K Number
K120846
Date Cleared
2012-06-08

(80 days)

Product Code
Regulation Number
866.2900
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

Puritan Liquid Amies Collection and Transport System is intended for use in the collection and transport of clinical specimens containing aerobic and fastidious bacteria from the patient to the laboratory for bacteriological examination and culture.

Device Description

Puritan Liquid Amies Collection and Transport System is comprised of a sterile peel pouch containing a polyester flock swab applicator for collecting specimen and a polypropylene vial containing 1 ml of modified Amies liquid transport medium. The polyester flock swab applicators are provided in two different tip sizes to accommodate various specimen types. Amies liquid medium is a nonnutritive balanced salt solution containing inorganic phosphates to provide buffering capability, sodium chloride, potassium chloride, calcium chloride and magnesium chloride to provide essential ions that help maintain osmotic balance. Sodium thioglycollate provides a reduced environment. It is recommended for maintaining the viability of aerobic, anaerobic and fastidious bacteria during the transport to the laboratory.

AI/ML Overview

The Puritan Liquid Amies Collection and Transport System is intended for the collection and transport of clinical specimens containing aerobic, anaerobic, and fastidious bacteria. The pivotal study demonstrating its performance is the "Recovery Testing" described in section 5.8 of the 510(k) summary. This study compared the Puritan system to a predicate device (BD (Copan) Liquid Amies Collection and Transport System, K061301) to demonstrate substantial equivalence.

Here's a breakdown of the requested information:

1. Table of Acceptance Criteria and Reported Device Performance:

Feature/TestAcceptance CriteriaReported Device Performance
Bacterial Recovery (Viability)Recovery of bacteria within acceptance criteria as defined by CLSI M40-A guidelines (details of specific criteria not provided, but generally involves maintaining viability within a certain log range compared to initial inoculum)The Puritan Liquid Amies system showed recovery of bacteria within the acceptance criteria, comparable to the predicate device.
pH StabilitypH within the specified range (7.3 ± 0.2)All samples tested were found to maintain pH within the specified range after 18 months.
CytotoxicityNo evidence of cytotoxicityNo evidence of cytotoxicity was detected using the ISO Elution Method-1X MEM Extract for glue, shaft, and polyester (flock) swabs.
SterilizationValidation following ANSI/AAMI/ISO 11137:2006 guidelinesPuritan Liquid Amies Transport Systems are sterilized by gamma irradiation and validated following ANSI/AAMI/ISO 11137:2006.
Shelf LifeMaintain microbial recovery up to the expiry date (18 months)Stability tests verified the ability of the aged products to maintain microbial recovery up to the expiry date.

2. Sample size used for the test set and the data provenance:

  • Sample Size: The document mentions "known inocula of ATCC type culture and clinically significant microorganisms" were inoculated. It also states "random samples from three different lots of Puritan Liquid Amies Collection and Transport System" were used for pH stability. However, the exact number of microorganisms tested, replicates per microorganism, or total sample size for the core bacterial recovery study is not explicitly stated in the provided text.
  • Data Provenance: The origin of the data is from laboratory testing (in vitro) comparing the Puritan device to a predicate device. It is not patient or country-specific data, but rather controlled experimental data. The study is prospective in the sense that the experiments were conducted specifically to evaluate the device.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

This information is not applicable and not provided for this type of device (microbiological transport system). The ground truth for bacterial viability is established through quantitative laboratory methods (e.g., colony counting) and comparison to established standards (CLSI M40-A), not by expert consensus or interpretation of images/clinical data.

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

This information is not applicable and not provided. Adjudication methods are typically used in studies involving human interpretation (e.g., radiology for diagnostic devices) where multiple readers disagree. For this in vitro microbiological test, the results are quantitative and objective, eliminating the need for adjudication.

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 information is not applicable. The Puritan Liquid Amies Collection and Transport System is a medical device for specimen collection and transport, not an AI-powered diagnostic tool involving human readers. Therefore, an MRMC study or AI assistance is irrelevant to its evaluation.

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

This information is not applicable. This device is not an algorithm. Its performance is evaluated independently (standalone in a laboratory setting) by assessing its ability to maintain bacterial viability, followed by subsequent testing by laboratory personnel. There is no human-in-the-loop aspect for the function of the transport medium itself.

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

The ground truth used for the bacterial recovery test is based on quantitative microbiological methods, specifically the known initial inoculum of ATCC type cultures and clinically significant microorganisms, and their subsequent viability over time. The Clinical and Laboratory Standards Institute (CLSI) M40-A guidelines likely define the acceptable range of recovery, acting as the reference standard.

8. The sample size for the training set:

There is no training set in the context of this device. This is a laboratory-tested medical device, not a machine learning model.

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

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

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K120846

JUN - 8 2012

510(k) Summary

Puritan Liquid Amies Collection and Transport System

5.1 Sponsor

Puritan Medical Products LLC

31 School St., Guilford, ME 04443

Mehdi Karamchi Contact:

Telephone Number: 207-876-3311

Date: May 24, 2012

5.2 Device Name

- Classification Name: .Transport Culture Medium .
- Common Name: .Microbiological Specimen Collection and Transport System .
Proprietary Name: .Puritan Liquid Amies Swab Collection and Transport System .

Regulatory Information 5.3

A. Regulatory Section:21 CFR 866.2900
B. Classification:Class I
C. Product Code:JTW, JTX
D. Panel:Microbiology

. 5.4 Predicate Device

BD (Copan) Liquid Amies Collection and Transport System

510K Number: K061301

5.5 Device Description

Puritan Liquid Amies Collection and Transport System is comprised of a sterile peel pouch containing a polyester flock swab applicator for collecting specimen and a polypropylene vial

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containing 1 ml of modified Amies liquid transport medium. The polyester flock swab applicators are provided in two different tip sizes to accommodate various specimen types.

Amies liquid medium is a nonnutritive balanced salt solution containing inorganic phosphates to provide buffering capability, sodium chloride, potassium chloride, calcium chloride and magnesium chloride to provide essential ions that help maintain osmotic balance. Sodium thioglycollate provides a reduced environment. It is recommended for maintaining the viability of aerobic, anaerobic and fastidious bacteria during the transport to the laboratory.

5.6 Intended Use

Puritan Liquid Amies Collection and Transport System is intended for use in the collection and transport of clinical specimens containing aerobic and fastidious bacteria from the patient to the laboratory for bacteriological examination and culture.

5.6.1 Indication(s) For Use

Puritan Liquid Amies Collection and Transport System is intended for use in the collection and transport of clinical specimens containing aerobic and fastidious bacteria from the patient to the laboratory for bacteriological examination and culture.

5.7 Substantial Equivalence statement

Puritan Liquid Amies Collection and Transport Systems is similar in design, manufacturing and intended usage to the predicate device. Both Puritan and predicate devices are single-use devices intended for collection and transport of clinical specimens containing aerobes, anaerobes and fastidious bacteria.

2

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Puritan Versus Competitor Similarities
ItemTest DevicePredicate
Intended UseCollection and transport of clinicalspecimens from the patient to thelaboratory for bacterial examinationand cultureSame
Single-use DeviseYesYes
Medium FormulationSodium chlorideDisodium phosphateSodium thioglycollateMonopotassium phosphatePotassium chlorideCalcium chlorideMagnesium ChlorideSame
pH$7.3 \pm 0.2$Same
Storage Temperature2-25°C (refrigerated and roomtemperature)Same
ContainerPlastic; conical bottomSame
Product ConfigurationMedium in tubes & CapSystem including Medium and swab inpeel pouch option.Same

.

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Puritan Versus Competitor Differences
ItemDevicePredicate
Swab TipHydraFlock Swab (Polyester)Nylon Flock swab
Shelf Life18 months15 months

5.8 Recovery Testing

To determine the ability of the Puritan Amies liquid medium to maintain viability of different strains of aerobes, anaerobes and fastidious bacteria, known inocula of ATCC type culture and clinically significant microorganisms were inoculated into the Puritan liquid Amies transport medium and compared to the predicate device following Clinical and Laboratory Standards Institute(CLSI), M40-A guidelines. The Puritan Liquid Amies system showed recovery of bacteria within the acceptance criteria like the predicate device.

5.9 Stability Testing

Stability tests were performed on Puritan Amies liquid products to verify the ability of the aged products to maintain microbial recovery up to the expiry date.

5.10 pH Stability

The pH of the test device was measured at predetermined time intervals up to 18 month after manufacturing date. The test was performed using calibrated pH meter with random samples from three different lots of Puritan Liquid Amies Collection and Transport System. All samples tested were found to maintain pH within the specified range.

5.11 Cytotoxicity

Cytotoxicity test was conducted to evaluate glue, shaft and the polyester (flock) swabs for potential cytotoxicity effect following ISO Elution Method-1X MEM Extract. No evidence of cytotoxicity was detected.

5.12 Sterilization

Puritan Liquid Amies Transport Systems are sterilized by gamma irradiation and validated following ANSI/AAMI/ISO 11137:2006, Sterilization of health care products radiation guidelines.

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DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/4/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo is circular, with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES . USA" arranged around the top half of the circle. Inside the circle is an abstract symbol that resembles an eagle or bird in flight.

Food and Drug Administration 10903 New Hampshire Avenue Silver Spring, MD 20993

Puritan Medical Products LLC. c/o Mehdi Karamchi B. Sc. RM (ccm) Vice President of Scientific Affairs 31 School Street, PO Box 149 Guilford. ME 04443-0149

JUN - 8 2012

Re: K120846

Trade/Device Name: Puritan® Liquid Amies Collection and Transport System Regulation Number: 21 CFR 866.2900 Regulation Name: Microbiological specimen collection and transport device Regulatory Class: Class I Product Code: LIO, JTW, JTX Dated: March 20, 2012 Received: March 20, 2012

Dear Mr. Karamchi:

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 class II (Special Controls), it may be subject to such additional controls. Existing major regulations affecting your device can be found in Title 21. Code of Federal Regulations (CFR), Parts 800 to 895. 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. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Parts 801 and 809); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); and good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820). 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

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Page 2 - Mehdi Karamchi B. Sc. RM

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 Parts 801 and 809), please contact the Office of In Vitro Diagnostic Device Evaluation and Safety at (301) 796-5450. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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/cdrh/industry/support/index.html.

Sincerely yours,

Sally, attgum

Sally A. Hojvat, M.Sc., Ph.D. Director Division of Microbiology Devices Office of In Vitro Diagnostic Device Evaluation and Safety Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number: K120846

Device Name: Puritan® Liquid Amies Collection and Transport System

Indications for Use:

Puritan® Liquid Amies Collection and Transport System is intended for use in the collection and transport of clinical specimens containing aerobic, anaerobic and fastidious bacteria from the patient to the laboratory for bacteriological examination and culture.

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 In Vitro Diagnostic Devices (OIVD)

Laura Feldbolz


Division Sign-Off

Office of In Vitro Diagnostic Device Evaluation and Safety

510(k) K120846

Page 1 of

§ 866.2900 Microbiological specimen collection and transport device.

(a)
Identification. A microbiological specimen collection and transport device is a specimen collecting chamber intended for medical purposes to preserve the viability or integrity of microorganisms in specimens during storage of specimens after their collection and during their transport from the collecting area to the laboratory. The device may be labeled or otherwise represented as sterile. The device aids in the diagnosis of disease caused by pathogenic microorganisms.(b)
Classification. Class I (general controls). The device, when solely intended for use in the collection of concentrated parasites from specimens and transport, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 866.9.