K Number
K082988
Date Cleared
2009-02-13

(129 days)

Product Code
Regulation Number
876.1500
Reference & Predicate Devices
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

Medivators Advantage Plus Endoscope Reprocessing System tests, washes, disinfects and rinses flexible endoscopes, such as fiberoptic and video endoscopes between patient uses. The Advantage Plus system is indicated to provide high level disinfection of heat sensitive semi-critical endoscopes. Manual cleaning of endoscopes is required prior to placement in the Advantage Plus system.

Rapicide PA High Level Disinfectant is intended for use with the Advantage Plus Endoscope Reprocessing System to provide high level disinfection of endoscopes when used according to the directions for use. Rapicide PA Test Strips are used after the disinfection cycle to ensure that the used disinfectant is above the minimum recommended concentration (850ppm peracetic acid); this ensures that the disinfectant was above MRC during the entire disinfection cycle. Rapicide PA should be used under the following contact conditions:

Claim: High Level Disinfection
Time: 5 minutes
Temperature: 30(°C)
Minimum Recommended Concentration of Peracetic Acid (MRC): 850ppm

Device Description

The Advantage Plus AER is an electro-mechanical system intended to test, wash, and high level disinfect flexible fiberoptic and video endoscopes between uses. It is not intended for reprocessing rigid endoscopes. The Advantage is capable of asynchronously reprocessing two scopes at a time.

The Advantage Plus system uses the peracetic acid based Rapicide PA High Level Disinfectant. The Advantage Plus is a single use system in that it mixes the Part A and Part B of the Rapicide PA with water immediately prior to reprocessing and the disinfectant is not reused.

Endoscopes must be pre-cleaned and manually cleaned to SGNA and facility guidelines prior to placing in the system for reprocessing.

After the scopes are connected to the AER, the system tests the endoscopes for blockages in the channels and leaks in the outer skin, and then proceeds to the washing step. The system also includes an optional channel connectivity test to verify proper connection of the fluid channels for reprocessing. If the endoscopes pass the blockage and leak tests and the washing cycle has been completed, the system proceeds to rinse the instruments and begins the disinfection cycle.

For the disinfection cycle, the incoming water is mixed with the two part germicide in the basin. The temperature of the incoming water is monitored to ensure that water temperature is within the operating constraints (30℃) required for disinfection after the water and germicide are mixed together. Following the 5 minute disinfectant contact time, the user takes a sample to test for MRC and then the disinfectant is emptied from the basin into the drain from the machine. Following disinfection, the endoscopes are rinsed and dried by the machine, either by filtered air or an optional alcohol rinse, and are then removed from the machine for the next use.

The machine has many built in safety features which stop the cycle and alarm when certain conditions exist which could indicate that disinfection might be compromised. These alarms and causes are defined in the directions for use for the product.

The machine also prints records by endoscope serial number indicating the results of testing, disinfection, number of disinfections, etc. which are required for permanent records.

Rapicide PA High Level Disinfectant is a peracetic acid based, two part disinfectant. Part A contains the active ingredients and Part B contains anticorrosive agents and surfactants. Part A and Part B are mixed in the machine and diluted with water. The Minimum Recommended Concentration (MRC) of Rapicide PA is 850 ppm of peracetic acid. A test strip is used to ensure that the use solution is above the MRC.

AI/ML Overview

The provided document describes a 510(k) premarket notification for the Medivators Advantage Plus Endoscope Reprocessing System and Rapicide PA High Level Disinfectant. It focuses on demonstrating the device's substantial equivalence to existing devices and its safety and effectiveness.

Here's an analysis of the acceptance criteria and study information, based on the provided text:

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

Acceptance Criteria CategorySpecific CriterionReported Device Performance
High-Level Disinfection (HLD) Efficacy (for Rapicide PA)
SporicidalTotal kill of Clostridium sporogenes and Bacillus subtilis sporesTotal Kill
Confirmatory SporicidalTotal kill of Clostridium sporogenes and Bacillus subtilis sporesTotal Kill
TuberculocidalTotal kill of Mycobacterium bovis (BCG)Total Kill
Virucidal (Polio)Complete inactivation of Polio virus type 2Complete Inactivation
Virucidal (Herpes)Complete inactivation of Herpes simplex virus type 1Complete Inactivation
Virucidal (HIV)Complete inactivation of Human Immunodeficiency Virus type 1Complete Inactivation
FungicidalTotal kill of Trichophyton mentagrophytesTotal Kill
Use-DilutionTotal kill of Pseudomonas aeruginosa, Staphylococcus aureus, Salmonella choleraesuisTotal Kill
Simulated-Use>6 log Reduction of Mycobacterium terrae>6 log Reduction
In-UseTotal kill on Clinically Used Scopes (microorganisms)Total Kill
Disinfectant Parameters (for Rapicide PA)
Contact Time5 minutesUsed as prescribed in conditions for HLD
Temperature30°CUsed as prescribed in conditions for HLD; machine maintained required temperature
Minimum Recommended Concentration (MRC)850ppm peracetic acidUsed as prescribed in conditions for HLD; test strips ensure MRC is above 850ppm
Material CompatibilityNo significant deterioration of endoscopes and AER materials over timeShowed no significant deterioration
BiocompatibilityDisinfectant residue left on endoscopes within determined safe levelsAny remaining residues would not have an effect on patients or users
Machine Performance (Advantage Plus AER)
Leak CheckPerforms correctlyPerformed correctly
Blockage CheckPerforms correctlyPerformed correctly
Connectivity ChecksPerforms correctlyPerformed correctly
Washing CyclePerforms correctlyPerformed correctly
Disinfection CyclePerforms correctlyPerformed correctly
Rinse CyclesPerforms correctlyPerformed correctly
Drying CyclesPerforms correctlyPerformed correctly
Error MessagesFunction properly to notify users of failure modesFunctioned properly
Critical ParametersFunction correctlyFunctioned correctly
Self-Disinfection CycleDisinfects all areas of the machine, including water filtration systemWorks properly, disinfecting all areas
Water Filtration SystemFunctions appropriately over time; alarms if filters pluggedFunctions appropriately; alarms when plugged
Water Filters (when plugged)Remain bacterial retentiveRemained bacterial retentive

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

The document does not explicitly state the sample sizes for most of the efficacy tests (e.g., number of replicates for sporicidal, virucidal, etc., or number of endoscopes/tests for simulated-use and in-use).

  • In-Use Study: "Clinically Used Scopes" were used. The number is not specified.
  • Country of Origin: Not specified, but the manufacturer is "Medivators Reprocessing Systems, a Division of Minntech Corporation" with an address in Minneapolis, MN, USA. This suggests the testing was likely conducted in the USA or under US regulations.
  • Retrospective or Prospective: The nature of the efficacy and performance testing implies prospective studies designed to meet regulatory requirements, as they are "provided to the FDA to show" these aspects.

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 information is not provided in the document. The efficacy tests are primarily microbiological and engineering in nature, relying on laboratory methods and established quantitative measures (e.g., cell/spore counts, log reduction, temperature, concentration). "Experts" in this context would likely be microbiologists, chemists, and engineers, but their number and specific qualifications are not detailed.

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

This concept of "adjudication method" (typically used for expert consensus on image interpretation) is not applicable to the type of testing described (microbiological efficacy, material compatibility, machine performance). The results are based on objective measurements and established laboratory protocols.

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. An MRMC study is relevant for diagnostic imaging interpretation with AI assistance. The Medivators device is an endoscope reprocessor and high-level disinfectant, not an AI-powered diagnostic tool for human readers.

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

This is not applicable in the context of an AI algorithm. However, if interpreted as "device function without human intervention during the critical phases," the document describes the Advantage Plus AER as an automated system that performs cycles (washing, disinfection, rinsing, drying) with built-in safety features and alarms. The disinfection cycle itself is automated after manual pre-cleaning and loading. A human user takes a sample for MRC testing after the disinfection cycle, indicating a human "check" but not necessarily "in-the-loop" performance during the automated disinfection process itself. The efficacy tests for Rapicide PA are a standalone assessment of the disinfectant's capability.

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

The ground truth for most of the efficacy claims is established by:

  • Microbiological assays: Quantitative laboratory methods to determine the reduction or "kill" of specific microorganisms (bacteria, spores, viruses, fungi) under controlled conditions. This involves standard protocols for culture, inoculation, exposure, and enumeration.
  • Chemical analysis: To confirm concentration (e.g., ppm peracetic acid).
  • Physical measurements: Temperature, time.
  • Engineering validation: Testing of machine functions (leak check, blockage check, washing, rinsing, drying, error messages) against design specifications and operational requirements.

8. The sample size for the training set:

This is not applicable. This device is not an AI/machine learning model that requires a training set. The term "training set" is relevant for AI systems, not for a physical reprocessing system and disinfectant.

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

This is not applicable as there is no "training set" for this device.

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Medivators Advantage Plus Endoscope Reprocessing System and Rapicide PA High Level Disinfectant

FEB 1 3 2009

510(k) Summary of Safety and Effectiveness

Manufacturer:Medivators Reprocessing Systems, a Division of MinntechCorporation
Address:14605 28th Avenue NorthMpls., MN 55447USA

Lynn Lueders Official Contact: Director, Regulatory Affairs

Medivators has supplied the following information to the U.S. Food and Drug Administration to support substantial equivalence of the Advantage Plus Endoscope Reprocessing System and Rapicide PA High Level Disinfectant to other endoscope reprocessors and high level disinfectants currently marketed in the U.S.

1. Device Description

The Advantage Plus AER is an electro-mechanical system intended to test, wash, and high level disinfect flexible fiberoptic and video endoscopes between uses. It is not intended for reprocessing rigid endoscopes. The Advantage is capable of asynchronously reprocessing two scopes at a time.

The Advantage Plus system uses the peracetic acid based Rapicide PA High Level Disinfectant. The Advantage Plus is a single use system in that it mixes the Part A and Part B of the Rapicide PA with water immediately prior to reprocessing and the disinfectant is not reused.

Endoscopes must be pre-cleaned and manually cleaned to SGNA and facility guidelines prior to placing in the system for reprocessing.

After the scopes are connected to the AER, the system tests the endoscopes for blockages in the channels and leaks in the outer skin, and then proceeds to the washing step. The system also includes an optional channel connectivity test to verify proper connection of the fluid channels for reprocessing. If the endoscopes pass the blockage and leak tests and

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Page 2

the washing cycle has been completed, the system proceeds to rinse the instruments and begins the disinfection cycle.

For the disinfection cycle, the incoming water is mixed with the two part germicide in the basin. The temperature of the incoming water is monitored to ensure that water temperature is within the operating constraints (30℃) required for disinfection after the water and germicide are mixed together. Following the 5 minute disinfectant contact time, the user takes a sample to test for MRC and then the disinfectant is emptied from the basin into the drain from the machine. Following disinfection, the endoscopes are rinsed and dried by the machine, either by filtered air or an optional alcohol rinse, and are then removed from the machine for the next use.

The machine has many built in safety features which stop the cycle and alarm when certain conditions exist which could indicate that disinfection might be compromised. These alarms and causes are defined in the directions for use for the product.

The machine also prints records by endoscope serial number indicating the results of testing, disinfection, number of disinfections, etc. which are required for permanent records.

Rapicide PA High Level Disinfectant is a peracetic acid based, two part disinfectant. Part A contains the active ingredients and Part B contains anticorrosive agents and surfactants. Part A and Part B are mixed in the machine and diluted with water. The Minimum Recommended Concentration (MRC) of Rapicide PA is 850 ppm of peracetic acid. A test strip is used to ensure that the use solution is above the MRC.

Intended Use 2.

Medivators Advantage Plus Endoscope Reprocessing System tests, washes, disinfects and rinses flexible endoscopes, such as fiberoptic and video endoscopes between patient uses. The Advantage Plus system is indicated to provide high level disinfection of heat sensitive semi-critical endoscopes.

Rapicide PA High Level Disinfectant is intended for use with the Advantage Plus Endoscope Reprocessing System to provide high level disinfection of endoscopes when used according to the directions for use.

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Rapicide PA Test Strips are used after the disinfection cycle to ensure that the used disinfectant is above the minimum recommended concentration (850ppm peracetic acid); this ensures that the disinfectant was above MRC during the entire disinfection cycle.

Rapicide PA should be used under the following contact conditions:

ClaimTimeTemperatureMinimum RecommendedConcentration ofPeracetic Acid(MRC)
High LevelDisinfection5 minutes30(°C)850ppm

3. Comparison to Another Device in Commercial Distribution Within the United States

The Advantage Plus is equivalent in function and indications to the Medivators MDS Endoscope Reprocessing System (K063876) and the Advanced Sterilization Products' EvoTech™ Integrated Endoscope Disinfection System (K061899). All of the machines have the same indications for use and the same methods of providing disinfection.

Rapicide PA High Level Disinfectant is equivalent in indications and usage to Acecide High Level Disinfectant and Sterilant (K041984) and Peract 20 Liquid Sterilant (K960513). All of the products are peracetic acid based germicides labeled for providing high level disinfection to flexible endoscopes.

Summary of Testing 4.

Medivators has provided testing to show that the Advantage Endoscope Reprocessing system and Rapicide PA are safe and effective for their intended use following the requirements listed in the FDA's Guidance on Premarket Notification [510(k)] Submissions for Automated Endoscope Washers, Washer/Disinfectors, and Disinfectors Intended for Use in Health Care Facilities (dated August 1993) and the Content and Format of Premarket Notification [510(k)] Submissions for Liquid Chemical Sterilants/High Level Disinfectants (January 3, 2000).

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Page 4

The efficacy testing for Rapicide PA is summarized in the table below:

TestsOrganismsResults
SporicidalClostridium sporogenes andBacillus subtilis sporesTotal Kill
ConfirmatorySporicidalClostridium sporogenes andBacillus subtilis sporesTotal Kill
TuberculocidalMycobacterium bovis (BCG)Total Kill
VirucidalPolio virus type 2Complete Inactivation
VirucidalHerpes simplex virus type 1Complete Inactivation
VirucidalHuman Immunodeficiency Virustype 1Complete Inactivation
FungicidalTrichophyton mentagrophytesTotal Kill
Use-DilutionPseudomonas aeruginosaStaphylococcus aureus SalmonellacholeraesuisTotal Kill
Simulated-UseMycobacterium terrae>6 log Reduction
In-UseClinically Used ScopesTotal Kill

Efficacy Testing Summary Table

Material Compatibility

The effect of disinfectant on the materials used in endoscopes and in the AER system was evaluated and showed that the endoscopes and AER materials showed no significant deterioration over time. Studies were also presented to show that the filters used in the water filtration system were compatible with Rapicide PA.

Biocompatibility

The amount of disinfectant residue left on endoscopes after the disinfection and rinsing cycles was evaluated and compared to determined safe levels. The results of the testing showed that any remaining residues would not have an effect on patients or users.

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Page 5

Performance Data

Data was provided to the FDA to show that the machine performs as required. This evaluation included testing to show that the leak check, blockage check, connectivity checks, washing cycle, disinfection cycle, rinse cvcles, and drying cycles performed correctly. Any error messages were tested to ensure they function properly to notify users of any possible failure modes. Testing was performed to show that all critical parameters of the machine function correctly.

Testing was provided that showed that the disinfectant remained at its required temperature for the length of time required for high level disinfection.

Testing was completed that showed that the Advantage Plus self disinfection cycle works properly by disinfecting all areas of the machine, including the water filtration system.

Studies were performed to show that the water filtration system will function appropriately over time and that the machine will alarm if water filters are plugged to a point which will lower the water pressure below required input. This study also showed that the filters remained bacterial retentive even when plugged to a point that causes the machine to alarm.

Summary of Substantial Equivalence 5.

Medivators has provided the above information in the form of a 510(k) to support the claim that the Advantage Plus Endoscope Reprocessing System and Rapicide PA are safe and effective when used in accordance with the device labeling.

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Image /page/5/Picture/0 description: The image shows the logo for the Department of Health & Human Services, USA. The logo consists of a stylized eagle with its wings spread, and the text "DEPARTMENT OF HEALTH & HUMAN SERVICES . USA" arranged in a circular pattern around the eagle. The eagle is depicted in black, and the text is also in black against a white background. The logo is simple and recognizable, representing the department's role in providing health and human services to the United States.

DEPARTMENT OF HEALTH & HUMAN SERVICES

Public Health Service

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

FEB 1 3 2009

Medivators Reprocessing Systems C/o Ms. Lynn Lueders Director, Regulatory Affairs Minntech Corporation 14605 28th Avenue North Minneapolis, Minnesota 55447-4822

Re: K082988

Trade/Device Name: Medivators Advantage Plus Endoscope Reprocessing System and Rapicide PA High Level Disinfectant Regulation Number: 21 CFR 876.1500 Regulation Name: Endoscope and Accessories Regulatory Class: II Product Code: FEB

Dated: January 28, 2009

Received: January 29, 2009

Dear Ms. Lueders:

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 Ford, 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 - Ms. Lueders

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), please contact the Center for Devices and Radiological Health's (CDRH's) Òffice of Compliance at (240) 276-0115. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding postmarket surveillance, please contact CDRH's Office of Surveillance and Biometric's (OSB's) Division of Postmarket Surveillance at 240-276-3474. For questions regarding the reporting of device adverse events (Medical Device Reporting (MDR)), please contact the Division of Surveillance Systems at 240-276-3464. 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 (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely vours.

Anthony D. Matosian

Ginette Y. Michaud, M.D. Acting Director 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):

Device Name:

Medivators Advantage Plus Endoscope Reprocessing System and Rapicide PA High Level Disinfectant

Indications for Use:

Medivators Advantage Plus Endoscope Reprocessing System tests, washes, disinfects and rinses flexible endoscopes, such as fiberoptic and video endoscopes between patient uses. The Advantage Plus system is indicated to provide high level disinfection of heat sensitive semi-critical endoscopes. Manual cleaning of endoscopes is required prior to placement in the Advantage Plus system.

Rapicide PA High Level Disinfectant is intended for use with the Advantage Plus Endoscope Reprocessing System to provide high level disinfection of endoscopes when used according to the directions for use. Rapicide PA Test Strips are used after the disinfection cycle to ensure that the used disinfectant is above the minimum recommended concentration (850ppm peracetic acid); this ensures that the disinfectant was above MRC during the entire disinfection cycle. Rapicide PA should be used under the following contact conditions:

ClaimTimeTemperatureMinimumRecommendedConcentration ofPeracetic Acid(MRC)
High LevelDisinfection5 minutes30(℃)850ppm

Over-the Counter Use X AND/OR Prescription Use (21-EFR-801 Subpart-C) >(Part 21 CFR 801 Subpart D)

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

K082988

Concurrence of CDRH, Office of Device Evaluation (ODE)

GCT fa SSM

(Division Sign-Off) (Division of Anasthesiology, General Hospital infection Schrol, Dental Devices

510(k) Number:

§ 876.1500 Endoscope and accessories.

(a)
Identification. An endoscope and accessories is a device used to provide access, illumination, and allow observation or manipulation of body cavities, hollow organs, and canals. The device consists of various rigid or flexible instruments that are inserted into body spaces and may include an optical system for conveying an image to the user's eye and their accessories may assist in gaining access or increase the versatility and augment the capabilities of the devices. Examples of devices that are within this generic type of device include cleaning accessories for endoscopes, photographic accessories for endoscopes, nonpowered anoscopes, binolcular attachments for endoscopes, pocket battery boxes, flexible or rigid choledochoscopes, colonoscopes, diagnostic cystoscopes, cystourethroscopes, enteroscopes, esophagogastroduodenoscopes, rigid esophagoscopes, fiberoptic illuminators for endoscopes, incandescent endoscope lamps, biliary pancreatoscopes, proctoscopes, resectoscopes, nephroscopes, sigmoidoscopes, ureteroscopes, urethroscopes, endomagnetic retrievers, cytology brushes for endoscopes, and lubricating jelly for transurethral surgical instruments. This section does not apply to endoscopes that have specialized uses in other medical specialty areas and that are covered by classification regulations in other parts of the device classification regulations.(b)
Classification —(1)Class II (special controls). The device, when it is an endoscope disinfectant basin, which consists solely of a container that holds disinfectant and endoscopes and accessories; an endoscopic magnetic retriever intended for single use; sterile scissors for cystoscope intended for single use; a disposable, non-powered endoscopic grasping/cutting instrument intended for single use; a diagnostic incandescent light source; a fiberoptic photographic light source; a routine fiberoptic light source; an endoscopic sponge carrier; a xenon arc endoscope light source; an endoscope transformer; an LED light source; or a gastroenterology-urology endoscopic guidewire, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.(2) Class I for the photographic accessories for endoscope, miscellaneous bulb adapter for endoscope, binocular attachment for endoscope, eyepiece attachment for prescription lens, teaching attachment, inflation bulb, measuring device for panendoscope, photographic equipment for physiologic function monitor, special lens instrument for endoscope, smoke removal tube, rechargeable battery box, pocket battery box, bite block for endoscope, and cleaning brush for endoscope. The devices subject to this paragraph (b)(2) are exempt from the premarket notification procedures in subpart E of part 807of this chapter, subject to the limitations in § 876.9.