Latex Surgical Gloves, Sterile are submitted to support the expiration date labeling claim and protein content labeling claim.
Based on the results obtained through out the Stability Test, it can be concluded that the Powdered Brown Latex Surgical Gloves, Sterile produced by WRP Asia Pacific Sdn Bhd has demonstrated that the barrier properties, physical and mechanical properties, packaging integrity and sterility of the gloves are maintained for the duration of the claimed shelf-life (expiration date, i.e. 5 years). Also, based on the protein content test report, the protein level of the gloves is well below 50 us/g and supports our protein content labeling claim.
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Image /page/1/Picture/0 description: The image shows the seal of the U.S. Department of Health & Human Services. The seal features the department's name encircling a stylized caduceus symbol. The caduceus is represented by three intertwined strands forming a shape resembling a bird or abstract human figures. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular pattern around the symbol.
DEPARTMENT OF HEALTH & HUMAN SERVICES
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
Mr. K. K Leong Associate Manager, QA/RA WRP Asia Pacific Sdn. Bhd. Lot 1, Jalan 3, Kawasan Perusahaan Bandar Baru Salak Tinggi, 43900 Sepang Selangor Darul Ehsan, MALAYSIA
JUL 5 - 2002
Re: K021119
Trade/Device Name: Powdered Brown Latex Surgical Gloves, Sterile with Expiration Date Labeling Claim and Protein Content Labeling Claim Regulation Number: 878.4460 Regulation Name: Surgical Gloves Regulatory Class: I Product Code: KGO Dated: April 4, 2002 Received: April 8, 2002
Dear Mr. Leong:
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.
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Page 2 - Mr. Leong
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); 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.qov/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
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Image /page/3/Picture/0 description: The image shows the logo for WRP Asia Pacific Sdn Bhd. The logo consists of the letters "WRP" in white, set against a black oval shape. To the right of the logo is the text "WRP Asia Pacific Sdn Bhd" in a bold, sans-serif font. Below the company name is the number "147817 V".
INDICATIONS FOR USE
Applicant:
WRP Asia Pacific Sdn Bhd
KO21119 510(k) Number (if known):
Device Name:
POWDERED BROWN LATEX SURGICAL GLOVES, STERILE WITH EXPIRATION DATE LABELING CLAIM AND PROTEIN CONTENT LABELING CLAIM
Indications For Use:
The surgical glove is a device made of natural rubber latex intended to be worn by surgeons and/or operating room personnel to protect a surgical wound from contamination.
Concurrence of CDRH, Office of Device Evaluation (ODE)
Charles
(Division Sign-Off) Division of Dental, Infection Control, and General Hospital Devices 510(k) Number
Prescription Use (Per 21 CFR 801.109) OR Over-The-Counter
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
Mr. K. K. Leong Associate manager, QA/RA WRP Asia Pacific Sdn Bhd Lot 1, Jalan 3, Kawasan Perusahaan Bandar Baru Salak Tinggi, 43900 Sepang Selangor Darul Ehsan MALAYSIA
Re: K021119 (Powdered Brown Latex Surgical Gloves, Sterile with Expiration Date Labeling Claim)
K021159 (Powdered Latex Surgical Gloves, Sterile with Expiration Date Labeling Claim)
Dear Mr. Leong:
This letter notifies you that the data you submitted in your 510(k) submissions for the Powdered Brown latex Surgical Glove, Sterile with Expiration Date labeling Claim (K021119) and Powdered Latex Surgical Gloves. Sterile with expiration Date Labeling Claim (K021159) are inadequate to support a 5 year shelf life. Although FDA has determined that both 510(k)s are substantial equivalent, the shelf life labeling claim is a quality systems issue, not a premarket issue.
If you include a 5- year shelf life on your products with the data in the 510(k) submissions, FDA will consider your products misbranded.
If you wish to add a 5- year shelf life to the products labeling, please revise the test protocol you intend to use for the study, which should take FDA's July 5, 2002, comments into consideration. Please advise FDA of your intentions no later than July 31, 2002. If you have any questions, please contact Chiu Lin, Ph.D., Branch Chief, Infection Control Devices Branch at 301-443-8913.
Sincerely yours,
Timothy A. Ulatowski Director Division of Anesthesiology, General Hospital, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
§ 878.4460 Non-powdered surgeon's glove.
(a)
Identification. A non-powdered surgeon's glove is a device intended to be worn on the hands of operating room personnel to protect a surgical wound from contamination. A non-powdered surgeon's 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).