K Number
K132380
Device Name
PREVANTICS DEVICE SWAB
Date Cleared
2014-08-27

(392 days)

Product Code
Regulation Number
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Prevantics® Device swab contains a 3.15% Chlorhexidine Gluconate and 70% (v/v) Isopropyl Alcohol swab is intended for use to disinfect needleless access sites prior to use.
Device Description
The Prevantics® Device swab is available as a 2 in. x 2 in. swab which contains a 1mL solution (3.15% Chlorhexidine Gluconate and 70% (v/v) Isopropyl Alcohol). The product is intended for single, non-sterile use and is not made with natural rubber latex. The subject device is not intended to treat existing infections. The device is not intended to have any effect on contaminated infusion solutions. The subject device is composed of materials that have been successfully and safely used in medical devices including the predicate devises.
More Information

Not Found

No
The device is a disinfectant swab and the summary focuses on its antimicrobial efficacy through standard laboratory tests. There is no mention of AI or ML in the description, intended use, or performance studies.

No.
The device is intended for disinfection of needleless access sites, which is an external application for preventing infection, not for treating existing conditions or restoring health. The description explicitly states "The subject device is not intended to treat existing infections."

No

The device is intended for disinfecting needleless access sites, which is a preventative measure, not a diagnostic one. Diagnostic devices are used to identify a disease or condition.

No

The device is a physical swab containing a chemical solution, not a software program.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use is to "disinfect needleless access sites prior to use." This is a topical application for disinfection, not a test performed on a sample taken from the human body to provide information about a physiological state, health, or disease.
  • Device Description: The description reinforces its use as a disinfectant swab for external application.
  • Performance Studies: The performance studies focus on the antimicrobial efficacy of the solution against various microorganisms, which is relevant to its function as a disinfectant. They do not involve analyzing biological samples for diagnostic purposes.

IVD devices are typically used to examine specimens such as blood, urine, tissue, etc., to detect diseases, conditions, or infections. This device is used to prepare a surface on the body for a medical procedure.

N/A

Intended Use / Indications for Use

Prevantics® Device swab contains a 3.15% Chlorhexidine Gluconate and 70% (v/v) Isopropyl Alcohol swab is intended for use to disinfect needleless access sites prior to use.

Product codes (comma separated list FDA assigned to the subject device)

LKB

Device Description

The Prevantics® Device swab is available as a 2 in. x 2 in. swab which contains a 1mL solution (3.15% Chlorhexidine Gluconate and 70% (v/v) Isopropyl Alcohol). The product is intended for single, non-sterile use and is not made with natural rubber latex. The subject device is not intended to treat existing infections. The device is not intended to have any effect on contaminated infusion solutions. The subject device is composed of materials that have been successfully and safely used in medical devices including the predicate devises.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

It may be used in the home or healthcare facility.

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Testing included the following: a time kill study involving (two gram positive, two gram negative and 2 fungi) evaluated at multiple time points (15 and 30 sec), a minimum effective concentration (MEC) study (tested at 15 and 30 seconds) and a simulated use study.

For the Time-Kill Study and Minimal Effective Concentration (MEC) Study:
Six microorganisms were tested: two (2) Gram positive, two (2) Gram negative and 2 fungi (Staphylococcus aureus (ATCC #6538). Enterococcus faecalis (ATCC #29212). Escherichia coli (ATCC #11229), Pseudomonas aeruginosa (ATCC #15442), Candida albicans (ATCC #10231), and Candida glabrata (ATCC #2001)).
Three (3) lots Prevantics® Device Swab nearing end of shelf life were tested. Sterile Water for Injection was used as a control.
The testing was performed using the same techniques outlined in the Time-Kill Study section.

For the Simulated Use Study:
Microorganisms tested include Candida albicans (ATCC #10231), Candida parapsilosis (ATCC #7330), Escherichia coli (ATCC #25922), Pseudomonas aeruginosa (ATCC #27853), Staphylococcus aureus MRSA (ATCC #33591), Staphylococcus epidermidis MRSE (ATCC #51625), Staphylococcus aureus (ATCC #6538), Staphylococcus epidermidis (ATCC #12228).
The study tested three lots of Prevantics® Device Swab and the predicate device Curos® Port Protector, under both "No Soil" and "Yes Soil" conditions.

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

PDI performed multiple non-clinical tests in support of this 510k submission. Testing included the following: a time kill study involving (two gram positive, two gram negative and 2 fungi) evaluated at multiple time points (15 and 30 sec), a minimum effective concentration (MEC) study (tested at 15 and 30 seconds) and a simulated use study.

Time-Kill Study:
At both 15 and 30 seconds, application of the Prevantics Device Swab solution to the microbial cultures resulted in a >5.00 log10 reduction in CFU/mL for each of the six (6) microorganism listed above.

Minimal Effective Concentration (MEC) Study:
At both 15 and 30 seconds, application of the Prevantics® Device Swab solution to the microbial cultures resulted in a >4.00 log10 reduction in CFU/mL for each of the three (3) microorganism listed above. The results indicate that even when diluted to 50% of the nominal concentration, Prevantics Device Swab contains an effective antimicrobial combination.

Simulated Use Study:
The results demonstrate that Prevantics® Device Swab produces a >4.0 log10 reduction in microbial CFU/mL for seven (7) of eight (8) tested microorganisms, regardless of soil conditions. In comparison, the predicate device (Curos® Port Protector) achieved similar >4.0 log10 reduction on six (6) of eight (8) microorganisms. The Curos® Port Protector failed to achieve a >4.0 log10 reduction for Candida parapsilosis (ATCC #7330) and Staphylococcus epidermidis MRSE (ATCC 51625). The results of the simulated use testing indicate that Prevantics® Device Swab provides substantially equivalent results to the predicate device (Curos® Port Protector).

Summary of Non-Clinical Tests:
A variety of non-clinical tests were conducted to show the safety and effectiveness of the subject device including comparisons against the predicate devices. Standardized test methods from ISO-10993 were used in this testing and the methods and results are described in the submission.

Summary of Clinical Tests:
No new clinical tests were required to support the change. The review of the indications for use, the technical characteristics and the results provided from the non-clinical tests performed to satisfy International Standard ISO-10993, Biological Evaluation of Medical Devices Part 1: Evaluation and Testing (Cytotoxicity, Closed Patch Test, Dermal Irritation, Systemic Toxicity) demonstrate that Prevantics® Device Swabs are substantially equivalent to the predicate devices.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found. The studies report Mean Log10 Reduction in CFU/mL.

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K080466, K121655

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

N/A

0

Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized image of three human profiles facing to the right, stacked on top of each other. The profiles are rendered in a dark color, contrasting with the white background of the seal.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

August 27, 2014

Professional Disposables International, Inc. Ms. Elizabeth Ernst Senior Director, Regulatory & Medical Affairs Two Nice-Pak Park Orangeburg, NY 10962

Re: K132380

Trade/Device Name: Prevantics® Device Swab Regulation Number: Unclassified Regulation Name: Pad, Alcohol, Device Disinfectant Regulatory Class: Unclassified Product Code: LKB Dated: July 31, 2014 Received: August 1, 2014

Dear Ms. Ernst:

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.

1

Page 2 - Ms. Ernst

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 (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.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm. 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 Industry and Consumer Education 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 vours.

Erin |. Keith -S

Erin I. Keith, M.S. Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K132380

Device Name Prevantics® Device Swab

Indications for Use (Describe)

Prevantics® Device swab contains a 3.15% Chlorhexidine Gluconate and 70% (v/v) Isopropyl Alcohol swab is intended for use to disinfect needleless access sites prior to use.

Type of Use (Select one or both, as applicable)

  • Prescription Use (Part 21 CFR 801 Subpart D)

Over-The-Counter Use (21 CFR 801 Subpart C)

PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON A SEPARATE PAGE IF NEEDED.

FOR FDA USE ONLY

Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)

Saiiad H.

Digitally signed by Sajjad H. Syed -S DN: c=US, o=U.S. Government, ou=HHS, ou=FDA, ou=People, cn=Sajjad H. Syed -S, 0.9.2342.19200300.100.1.1=2000601742 Date: 2014.08.27 09:51:06 -04'00'

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3

Section 5: 510(K) Summary Statement 21(CFR 807.92)

510 K Summary
Manufacturer NameProfessional Disposables International, Inc.
Contact NameElizabeth Ernst
TitleSenior Director, Regulatory & Medical Affairs
Postal Address:100 Phillips Parkway, Montvale, NJ 07645
Fax:845-398-5347
Date:7/29/2014
Device Proprietary
NamesPrevantics® Device swab
Device Common or
Usual NameChlorhexidine Gluconate (3.15%)* and Isopropyl Alcohol (70%) Swab
Classification CodeLKB
Classification PanelGeneral Hospital
Regulation NumberN/A
Predicate DeviceSubstantial equivalence is claimed to the following devices as related to
intended use and design characteristics:
Curos® Port Protector, Ivera Medical Corp. (K080466)
BD Alcohol Swab, BD Medical – Medical Surgical Systems (K121655)
Description of the DeviceThe Prevantics® Device swab is available as a 2 in. x 2 in. swab which
contains a 1mL solution (3.15% Chlorhexidine Gluconate and 70% (v/v)
Isopropyl Alcohol). The product is intended for single, non-sterile use and
is not made with natural rubber latex. The subject device is not intended
to treat existing infections. The device is not intended to have any effect
on contaminated infusion solutions. The subject device is composed of
materials that have been successfully and safely used in medical devices
including the predicate devises.
Intended Use of the
Device:Prevantics® Device swab is intended for needleless access site
disinfection.
Technological
CharacteristicsThe Prevantics® Device Swab has a similar intended use as its predicate
device for disinfecting needleless access sites with the home or healthcare
facility. It is provided non-sterile and is constructed with 3.15%
chlorhexidine gluconate and the same 70% isopropyl alcohol as its
predicate devices. It varies in technological characteristics as compared to
two (2) of the predicate devices as the subject device is a nonwoven pad
saturated with chlorhexidine gluconate (3.15%) and isopropyl alcohol
(70%) and the predicate devices are either an alcohol pad (BD Alcohol
Pad) or contain an alcohol pad-like sponge within a rigid cap design like
Ivera's Curos® Port Protector.

4

Prevantics® Device swab Section 5: 510(K) Summary Statement 21(CFR 807.92) Professional Disposables International, Inc.

510K NumberK121655K080466
Product CodeLKBLKBLKB
Device NamePrevantics® Device SwabBD Alcohol SwabCuros® Port
ManufacturerProfessional Disposable
International IncBD Medical - Medical Surgical
SystemsIvera Medical Corporation
Intended UseWhen used for scrubbing for 5
seconds and drying for 5
seconds, Prevantics® Device
Swab (a single use device) will
disinfect needleless access sites
prior to access.Is a single use, sterile device containing
70% Isopropyl alcohol. When used for
scrubbing for 5 seconds and allowing
drying for 5 seconds, the device will
disinfect needleless access sites prior to
use.Is a device containing 70%
alcohol, intended for use on
swabbable luer access valves as a
disinfecting cleaner prior to line
access and to act as a physical
barrier to contamination between
line accesses. The device will
disinfect the valve three (3)
minutes after application and act
as a physical barrier to
contamination for up to seven (7)
days (168 hours) if not removed.
Additional
ClaimsNot made with natural rubber
latex
Antimicrobial
AgentChlorhexidine Gluconate
(3.15%) and Isopropyl Alcohol
(70%)70% Isopropyl Alcohol70% Isopropyl Alcohol
User
PopulationIt may be used in the home or
healthcare facility.It may be used in the home or
healthcare facility.The Curos® Disinfecting Port
Protector may be used in the home
or healthcare facility.
SterilizationNon-sterileTerminally Sterile (Unknown Method)Gamma Irradiated
PackagingIndividually wrappedIndividually wrappedIndividually wrapped

5

PDI performed multiple non-clinical tests in support of this 510k submission. Testing included the following: a time kill study involving (two gram positive, two gram negative and 2 fungi) evaluated at multiple time points (15 and 30 sec), a minimum effective concentration (MEC) study (tested at 15 and 30 seconds) and a simulated use study.

Time-Kill Study

A time-kill study was performed (based on ASTM E2315 - 03(2008) Standard Guide for Assessment of Microbial Activity Using a Time-Kill Procedure) to determine how rapidly and effectively Prevantics® Device Swab kills a variety of microorganisms. Three (3) lots Prevantics® Device Swab nearing end of shelf life were tested. (Three lots of the devices were labeled as Chlorascrub. This was the device name prior to rebranding. The devices will be referred to as Prevantics® Device Swabs throughout this document.) Sterile Water for Injection was used as a control.

Six microorganisms were tested: two (2) Gram positive, two (2) Gram negative and 2 fungi (Staphylococcus aureus (ATCC #6538). Enterococcus faecalis (ATCC #29212). Escherichia coli (ATCC #11229), Pseudomonas aeruginosa (ATCC #15442), Candida albicans (ATCC #10231), and Candida glabrata (ATCC #2001). At both 15 and 30 seconds, application of the Prevantics Device Swab solution to the microbial cultures resulted in a >5.00 log10 reduction in CFU/mL for each of the six (6) microorganism listed above.

Mean Log10 Reduction
MicroorganismTest Substance15 sec30 sec
Escherichia coli
(ATCC #11229)Chlorascrub Swab
Lot No. 112001596.076.07
Chlorascrub Swab
Lot No. 112002476.076.07
Chlorascrub Swab
Lot No. 112002516.076.07
Sterile Water
Lot No. 250650310.010.02
Staphylococcus aureus
(ATCC #6538)Chlorascrub Swab
Lot No. 112001596.006.00
Chlorascrub Swab
Lot No. 112002476.006.00
Chlorascrub Swab
Lot No. 112002516.006.00
Sterile Water
Lot No. 25065031-0.010.06
Candida albicans
(ATCC #10231)Chlorascrub Swab
Lot No. 112001595.885.88
Chlorascrub Swab
Lot No. 112002475.885.88
Chlorascrub Swab
Lot No. 112002515.885.88
Sterile Water
Lot No. 250650310.07-0.01

6

Prevantics® Device swab Section 5: 510(K) Summary Statement 21(CFR 807.92) Professional Disposables International, Inc.

MicroorganismTest SubstanceMean Log10 Reduction
15 sec30 sec
Enterococcus faecalis
(ATCC #29212)Chlorascrub Swab
Lot No. 112001595.765.76
Chlorascrub Swab
Lot No. 112002475.765.76
Chlorascrub Swab
Lot No. 112002515.765.76
Sterile Water
Lot No. 250650310.070.14
Pseudomonas aeruginosa
(ATCC # 15442)Chlorascrub Swab
Lot No. 112001596.466.46
Chlorascrub Swab
Lot No. 112002476.466.46
Chlorascrub Swab
Lot No. 112002516.466.46
Sterile Water
Lot No. 250650310.200.23
Candida glabrata
(ATCC #2001)Chlorascrub Swab
Lot No. 112001596.076.07
Chlorascrub Swab
Lot No. 112002476.076.07
Chlorascrub Swab
Lot No. 112002516.076.07
Sterile Water
Lot No. 250650310.160.19

Minimal Effective Concentration (MEC) Study

The minimal effective concentration was examined using a range of dilutions of the Prevantics® Device Swab solution (50 - 90% of nominal). The testing was performed using the same techniques outlined in the Time-Kill Study section above. The microorganisms were limited to one each of Gram positive, Gram negative and fungus (Staphylococcus aureus (ATCC #6538), Escherichia coli (ATCC #11229), and Candida albicans (ATCC #10231)).

At both 15 and 30 seconds, application of the Prevantics® Device Swab solution to the microbial cultures resulted in a >4.00 log10 reduction in CFU/mL for each of the three (3) microorganism listed above. The results indicate that even when diluted to 50% of the nominal concentration, Prevantics Device Swab contains an effective antimicrobial combination.

7

Simulated Use Study

Additionally, in-vitro data from a Simulated Use Study is also submitted to substantiate performance that the subject device is substantially equivalent to the predicate devices.

| | | Mean Log10 Reduction (CFU/mL) of Needless Access
Site After 5 Second Application | | | | |
|--------------------------------------------------|------|-------------------------------------------------------------------------------------|---------------|---------------|-------------------------------|---------------|
| Microorganism | Soil | Mean
Lot 1 | Mean
Lot 2 | Mean
Lot 3 | Overall
Mean
Prevantics | Mean
Curos |
| Candida albicans
(ATCC #10231) | No | 6.5 | 6.5 | 4.9 | 6.0 | 6.5 |
| | Yes | 6.2 | 6.2 | 6.2 | 6.2 | 5.3 |
| Candida parapsilosis
(ATCC #7330) | No | 7.2 | 5.2 | 7.2 | 6.5 | 2.1 |
| | Yes | 4.8 | 5.4 | 3.5 | 4.6 | 2.5 |
| Escherichia coli
(ATCC #25922) | No | 5.7 | 4.9 | 4.4 | 5.0 | 6.3 |
| | Yes | 4.8 | 6.2 | 3.1 | 4.7 | 6.2 |
| Pseudomonas aeruginosa
(ATCC #27853) | No | 3.3 | 4.4 | 4.6 | 4.1 | 5.5 |
| | Yes | 5.3 | 4.3 | 3.1 | 4.2 | 5.4 |
| Staphylococcus aureus MRSA
(ATCC #33591) | No | 5.1 | 3.6 | 3.4 | 4.1 | 6.5 |
| | Yes | 6.6 | 4.9 | 4.9 | 5.5 | 4.3 |
| Staphylococcus epidermidis MRSE
(ATCC #51625) | No | 2.3 | 2.8 | 2.3 | 2.4 | 2.7 |
| | Yes | 4.6 | 3.0 | 1.3 | 2.9 | 2.2 |
| Staphylococcus aureus
(ATCC #6538)* | No | 5.8 | 5.5 | 6.2 | 5.8 | 5.5 |
| | Yes | 4.7 | 6.1 | 5.4 | 5.4 | 6.2 |
| Staphylococcus epidermidis
(ATCC #12228)* | No | 5.5 | 5.4 | 5.3 | 5.4 | 5.7 |
| | Yes | 6.4 | 5.7 | 5.5 | 5.9 | 5.0 |

  • The testing of both Staphylococcus aureus and Staphylococcus epidermidis were repeated after the initial results for Staphylococcus epidermidis demonstrated a 4.0 log10 reduction in microbial CFU/mL for seven (7) of eight (8) tested microorganisms, regardless of soil conditions. In comparison, the predicate device (Curos® Port Protector) achieved similar >4.0 log10 reduction on six (6) of eight (8) microorganisms. The Curos® Port Protector failed to achieve a >4.0 log10 reduction for Candida parapsilosis (ATCC #7330) and Staphylococcus epidermidis MRSE (ATCC 51625). The results of the simulated use testing indicate that Prevantics® Device Swab provides substantially equivalent results to the predicate device (Curos® Port Protector).

8

| Determination of Substantial

Equivalence:Summary of Non-Clinical Tests
A variety of non-clinical tests were conducted to show the safety
and effectiveness of the subject device including comparisons
against the predicate devices. Standardized test methods from ISO-
10993 were used in this testing and the methods and results are
described in the submission.
Summary of Clinical Tests
No new clinical tests were required to support the change.

The review of the indications for use, the technical characteristics
and the results provided from the non-clinical tests performed to
satisfy International Standard ISO-10993, Biological Evaluation of
Medical Devices Part 1: Evaluation and Testing (Cytotoxicity,
Closed Patch Test, Dermal Irritation, Systemic Toxicity)
demonstrate that Prevantics® Device Swabs are substantially
equivalent to the predicate devices. |

  • Conclusion Prevantics® Device Swab shares the same indications for use, similar design and functional features and was found to be substantially equivalent to the predicate devices. Prevantics® Device Swab has the same intended use as the predicate; and while it has different technological characteristics, the information submitted to FDA does not raise new questions of safety and effectiveness and demonstrates that the device is at least as safe and effective as the legally marketed devices.
    This summary includes all information necessary and Professional Disposable International Inc will provide any additional information requested by FDA during review of the 510(k).

Professional Disposable International Inc verifies that the following criteria have been met.

  • The summary includes only information that is also covered in the body of the 510(k). .
  • The summary does not contain any puffery or unsubstantiated labeling claims. .
  • The summary does not contain any raw data, i.e., contains only summary data. ●
  • The summary does not contain any trade secret or confidential commercial information. .
  • The summary does not contain any patient identification information. .