K Number
K143629
Device Name
U&U Bowie-Dick Test Pack
Date Cleared
2015-05-19

(148 days)

Product Code
Regulation Number
880.2800
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
U&U Bowie-Dick Test Pack are designed for testing air removal efficiency of dynamic-air-removal prevacuum steam sterilizers operating at 134 degree C (273 degree F) for 3.5 minutes. The U&U Bowie-Dick Test Pack is for single use and will demonstrate a uniform color change from yellow to dark brown/black when proper sterilization are met and no air is present. If enough air is present to create a 2°C (+1°C /-0°C) temperature difference between the center of the Bowie-Dick Test Pack, as identified in ANSI/AAMI/ISO 11140-5, and the drain temperature at the beginning of the final one minute of a three and half minute cycle the U&U Bowie-Dick Test Pack will demonstrate a non-uniform color change
Device Description
The U&U Bowie-Dick Test Pack is equivalent in performance to the Bowie-Dick towel pack described in AAMI ST66. The test pack consists of a chemical indicator test sheet positioned within a pack of porous sheets. The test sheet contains a steam-sensitive chemical indicator ink printed on paper as a yellow-colored pattern. The test sheet will turn a uniform dark brown/black color except when air removal failures such as air leaks occur. An air removal failure is indicated by a lighter-colored area in the indicator ink pattern of an otherwise dark-colored test sheet.
More Information

Not Found

No
The device is a chemical indicator test pack that changes color based on temperature and air presence, which is a purely physical/chemical process, not involving AI or ML. The summary explicitly states "Not Found" for mentions of AI, DNN, or ML, and describes a simple color change mechanism.

No
The device is a sterilizer test pack designed to verify air removal efficiency in steam sterilizers, not to treat or diagnose patients.

No

This device is a Bowie-Dick Test Pack, used to test the air removal efficiency of steam sterilizers. It indicates if proper sterilization conditions are met or if air is present, which is a quality control measure for equipment performance, not a diagnostic tool for patients or medical conditions.

No

The device description clearly indicates it is a physical test pack consisting of porous sheets and a chemical indicator test sheet with ink, not software.

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

Here's why:

  • Intended Use: The intended use is to test the air removal efficiency of steam sterilizers. This is a quality control test for a medical device (the sterilizer), not a test performed on a biological sample from a patient to diagnose a condition or provide information about their health.
  • Device Description: The device is a test pack with a chemical indicator that changes color based on steam penetration. It does not interact with biological samples.
  • Lack of Biological Sample Input: There is no mention of the device being used with blood, urine, tissue, or any other biological specimen.
  • Focus on Sterilizer Performance: The entire description revolves around evaluating the performance of a steam sterilizer, not a patient's health status.

IVD devices are specifically designed to be used in vitro (outside the body) to examine specimens derived from the human body to provide information for diagnostic, monitoring, or compatibility purposes. This device does not fit that description.

N/A

Intended Use / Indications for Use

U&U Bowie-Dick Test Pack are designed for testing air removal efficiency of dynamic-air-removal prevacuum steam sterilizers operating at 134 degree C (273 degree F) for 3.5 minutes. The U&U Bowie-Dick Test Pack is for single use and will demonstrate a uniform color change from yellow to dark brown/black when proper sterilization are met and no air is present. If enough air is present to create a 2°C (+1°C /-0°C) temperature difference between the center of the Bowie-Dick Test Pack, as identified in ANSI/AAMI/ISO 11140-5, and the drain temperature at the beginning of the final one minute of a three and half minute cycle the U&U Bowie-Dick Test Pack will demonstrate a non-uniform color change

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

JOJ

Device Description

The U&U Bowie-Dick Test Pack is equivalent in performance to the Bowie-Dick towel pack described in AAMI ST66. The test pack consists of a chemical indicator test sheet positioned within a pack of porous sheets. The test sheet contains a steam-sensitive chemical indicator ink printed on paper as a yellow-colored pattern. The test sheet will turn a uniform dark brown/black color except when air removal failures such as air leaks occur. An air removal failure is indicated by a lighter-colored area in the indicator ink pattern of an otherwise dark-colored test sheet.

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

Not Found

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

Not Found

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

Validation of the U&U Bowie-Dick Test Pack included performance testing in dynamic-air-removal steam sterilizer, biocompatibility, storage condition, shelf life. All results, from testing meet the predetermined acceptance criteria.

Testing Items:

  • Visual inspection: PASS (Inspect the Cleanliness of Bowie-dick test pack.)
  • Dimensions: PASS (Width: 140±1mm; Length: 140±1mm; Height: 18±1mm)
  • Endpoint Color: Black (Dark brown/black)
  • Indicator Format: 66% (The bowie-dick internal indicator ink shall be uniformly distributed on its substrate paper to cover not less than 30 % of the test area of the substrate paper. the indicator ink printed / the substrate paper ≥ 30%)
  • Indicator Color Change Performance: PASS (The bowie-dick internal indicator system shall show a uniform color after exposure to saturated steam at 134°C for 3.5 min.)
  • Internal Indicator Color Change Fault Performance: PASS (Color change fault condition (the temperature at the center of the bowie-dick test pack is 2°C lower than the temperature of the chamber drain at the beginning of the final 1 min of a 3.5 min cycle at 134 °C). After exposure to conditions used to produce a color change fault condition in the bowie-dick test pack. the internal indicator shall show a non-uniform color change.)
  • Air Permeance Performance: PASS (The bowie-dick test pack shall have an air porosity not less than 1.7 µm/(Pa·s) when tested in accordance with ISO 5636-3 at an air pressure of 1.47 kPa)
  • Toxicity: PASS (Non-toxic; In Vitro Cytotoxicity (MTT cytotoxicity test) Test Result: Under the conditions of cytotoxicity study, the viability of 100% extract of the test article was 76 %. It can be considered that the article extracts had not a cytotoxic potential.)

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

Not Found

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.

K093199

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

§ 880.2800 Sterilization process indicator.

(a)
Biological sterilization process indicator —(1)Identification. A biological sterilization process indicator is a device intended for use by a health care provider to accompany products being sterilized through a sterilization procedure and to monitor adequacy of sterilization. The device consists of a known number of microorganisms, of known resistance to the mode of sterilization, in or on a carrier and enclosed in a protective package. Subsequent growth or failure of the microorganisms to grow under suitable conditions indicates the adequacy of sterilization.(2)
Classification. Class II (performance standards).(b)
Physical/chemical sterilization process indicator —(1)Identification. A physical/chemical sterilization process indicator is a device intended for use by a health care provider to accompany products being sterilized through a sterilization procedure and to monitor one or more parameters of the sterilization process. The adequacy of the sterilization conditions as measured by these parameters is indicated by a visible change in the device.(2)
Classification. Class II (performance standards).

0

Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health and 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.

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

May 19, 2015

U&U Medical Technology Co., Ltd. C/O Ms. Li Qian Official Correspondent CARELIFE (USA), Inc. 1580 Boggs Rd. Suite 500/600 Duluth, Georgia 30096

Re: K143629

Trade/Device Name: U&U Bowie-Dick Test Pack Regulation Number: 21 CFR 880.2800 Regulation Name: Chemical Indicator/Physical/Chemical sterilization process indicator Regulatory Class: II Product Code: JOJ Dated: April 15, 2015 Received: April 20, 2015

Dear Ms. Li Qian:

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. Li Qian

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 yours,

Tejashri Purohit-Sheth, M.D.

Tejashri Purohit-Sheth, M.D. Clinical Deputy Director DAGRID/ODE/CDRH FOR

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) K143629

Device Name U&U Bowie-Dick Test Pack

Indications for Use (Describe)

U&U Bowie-Dick Test Pack are designed for testing air removal efficiency of dynamic-air-removal prevacuum steam sterilizers operating at 134 degree C (273 degree F) for 3.5 minutes. The U&U Bowie-Dick Test Pack is for single use and will demonstrate a uniform color change from yellow to dark brown/black when proper sterilization are met and no air is present. If enough air is present to create a 2°C (+1°C /-0°C) temperature difference between the center of the Bowie-Dick Test Pack, as identified in ANSI/AAMI/ISO 11140-5, and the drain temperature at the beginning of the final one minute of a three and half minute cycle the U&U Bowie-Dick Test Pack will demonstrate a non-uniform color change

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

| Prescription Use (Part 21 CFR 801 Subpart D)

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

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3

Rev 0.03 15/05/15

Sec 005_510(K) Summary

This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of SMDA and 21 CFR §807.92

Date Prepared: 2015-05-15 Submission Numbers for Pre-Submission: K143629

1. Submitter Name and Address:

Name:U&U Medical Technology Co., Ltd
Address:Dongzhou Village,Hengshanqiao,Changzhou,Jiangsu,China
RM EE1092 1/F Building 1, No 1755, HONGMEI Road, Shanghai, China
Contactor Name:Garfield Wang
TEL:+86-13902471751
E-mail:Wangxuebo_11@hotmail.com

US Agent:

Name:CARELIFE (USA) INC.
Address:1580 Boggs Rd, Suite 500/600 Duluth GA 30096
TEL:404 6612228
Contact person :Ms. LI QIAN liqian@shanghaicarelife.com

2. Submission Devices Information:

Trade/Proprietary Name: U&U Bowie-Dick Test Pack Common Name: Bowie-Dick Test Pack Classification name: indicator, physical/chemical sterilization process Class: II FDA review panel code: General Hospital Product code: JOJ Regulation Number: 21 CFR 880.2800

3. Predicate Devices Information:

Trade Name:3M Comply Bowie-Dick Type Lead Free Test Pack
510(K) Number:K093199
Manufacturer:3M Health Care

4. Devices Description:

The U&U Bowie-Dick Test Pack is equivalent in performance to the Bowie-Dick towel pack described in AAMI ST66. The test pack consists of a chemical indicator test sheet positioned within a pack of porous sheets. The test sheet contains a steam-sensitive chemical indicator ink printed on paper as a yellow-colored pattern. The test sheet will turn a uniform dark brown/black color except when air removal failures such as air leaks occur. An air removal failure is indicated by a lighter-colored area in the indicator ink pattern of an otherwise dark-colored test sheet.

Model Number:

4

510(k) Submission

U&U ChangZhou Medical Packaging Technology Co., Ltd Dongzhou Village,Hengshangiao,Changzhou,Jiangsu,China U&U (Shanghai) Medical Technology Co., Limited RM EÈ1092 1/F Building 1, No 1755, HONGMEI Road, Shanghai, China [Bowie-Dick Test Pack]

Rev 0.03 15/05/15

| Ref
Number | Model
Number | Description | Size |
|---------------|-----------------|--------------------------|--------------|
| UUBD0001 | UUBDTP | U&U Bowie-Dick Test Pack | 140X140X18mm |

5. Intended Use:

U&U Bowie-Dick Test Pack are designed for testing air removal efficiency of dynamic-airremoval prevacuum steam sterilizers operating at 134 degree C (273 degree F) for 3.5 minutes. The U&U Bowie-Dick Test Pack is for single use and will demonstrate a uniform color change from yellow to dark brown/black when proper sterilization conditions are met and no air is present. If enough air is present to create a 2°C (+1°C /-0°C) temperature difference between the center of the Bowie-Dick Test Pack, as identified in ANSI/AAMI/ISO 11140-5, and the drain temperature at the beginning of the final one minute of a three and half minute cycle the U&U Bowie-Dick Test Pack will demonstrate a non-uniform color change

6. Technical Design and Performance Characteristics:

The U&U Bowie-Dick Test Pack uses impermeable lavers on the top and bottom to direct steam and enhances the air capture qualities. A precisely controlled pad of porous substrate is used to establish a matrix for the formation of an air bubble and to act as a reservoir of air simulating the towels in a conventional large towel pack.

The reticulated foam layer acts as a steam pathway for the control of air bubble alignment and insulates the indicator from radiant heat emanating from the hot surface of the sterilizer chamber. Air is evacuated from the chamber and the test pack during the pre-vacuum cycle. If an air leak is present, air will bleed back into the chamber as a vacuum is pulled. Since air is much cooler and heavier than steam, it will be forced to the bottom of the chamber near the drain when the steam valves opens. As pressure begins to increase, the air and then the steam enters the pack from the sides and top of the reticulated foam pathway at the top of the pack. The steam pressure compresses the air into a bubble and pushes it toward the bottom of the pack. As the steam pressure increases, the air bubble is squeezed smaller and smaller until the pressure stabilizes.

7. SUBSTANTIAL EQUIVALENCE DISCUSSION:

U&U Medical Technology Co., Ltd is claiming substantial equivalence for its U&U Bowie-Dick Test Pack to the 3M Comply Bowie-Dick Type Lead Free Test Pack (K093199) based on test data obtained during validation studies. We have demonstrated with testing that the U&U Bowie-Dick Test Pack performs consistently with results which indicate that the indicator is sensitive enough to detect when enough air is left within the sterilizer chamber to create a 2°C (+1° /-0°C) temperature difference between the center of the Bowie-Dick Test Pack, as identified in ANSI/AAMI/ISO 11140-5. Under these conditions, the indicator sheet would demonstrate a non-uniform color change. The U&U Bowie-Dick Test Pack is also comparable to other commercially available Bowie Dick test packs cleared by the FDA.

Comparison table:

| Element of

ComparisonSubmission DevicePredicate Device K093199
Intended UseU&U Bowie-Dick Test Pack are designed
for testing air removal efficiency ofThe 3MTM Comply Tm Bowie-Dick Type Lead
Free Test Pack is designed for testing air
dynamic-air-removal prevacuum steam
sterilizers operating at 134 °C (273°F) for
3.5 minutes. The U&U Bowie-Dick Test
Pack is for single use and will demonstrate
a uniform color change from yellow to dark
brown/black when proper sterilization
conditions are met and no air is present. If
enough air is present to create a 2°C (+1°
/-0°C) temperature difference between the
center of the Bowie-Dick Test Pack, as
identified in ANSI/AAMI/ISO 11140-5, and
the drain temperature at the beginning of
the final one minute of a three and half
minute cycle the U&U Bowie-Dick Test
Pack will demonstrate a non-uniform color
changeremoval efficiency of 132- 134 °C(270- 273 F )
dynamic-air-removal steam sterilizers.
Raw MaterialsImpermeable Layer - Frame Board
Reticulated Foam - Polyurethane
Porous Substrate - Food Packaging Board
Indicator Sheet - Indicator ink & paper
Disposable Wrap - Polypropylene Wrap
Label - Paper & Hotmelt AdhesiveImpermeable Layer - Frame Board
Reticulated Foam - Polyurethane
Porous Substrate - Food Packaging Board
Indicator Sheet - Inicator ink & paper
Disposable Wrap - Polypropylene Wrap
Label - Paper & Hotmelt Adhesive
Indicator AgentIndicator Ink - Lithium carbonate (5-10%),
Triethylamine(1-5%) , Normal Propanol(1-
5%)Indicator Ink - unknown
Chemical
Indicator TypeAir Removal Indicator For Test PackAir Removal Indicator For Test Pack
Endpoint ColorDark brown/BlackDark brown/Black
Sterilization
Methoddynamic-air-removal steam sterilizerdynamic-air-removal steam sterilizer
Indictor Color
Change
PerformanceThe bowie-dick internal indicator system
shall show a uniform color after exposure
to saturated steam at 134°C for 3.5 min.The bowie-dick internal indicator system shall
show a uniform color after exposure to saturated
steam at 134°C for 3.5 min.
Internal
Indicator Color
Change Fault
PerformanceColor change fault condition (the
temperature at the center of the bowie-
dick test pack is 2°C lower than the
temperature of the chamber drain at the
beginning of the final 1 min of a 3.5 min
cycle at 134 °C). After exposure to
conditions used to produce a color change
fault condition in the bowie-dick test pack.
the internal indicator shall show a non-
uniform color change.Color change fault condition (the temperature at
the center of the bowie-dick test pack is 2°C
lower than the temperature of the chamber drain
at the beginning of the final 1 min of a 3.5 min
cycle at 134 °C). After exposure to conditions
used to produce a color change fault condition in
the bowie-dick test pack. the internal indicator
shall show a non-uniform color change.
Recommended
Storage
Conditions:Store in a dry (