(111 days)
Intended for use in hospitals and healthcare facilities to contain other medical devices that are to be sterilized and to allow sterilization of the enclosed medical devices using steam sterilizers. Sterilized devices may be stored and transferred in the container.
The devices included in this submission are to be used with a pre-vacuum cycle of 4 minutes at 270 degrees F with a dry time of 20 minutes.
The devices (natural aluminum color containers and lids) subject to this submission are as follows:
Full Size 1/1 Y110.20 Full Size 1/1 Y110.15 Full Size 1/1 Y110.13 Full Size 1/1 Y110.10 3/4 Size Y210.10 34 Size Y210.15 3/4 Size Y210.13 1/2 Size Y310.20 1/2 Size Y310.15 1/2 Size Y310.13 1/2 Size Y310.10
The maximum load weight is 24.75 lbs for full size, 12.5 lbs for 34 size, and 9.25 Ibs for 1/2 size. The sterilization validation included three types of loads, empty, full load of textiles, and full load of surgical instruments.
The subject trays are not validated for use with lumened devices, air driven instruments, power systems, or cannulized instruments.
The devices included in this submission are to be used with a pre-vacuum cycle of 4 minutes at 270 degrees F with a dry time of 20 minutes. Stacking during sterilization is not recommended.
The devices subject to this submission are as follows:
Full Size 1/1 Y110.20 (580 x 280 x 200mm) Full Size 1/1 Y110.15 (580 x 280 x 150mm) Full Size 1/1 Y110.13 (580 x 280 x 135mm) Full Size 1/1 Y110.10 (580 x 280 x 100mm) 3/4 Size Y210.15 (465 x 280 x 150mm) 3/4 Size Y210.13 (465 x 280 x 135mm) 3/4 Size Y210.10 (465 x 280 x 100mm) 1/2 Size Y310.20 (285 x 280 x 200mm) 1/2 Size Y310.15 (285 x 280 x 150mm) 1/2 Size Y310.13 (285 x 280 x 135mm) 1/2 Size Y310.10 (285 x 280 x 100mm)
The maximum load weight is 24.75 lbs for full size, 12.5 lbs for ¾ size, and 9.25 lbs for 1/2 size.
The devices are composed of anodized aluminum (this does not include colored anodized lids).
Here's a breakdown of the acceptance criteria and study information for the Bahadir USA STERILIZATION TRAYS, based on the provided 510(k) summary:
1. Table of Acceptance Criteria and Reported Device Performance
The provided document details non-clinical tests performed rather than specific quantitative acceptance criteria or their corresponding performance results in a structured format. However, based on the types of tests performed and the ultimate goal of substantial equivalence for sterilization trays, we can infer the implied acceptance criteria.
| Acceptance Criteria (Implied) | Reported Device Performance |
|---|---|
| Sterilization Effectiveness: - Pass steam sterilization (pre-vacuum cycle: 4 min at 270°F, 20 min dry time). - Effective sterilization of various loads (empty, full textile, full surgical instruments). - Prevention of microbial migration during storage. | The devices were subjected to "sterility testing" and "half cycle" tests. Validation included three types of loads: empty, full load of textiles, and full load of surgical instruments. The trays "Permits entry of sterilization agent and prevents microbial migration during storage." |
| Cleaning Effectiveness: - Device can be effectively cleaned. | The devices were subjected to "cleaning validation." |
| Material Durability/Aging: - Device maintains integrity and function over time/usage. | The devices were subjected to "aging studies." |
| Product Performance/Integrity: - Device physically holds contents. - Maintains seal integrity. - Withstands sterilization cycle conditions. | The devices were subjected to "performance testing." Features like "Sealed: Yes" and "Gasket: Silicone Based" indicate an expectation of seal integrity. |
| Biocompatibility/Safety (Implied): - Materials are safe for medical device contact. | The main material is anodized aluminum (with stainless steel handles, silicone seal, paper filter). Substantial equivalence to predicate devices (also aluminum alloy with similar components) implies material safety. |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: Not explicitly stated. The document mentions "The devices were subjected to cleaning validation, aging studies, half cycle, sterility testing and performance testing." It refers to "the devices included in this submission" as a set of specific models (11 different sizes). It does not specify how many units of each model, or total units, were tested for each type of study.
- Data Provenance: Not explicitly stated. It's unclear if the testing was done by the manufacturer, an independent lab, or in a specific country. Given the manufacturer's address in New York, USA, it is likely the testing was conducted in the USA or supervised from there. The study appears to be prospective in nature, as it describes tests performed on the physical devices to support the 510(k) submission.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
Not applicable. This device is a physical sterilization tray, and the "ground truth" for its performance is established through objective physical, biological, and chemical tests (e.g., sterility indicators, microbial challenge tests, physical integrity checks, material degradation analysis). There were no human experts establishing a "ground truth" through interpretation or consensus, unlike in studies involving diagnostic imaging or clinical outcomes.
4. Adjudication Method for the Test Set
Not applicable. As noted above, the "ground truth" for this type of device is based on objective scientific testing, not expert consensus or adjudication. Test results would be interpreted against predefined pass/fail criteria.
5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study Was Done
No, a Multi Reader Multi Case (MRMC) comparative effectiveness study was not done. This type of study is typically used for diagnostic or screening devices where human readers (e.g., radiologists) interpret cases, and the AI's impact on their performance is evaluated. Sterilization trays do not involve human interpretation in this manner.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
Yes, in essence, the studies performed (cleaning validation, aging studies, half cycle, sterility testing, performance testing) represent a "standalone" evaluation of the device's physical and functional properties, without human interaction as an integral part of its direct performance (beyond setup and monitoring). The device itself, independent of human interpretive input during use, was tested for its intended function.
7. The Type of Ground Truth Used
The ground truth used for these studies would be based on:
- Biological Indicators/Chemical Indicators: For sterility testing, the absence of viable microorganisms after sterilization, often confirmed by biological indicator sterility (e.g., spore strips showing no growth) and chemical indicator changes.
- Physical Measurements/Observation: For cleaning validation (absence of residual soil), aging studies (material integrity, absence of cracks/corrosion), and performance testing (device remaining intact, seals functional, filters allowing air passage while trapping microbes).
- Adherence to Standards: Compliance with relevant industry standards (e.g., AAMI ST77, as mentioned).
8. The Sample Size for the Training Set
Not applicable. This is a physical medical device, not an AI/machine learning algorithm. Therefore, there is no "training set" in the computational sense.
9. How the Ground Truth for the Training Set Was Established
Not applicable. As there is no AI algorithm or training set, this question is not relevant.
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510(k) Summary (as required by 21 CFR 807.92(c))
Manufacturer Name and Address
Bahadir USA Corp. 275 West Hoffman Avenue Lindenhurst, NY 11757 Contact: Ismail Kilic Tel: 631-608-8522
NOV 1 8 2010
FIDENTIAL DOCUMENT
__. ___ ____ _________________________________________________________________________________________________________________________________________________________________
Submitter / Contact Person / Regulatory Correspondent
Ismail Kilic Bahadir USA Corp. 275 West Hoffman Avenue Lindenhurst, NY 11757
Tel: 631-608-8522 Email: info@bahadirusa.com
510(k) Written By: Joseph Azary / Orchid Design
Date Prepared Revised September 23, 2010
Name of Device
BAHADIR STERILIZATION TRAYS
Classification Name
Sterilization Wraps, Trays, Containers Class 2 - KCT
Predicate Device
Miltex Rigid Sterilization Trays - K050570 Sklar – SklarLite Rigid Sterilization Container – K091720
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K102146
CONFIDENTIAL DOCUMENT
p2 of 6
Description of the Device Intended Use
Intended for use in hospitals and healthcare facilities to contain other medical devices that are to be sterilized and to allow sterilization of the enclosed medical devices using steam sterilizers. Sterilized devices may be stored and transferred in the container.
The devices included in this submission are to be used with a pre-vacuum cycle of 4 minutes at 270 degrees F with a dry time of 20 minutes.
The devices (natural aluminum color containers and lids) subject to this submission are as follows:
Full Size 1/1 Y110.20 Full Size 1/1 Y110.15 Full Size 1/1 Y110.13 Full Size 1/1 Y110.10 3/4 Size Y210.10 34 Size Y210.15 3/4 Size Y210.13 1/2 Size Y310.20 1/2 Size Y310.15 1/2 Size Y310.13 1/2 Size Y310.10
The maximum load weight is 24.75 lbs for full size, 12.5 lbs for 34 size, and 9.25 Ibs for 1/2 size. The sterilization validation included three types of loads, empty, full load of textiles, and full load of surgical instruments.
The subject trays are not validated for use with lumened devices, air driven instruments, power systems, or cannulized instruments.
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DESCRIPTION
-The-devices-included-in-this-submission-are-to-be-used-with-a-pre-vacuum-cycle of 4 minutes at 270 degrees F with a dry time of 20 minutes. Stacking during sterilization is not recommended.
The devices subject to this submission are as follows:
Full Size 1/1 Y110.20 (580 x 280 x 200mm) Full Size 1/1 Y110.15 (580 x 280 x 150mm) Full Size 1/1 Y110.13 (580 x 280 x 135mm) Full Size 1/1 Y110.10 (580 x 280 x 100mm) 3/4 Size Y210.15 (465 x 280 x 150mm) 3/4 Size Y210.13 (465 x 280 x 135mm) 3/4 Size Y210.10 (465 x 280 x 100mm) 1/2 Size Y310.20 (285 x 280 x 200mm) 1/2 Size Y310.15 (285 x 280 x 150mm) 1/2 Size Y310.13 (285 x 280 x 135mm) 1/2 Size Y310.10 (285 x 280 x 100mm)
The maximum load weight is 24.75 lbs for full size, 12.5 lbs for ¾ size, and 9.25 lbs for 1/2 size.
The devices are composed of anodized aluminum (this does not include colored anodized lids).
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-Comparison to Predicate -Devices-
The containers are the same design, same materials, same shapes, and sizes.
| Feature | Bahadir | Miltex K072563 | SklarLite K091720 |
|---|---|---|---|
| Intended Use | Intended for use inhospitals andhealthcare facilitiesto contain othermedical devices thatare to be sterilized.Containers allowsterilization of theenclosed medicaldevices, includingsurfaces andlumens, using highvacuum steamsterilizers for 270 Ffor 4 minutes with20 minutes(minimum) dry time. | Intended for use inhospitals andhealthcare facilitiesto contain othermedical devices thatare to be sterilizedand to allowsterilization of theenclosed medicaldevices, includingsurfaces andlumens, usinggravity steamsterilizers. | Intended for use inhospitals andhealthcare facilitiesto contain othermedical devices thatare to be sterilized.Containers allowsterilization of theenclosed medicaldevices, includingsurfaces andlumens, using highvacuum steamsterilizers for 270 Ffor 4 minutes with30 minutes(minimum) dry time. |
| Material | Aluminum Alloy,stainless steelhandles, siliconeseal, paper filter | Aluminum Alloy,stainless steelhandles, siliconeseal, paper filter | Aluminum Alloy,stainless steelhandles, siliconeseal, paper filter |
| Filter | Paper Filter | Paper FilterPTFE Teflon Filter(for Ethylene Oxide)*Miltex had EOcleared in another510k. | Paper Filter |
| Sterilization Method | Steam | Ethylene OxideSteam*Miltex has EOcleared in another510k | Steam |
| Configurations /Dimensions | Includes 1/2 size, 3/4size, and full size | Includes 1/2 size, 3/4size, and full size**Miltex has theirdimension in inches.The below is a | Full size580mm x 280mm x200mm580mm x 280mm x150mm |
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| K102146CONFIDENTIAL DOCUMENT | p5cf6 | ||||
|---|---|---|---|---|---|
| Full size | units. | 135mm | |||
| 580mm x 280mm x200mm | Full size | 580mm x 280mm x100mm | |||
| 580mm x 280mm x150mm | 580mm x 280mm x150mm | 580mm x 280mm x260mm | |||
| 580mm x 280mm x135mm | 580mm x 280mm x135mm | 3/4 Size | |||
| 580mm x 280mm x100mm | 580mm x 280mm x100mm | 465mm x 280mm x150mm | |||
| 3/4 Size | 3/4 Size | 465mm x 280mm x135mm | |||
| 465mm x 280mm x150mm | 465mm x 280mm x150mm | 465mm x 280mm x100mm | |||
| 465mm x 280mm x135mm | 465mm x 280mm x135mm | 1/2 size | |||
| 465mm x 280mm x100mm | 465mm x 280mm x100mm | 285mm x 280mm x200mm | |||
| 1/2 size | 1/2 size | 285mm x 280mm x150mm | |||
| 285mm x 280mm x200mm | 285mm x 280mm x150mm | 285mm x 280mm x135mm | |||
| 285mm x 280mm x150mm | 285mm x 280mm x135mm | 285mm x 280mm x100mm | |||
| 285mm x 280mm x135mm | 285mm x 280mm x100mm | 285mm x 280mm x260mm | |||
| 285mm x 280mm x100mm | |||||
| Perforation | The units included inthis submissioninclude perforatedlids and non-perforated bottoms. | The units included intheir 510k includedperforated lids andperforated bottoms. | The units included intheir 510k includedperforated and non-perforated lids andperforated and non-perforated bottoms. | ||
| Air Permeance | Permits entry ofsterilization agentand preventsmicrobial migrationduring storage. | Permits entry ofsterilization agentand preventsmicrobial migrationduring storage. | Permits entry ofsterilization agentand preventsmicrobial migrationduring storage. | ||
| Intended to be re-used | Yes | Yes | Yes | ||
| Sealed | Yes | Yes | Yes | ||
| Conformance toAAMI ST 77 | Yes | Yes | Yes | ||
| Gasket | Silicone Based (graycolor) | Silicone Based (redcolor) | Silicone Based (graycolor) | ||
| Handles | Wider handles withsilicone holder | Smaller handles (noholder) | Smaller handles (noholder) | ||
| Cycle Parameters | 270 F at 4 minutes | 270 F at 4 minutes | 270 F at 4 minutes |
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K102146 Confidential Document
The differences - are - as - follows :-
- Sterilization Method (Miltex has received FDA to also use Ethylene ● Oxide. Bahadir USA is not pursuing EO at this time).
- Filter (the devices are offered with paper filters, but Miltex also offers . a PTFE Teflon filter for EO)
- The devices use a silicone based gasket around the lid. There is a . difference in color. Bahadir USA and Sklar use gray and Miltex uses red. We believe this difference is more cosmetic than performance related.
- Both devices have stainless steel handles. The handles on the ● Bahadir USA containers are wider and include a silicone holder to prevent the user from getting burned when the handles are hot.
- The Bahadir USA containers in this submissions are with perforated . lids and non-perforated bottoms. The Miltex and Sklar includes perforated lids and bottoms.
- The Sklar and Miltex 510(k)'s included larger range of sizes. .
- Sklar is offered in anodized colored lids, whereas Bahadir and Miltex . in silver (aluminum color).
Non-Clinical Tests Performed
The devices were subjected to cleaning validation, aging studies, half cycle, sterility testing and performance testing.
Summary .
In conclusion we believe the devices are substantially equivalent to the predicate devices and do not introduce new issues of safety or effectiveness.
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Image /page/6/Picture/1 description: The image shows the seal of the Department of Health & Human Services - USA. The seal is circular and contains the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. In the center of the seal is an abstract image of a bird.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
Mr. Ismail Kilic President Bahadir USA Corporation 275 West Hoffman Avenue Lindenhurst, New York 11757
NOV 1:8 . 2010 .
Re: K102146
Trade/Device Name: Bahadir USA Sterilization Trays Regulation Number: 21 CFR 880.6850 Regulation Name: Sterilization Wrap Regulatory Class: II Product Code: KCT . Dated: November 1, 2010 Received: November 8, 2010
Dear Mr. Ismail:
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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
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Page 2- Mr. Kilic
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); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); 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.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to
http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
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) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely yours,
Anthony D. Watson, B.S., M.S., M.B.A. Director
Division of Anesthesiology, General Hospital, Infection Control and Dental Devices
Office of Device Evaluation
Center for Devices and
Radiological Health
{8}------------------------------------------------
510(k) Number (if known):
Device Name: Bahadir USA Sterilization Trays
NOV 1 8 2010
Indications For Use:
Intended for use in hospitals and healthies to contain other medical devices that are to be sterlized and to allow sterliization of the enclosed medical devices using steam sterilized devices may be stored and transferred in the container.
The devices included in this submission are to be used with a pre-vacuum cycle of 4 minutes at 270 degrees F with a dry time of 20 minutes.
The devices (natural aluminum color containers and lids) subject to this submission are as follows:
Full Size 1/1 Y 10.20 Full Size 1/1 Y 110.15 Full Size 1/1 Y 110.13 Full Size 1/1 Y 110.10 % Size Y210.10 ¾ Size Y210.15 ¾ Size Y2I0.13 ½ Size Y310.20 % Size Y310.15 1/2 Size Y310.13 ½ Size Y310.10
The maximum load weight is 24.75 lbs for % size, and 9.25 lbs for ½ size. The sterlization validation included three types of loads, empty, full load of textiles, and full load of surgical instruments.
The subject trays are not validated for use with luments, power systems, or cannulized instruments.
Prescription Use (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use (21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Surr Puorer
(Division Sign-Off) (Division Sign-On)
Division of Anesthesiology, General Hospital Division Control, Dental Devices
Page 1 of 1
510(k) Number: K102146
§ 880.6850 Sterilization wrap.
(a)
Identification. A sterilization wrap (pack, sterilization wrapper, bag, or accessories, is a device intended to be used to enclose another medical device that is to be sterilized by a health care provider. It is intended to allow sterilization of the enclosed medical device and also to maintain sterility of the enclosed device until used.(b)
Classification. Class II (performance standards).