(47 days)
The various models of Inovel Type N95 Healthcare Particulate Respirators and Surgical Masks meet CDC Guidelines for TB Exposure Control within healthcare facilities. These devices are also intended to be worn by healthcare personnel during surgical procedures to protect both the patient and healthcare personnel from the transfer of microorganisms, body fluids and particulate material.
The Inovel type N95 Healthcare Particulate Respirators and Surgical Masks are constructed from an extruded plastic mesh used in the outer cover and a nonwoven spunbond used in the inner and outer cover. The polypropylene melt blown filter media is lavered between the inner and outer cover. The head strap is made of a non-latex rubber stapled to the mask. The inside nosepiece is a closed cell foam.
Here's an analysis of the acceptance criteria and study information for the Inovel Health Care N95 Particulate Respirators and Surgical Masks based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
| Performance Characteristic | Test Method | Acceptance Criteria | Reported Device Performance (New Models) | Predicate Device Performance |
|---|---|---|---|---|
| Fluid Resistance Performance | ASTM 1862 - 00a | 32 of 32 pass | 32 of 32 pass | 32 of 32 pass |
| Flammability Class | 16 CFR 1610 | Flame spread must be within upper and lower limits / No flame spread on 10 of 10 samples, meets Class I | No flame spread on 10 of 10 samples, meets Class I | No flame spread on 10 of 10 samples, meets Class I |
| Filter Efficiency (%) | NIOSH, 42 CFR Part 84 | > 95% Efficient | Average 99.33% efficient of 20 samples | Average 99.11% efficient of 20 samples |
| Breathing Resistance (mm H2O) | NIOSH, 42 CFR Part 84 | ≤ 35.0 mm H2O @ 85 lpm | Average 8.1 mm H2O @ 85 lpm of 3 samples | Average 11.3 mm H2O @ 85 lpm of 3 samples |
| Biocompatibility (Cytotoxicity) | ISO 10993 -- 1 | Score of 2 or less | Same as predicate device (Score of 0) | Score of 0 |
| Biocompatibility (Sensitization) | ISO 10993 -- 1 | Grade 1 (no different than control) | Same as predicate device (Grade 1) | Grade 1 |
| Biocompatibility (Primary Skin Irritation) | ISO 10993 -- 1 | Negligible | Same as predicate device (Negligible) | Negligible |
| Bacterial Filtration Efficiency | Modified Greene and Vesley Method. J Bacteriol 83:663-667 | Greater than 99.9% | Greater than 99.9% | Greater than 99.9% |
2. Sample Sizes Used for the Test Set and Data Provenance
- Fluid Resistance: 32 samples. Data provenance not explicitly stated (location of testing shown as "Inovel LLC" per the performance tests table, which is the manufacturer).
- Flammability Class: 10 samples. Data provenance not explicitly stated (location of testing shown as "Nelson Laboratories").
- Filter Efficiency: 20 samples. Data provenance not explicitly stated (location of testing shown as "NIOSH").
- Breathing Resistance: 3 samples. Data provenance not explicitly stated (location of testing shown as "NIOSH").
- Biocompatibility (Cytotoxicity, Sensitization, Primary Skin Irritation): Sample size for these tests is not explicitly stated, but the results are reported as "Same as predicate device" which had "Score of 0" for cytotoxicity, "Grade 1" for sensitization, and "Negligible" for primary skin irritation. These tests were conducted on predicate devices made from the same materials. Locations of testing shown as "Nelson Laboratories" and "Northview Pacific Laboratories, Inc."
- Bacterial Filtration Efficiency: Sample size not explicitly stated, but results indicate "Test results show a bacterial filtration efficiency greater than 99.9%". Location of testing shown as "Nelson Laboratories".
The text doesn't specify if the data is retrospective or prospective, nor does it provide a country of origin beyond identifying the laboratories and the manufacturer's location (Culver City, California).
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
The document describes performance testing based on established standards (ASTM, NIOSH, ISO, CFR) conducted by recognized laboratories. It does not mention "experts" establishing a "ground truth" in the way one might for diagnostic accuracy studies with human-interpreted data. The ground truth for these physical and biological performance characteristics is inherently defined by the test methods and regulatory standards themselves (e.g., a filter either achieves >95% efficiency or it doesn't, as measured by the specified NIOSH method).
4. Adjudication Method for the Test Set
Not applicable. The tests described are objective, standardized laboratory tests. There is no mention of subjective interpretation of results that would require an adjudication method among multiple human readers.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and Effect Size
No, a multi-reader multi-case (MRMC) comparative effectiveness study was not done. This device is a physical medical device (N95 respirator and surgical mask), not an AI-powered diagnostic tool, so such a study design is not relevant.
6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done
Not applicable. This device is a physical product, not an algorithm.
7. The Type of Ground Truth Used
The ground truth used for these performance tests is defined by the objective measurement criteria and standards outlined in the specified test methods (e.g., ASTM F 1862 for fluid resistance, 42 CFR Part 84 for filter efficiency and breathing resistance, 16 CFR 1610 for flammability, ISO 10993 for biocompatibility, and Modified Greene and Vesley Method for bacterial filtration efficiency). These are verifiable, quantitative measurements against regulatory and industry standards.
8. The Sample Size for the Training Set
Not applicable. This is a physical device, not an AI model, and therefore does not have a "training set."
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there is no training set for a physical device.
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Image /page/0/Picture/1 description: The image shows the word "inovel" in a bold, sans-serif font. Below the word "inovel" is the phrase "Different by design." in a smaller, italicized font. The text is black against a white background.
10111 WEST JEFFERSON BOULEVARD, CULVER CITY, CALIFORNIA 90232 FAX 310-837-0468 www.inovelmedical.com HONE 886-546-6835
August 8, 2006
12 - 1
510(k) Summary
Submitter:
OCT 2 4 2006
Inovel LLC 10111 W. Jefferson Blvd. Culver City, CA 90232-3509
Contact:
William Wawrzyniak Director Quality Assurance Telephone: 866-546-6835 Ext. 705 Fax: 310-837-0468 E-mail: billw@inovelmedical.com
Trade Name:
Inovel Health Care N95 Particulate Respirators and Surgical Masks, various models.
Common Name:
Health Care N95 Particulate Respirators and Surgical Masks.
Classification:
Name - Surgical Apparel, as described in 21 CFR 878.4040. Device Class - Class II Product Code - MSH CFR Section - 21 CFR 878.4040
Substantial Equivalency:
Inovel Health Care N95 Particulate Respirators and Surgical Masks are found to be substantially equivalent to Inovel Health Care N95 Particulate Respirators and Surgical Masks models 3000N95-XS, 3001N95-S, 3002N95-M, 3003N95-L, 3004N95-LP, 3101N95-S, 3102N95-M/L, and 3104N95-LP [(510(k) K051182]. These products have also been tested and approved by NIOSH as N95 Respirators.
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Image /page/1/Picture/1 description: The image shows the word "iNovel" in a bold, sans-serif font. The letters are black and slightly pixelated. Below the word "iNovel" is the phrase "Different by design." in a smaller, italicized font.
1 WEST JEFFERSON BOULEVARD, CULVER CITY, CALIFORNIA 90232 NE 886-548-8835
12 - 2
510(k) Summary (Continued)
Description:
The Inovel type N95 Healthcare Particulate Respirators and Surgical Masks are constructed from an extruded plastic mesh used in the outer cover and a nonwoven spunbond used in the inner and outer cover. The polypropylene melt blown filter media is lavered between the inner and outer cover. The head strap is made of a non-latex rubber stapled to the mask. The inside nosepiece is a closed cell foam.
The Inovel type N95 Healthcare Particulate Respirators and Surgical Masks are approved by NIOSH in accordance with 42 CFR Part 84. The certification numbers are TC-84A-4333 and TC-84A-4338.
The type N95 must meet the prescribed test criteria which specifies the use of 0.055 to 0.095 micron diameter challenge and requiring a 95% efficiency or better. The masks are resistant to synthetic blood as per ASTM F 1862 Standard Test method for Resistance of Medical Face Mask to Penetration by Synthetic Blood. Breathing resistance was tested by NIOSH in accordance to 42 CFR Part 84. The devices have a Bacterial Filtration Efficiency greater than 99.9%. Testing was conducted by Nelson Laboratories using the Modified Green and Vesley Method for evaluation of bacterial filtration efficiency of surgical masks.
Intended Use:
The various models of Inovel Type N95 Healthcare Particulate Respirators and Surgical Masks meet CDC Guidelines for TB Exposure Control within healthcare facilities. These devices are also intended to be worn by healthcare personnel during surgical procedures to protect both the patient and healthcare personnel from the transfer of microorganisms, body fluids and particulate material.
- Limitations:
These products do not eliminate the wearer from any risk of contracting any type of disease or infection. The mask should be changed immediately if contaminated with blood or body fluids.
Comparison of Predicate Devices:
The outside cover of the previously cleared devices incorporate a nonwoven polypropylene material with a layer of an extruded plastic mesh and the Inovel models 1510, 3211N95-S, 3212N95-M/L and 3217N95-LP incorporate an extruded plastic mesh without the nonwoven material on the outer cover. The head strap color of the cleared device is the same as the Inovel device models for which clearance is being requested.
The Inovel type N95 Healthcare Particulate Respirators and Surgical Masks incorporate a highly efficient filter media and is 95% efficiency or better against aerosols that have a count median diameter of 0.055 - 0.095 microns which was scientifically established as the most penetrating particle size. The legally marketed devices previously cleared 510(k) are manufactured from similar materials.
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12062665
Image /page/2/Picture/1 description: The image shows the logo for "Inovel" in a bold, sans-serif font. Below the logo, in a smaller, italicized font, is the tagline "Different by design.". The logo and tagline are both in black against a white background.
10111 WEST JEFFERSON BOULEVARD, CULVER CITY, CALIFORNIA 90232 TELEPHONE 866-546-8835 FAX 310-837-0468 www.inovelmedical.com
12 -- 3
510(k) Summary (continued)
Device and Predicate Devices Descriptions/ Comparisons
| Description | Inovel Health Care N95 ParticulateRespirators and Surgical Masks, models1510, 3211N95-S, 3212N95-M/L,3217N95-LP | Inovel Health Care N95 ParticulateRespirators and Surgical Masks, models3000N95-XS, 3001N95-S, 3002N95-M,3003N95-L, 3004N95-LP, 3101N95-S,3102N95-M/L, 3104N95-LP |
|---|---|---|
| Materials | ||
| Outer CoverFabrics | Ethylene-Vinyl Acetate Copolymer,extruded | Polypropylene Spunbond and Ethylene-Vinyl Acetate Copolymer, extruded |
| Nosepiece | Polyethylene foam | Polyethylene foam |
| Headband | Various colors elastic, latex free | Various colors elastic, latex free |
| Specification &Dimensions | Overall width: 4 5/8-7 3/4 inches | Overall width: 4 5/8-7 3/4 inches |
| Overall height: 4 3/4 - 5 1/2 inches | Overall height: 4 3/4 - 5 1/2 inches | |
| Mask Style | Molded Cup | Molded Cup |
| Design Features | Dual synthetic rubber or single elastichead strap | Dual synthetic rubber or single elastichead strap |
| NIOSH Certification# | TC-84A-4333TC-84A-4338 | TC-84A-4102TC-84A-4103 |
Risks to Health
:
| PerformanceCharacteristics | Test Method | Acceptance criteria/ Results | Predicate Device Results |
|---|---|---|---|
| Fluid ResistancePerformance | ASTM 1862 - 00a | 32 of 32 pass | 32 of 32 pass |
| Flammability Class | 16 CFR 1610 | Flame spread must be withinupper and lower limits/ Noflame spread on 10 of 10samples, meets Class I | Flame spread must be withinupper and lower limits/ No flamespread on 10 of 10 samples,meets Class I |
| Filter Efficiency(%) | NIOSH, 42 CFRPart 84 | > 95% Efficient/ average99.33% efficient of 20 samples | > 95% Efficient/ average 99.11%efficient of 20 samples |
| BreathingResistance(mm H2O) | NIOSH, 42 CFRPart 84 | ≤ 35.0 mm H2O @ 85 lpm/average 8.1 mm H2O @ 85lpm of 3 samples | ≤ 35.0 mm H2O @ 85 lpm/average 11.3 mm H2O @ 85 lpmof 3 samples |
| Biocompatibility * | ISO 10993 -- 1 | CytotoxicitySame as predicate deviceSensitizationSame as predicate devicePrimary Skin IrritationSame as predicate device | Cytotoxicity, score of 2 or less/Score of 0Sensitization, Grade 1 (nodifferent than control)/ Grade 1Primary Skin Irritation,Negligible/Negligible |
| Bacterial FiltrationEfficiency | Modified Greeneand VesleyMethod. J Bacteriol83:663-667 | Test results show a bacterialfiltration efficiency greaterthan 99.9% | Greater than 99.9% |
- Tests were conducted on Predicate Devices which are made from the same material as models identified in this 510(k) submission.
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Image /page/3/Picture/1 description: The image shows the logo for "inovEL" in a bold, sans-serif font. The letters are black and blocky, giving the logo a modern and industrial feel. Below the main logo, in a smaller, italicized font, is the tagline "Different by design."
EST JEFFERSON BOULEVARD, CULVER CITY, CALIFORNIA 9023 JE 886-546-8835
12 - 4
510(k) Summary (Continued)
Performance Tests:
These products were tested and certified by NIOSH as an approved N95 Respirator. It meets all the requirements prescribed in 42 CFR Part 84 and is assigned TC-84A-4333 and TC-84A-4338.
| Tests Performed | Laboratory |
|---|---|
| 1. Fluid Resistance - Resistance of Liquid(Synthetic Blood Penetration Resistance)ASTM F 1862. | Inovel LLC |
| 2. Filtration Efficiency (Particulate andBacterial) 42 CFR Part 84 | NIOSH |
| 3. Differential Pressure (Delta P) - BreathingResistance 42 CFR Part 84 | NIOSH |
| 4. Flammability 16 CFR 1610 (Class 1) | Nelson Laboratories |
| 5. Biocompatibility* (tested onpredicate devices)Cytotoxicity (ISO 10993-5) Sensitization (ISO 10993-10) Irritation (ISO 10993-10) | Nelson LaboratoriesNorthview Pacific Laboratories, Inc.(Coordinated by Nelson Laboratories)Northview Pacific Laboratories, Inc(Coordinated by Nelson Laboratories) |
| 6. Bacterial Filtration EfficiencyModified Greene and VesleyMethod. J Bacteriol 83:663-667 | Nelson Laboratories |
- Tests were conducted on Predicate Devices which are made from the same material as models identified in this 510(k) submission.
Safety/ Effectiveness:
The devices have a filtration equivalent to the previously cleared Inovel LLC N95 Particulate Respirator and Surgical mask models 3000N95-XS, 3001N95-S, 3002N95-M, 3003N95-L, 3004N95-LP, 3101N95-S, 3102N95-M/L and 3104N95-LP 510(k) number K051182. They are NIOSH approved and meet the CDC guidelines for TB exposure control.
Conclusion:
The basic construction and material used in the cleared devices are the same as in the new devices. The cleared devices and the new devices are also approved by NIOSH, and meets all other required tests. The Inovel type N95 Healthcare Particulate Respirators and Surgical Masks are substantially equivalent to those listed on page 2 - 4.
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Image /page/4/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle with three overlapping wings, representing the department's mission to protect the health of all Americans and provide essential human services. The logo is surrounded by the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" in a circular arrangement.
Public Health Service
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
OCT 9: 4 2006
Inovel LLC C/O Mr. Daniel W. Lehtonen Responsible Third Party official Intertek Testing Services 2307 East Aurora Road, Unit B7 Twinsburg, Ohio 44087
Re: K062665
Trade/Device Name: Health Care N95 Particulate and Surgical Masks, Models 1510, 3211N95-S, 3212N95-M/L, 3217N95-LP Regulation Number: 878.4040 Regulation Name: Surgical Apparel Regulatory Class: II Product Code: MSH Dated: October 16, 2006 Received: October 17, 2006
Dear Mr. Lehtonen:
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. Lehtonen
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 (OS) 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), please contact the Office of Compliance at (240) 276-0115. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). You may obtain other general information on your responsibilities under the Act 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/industry/support/index.html.
Sincerely yours,
Director
Cui Lin, Ph.D.
Division of Anesthesiology, General Hospital, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Indications for Use
510(k) Number (if known): KOG 2 665
Device Name: Health Care N95 Particulate Respirators and Surgical Masks, models 1510, 3211N95-S, 3212N95-M/L, 3217N95-LP
Indications for Use:
The various models of Inovel Type N95 Healthcare Particulate Respirators and Surgical Masks meet CDC Guidelines for TB Exposure Control within healthcare facilities. These devices are also intended to be worn by healthcare personnel during surgical procedures to protect both the patient and healthcare personnel from the transfer of microorganisms, body fluids and particulate material.
Prescription Use . AND/OR (Part 21 CFR 801 Subpart D)
Over-The-Counter Use . X (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
ា
I ansion of Anesthesiology, General Hospital Interion Control, Dental Device
Page 1 of 1
C.R.(K) Number:__
-1.
§ 878.4040 Surgical apparel.
(a)
Identification. Surgical apparel are devices that are intended to be worn by operating room personnel during surgical procedures to protect both the surgical patient and the operating room personnel from transfer of microorganisms, body fluids, and particulate material. Examples include surgical caps, hoods, masks, gowns, operating room shoes and shoe covers, and isolation masks and gowns. Surgical suits and dresses, commonly known as scrub suits, are excluded.(b)
Classification. (1) Class II (special controls) for surgical gowns and surgical masks. A surgical N95 respirator or N95 filtering facepiece respirator is not exempt if it is intended to prevent specific diseases or infections, or it is labeled or otherwise represented as filtering surgical smoke or plumes, filtering specific amounts of viruses or bacteria, reducing the amount of and/or killing viruses, bacteria, or fungi, or affecting allergenicity, or it contains coating technologies unrelated to filtration (e.g., to reduce and or kill microorganisms). Surgical N95 respirators and N95 filtering facepiece respirators are exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to § 878.9, and the following conditions for exemption:(i) The user contacting components of the device must be demonstrated to be biocompatible.
(ii) Analysis and nonclinical testing must:
(A) Characterize flammability and be demonstrated to be appropriate for the intended environment of use; and
(B) Demonstrate the ability of the device to resist penetration by fluids, such as blood and body fluids, at a velocity consistent with the intended use of the device.
(iii) NIOSH approved under its regulation.
(2) Class I (general controls) for surgical apparel other than surgical gowns and surgical masks. The class I device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to § 878.9.