K Number
K150477
Device Name
3M Comply Indicator Tape for Ethylene Oxide (EO) Sterilization
Manufacturer
Date Cleared
2015-07-02

(128 days)

Product Code
Regulation Number
880.2800
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The tape is designed to secure packs wrapped with untreated woven (i.e., reusable 100% cotton and cotton/poly blends) and disposable non-woven, paper/plastic, and spunbond polyolefin/plastic wraps. Use the EO indicator tape to demonstrate that packs have been exposed to one of the EO sterilization processes in the table below and to distinguish between processed and unprocessed packs. | EO Gas Concentration | Exposure Time | Temperature | Relative Humidity % | |----------------------|---------------|-------------|---------------------| | 736 mg/L | 4.5 hours | 38°C | 40 - 80 % | | 736 mg/L | 1 hour | 55°C | 40 - 80 % | | 759 mg/L | 4.5 hours | 38°C | 40 - 80 % | | 759 mg/L | 1 hour | 55°C | 40 - 80 % | | 736 mg/L | 1 hour | 54°C | >35% | | 736 mg/L | 4.5 hours | 38°C | >35% | | 736 mg/L | 1 hour | 55°C | >35% | | 736 mg/L | 3 hours | 37°C | >35% | | 759 mg/L | 1 hour | 55°C | >35% | | 759 mg/L | 3 hours | 37°C | >35% |
Device Description
The 3M Comply™ 1224 Indicator Tape for Ethylene Oxide (EO) Sterilization is a green, pressure sensitive adhesive tape with yellow stripes that can be used to secure packages for EO sterilization. Post-sterilization the yellow stripes turn to red-maroon.
More Information

Indox Ethylene Oxide Indicator Tape

Not Applicable

No
The device is a chemical indicator tape that changes color based on exposure to EO sterilization conditions, with no mention of AI/ML in the description or performance studies.

No

The device is an indicator tape used to confirm exposure to ethylene oxide sterilization processes, not to treat a condition or disease.

No

The device is an indicator tape used to confirm exposure to sterilization processes, not to diagnose a medical condition in a patient.

No

The device is a physical tape with a chemical indicator, 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 secure sterilization packs and indicate exposure to ethylene oxide (EO) sterilization processes. This is a process indicator for sterilization, not a diagnostic test performed on biological samples.
  • Device Description: The device is a tape with a color-changing indicator. It does not interact with or analyze biological specimens.
  • Lack of IVD Characteristics: The description does not mention any of the typical characteristics of an IVD, such as:
    • Analyzing biological samples (blood, urine, tissue, etc.)
    • Providing information about a patient's health status, disease, or condition
    • Using reagents or assays to detect specific substances

The device's function is solely to provide a visual confirmation that a sterilization process has occurred. This falls under the category of a sterilization process indicator, not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

The tape is designed to secure packs wrapped with untreated woven (i.e., reusable 100% cotton and cotton/poly blends) and disposable non-woven, paper/plastic, and spunbond polyolefin/plastic wraps.

Use the EO indicator tape to demonstrate that packs have been exposed to one of the EO sterilization processes in the table below and to distinguish between processed and unprocessed packs.

EO Gas ConcentrationExposure TimeTemperatureRelative Humidity %
736 mg/L4.5 hours38°C40 - 80 %
736 mg/L1 hour55°C40 - 80 %
759 mg/L4.5 hours38°C40 - 80 %
759 mg/L1 hour55°C40 - 80 %
736 mg/L1 hour54°C>35%
736 mg/L4.5 hours38°C>35%
736 mg/L1 hour55°C>35%
736 mg/L3 hours37°C>35%
759 mg/L1 hour55°C>35%
759 mg/L3 hours37°C>35%

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

JOJ

Device Description

The 3M ComplyTM 1224 Indicator Tape for Ethylene Oxide (EO) Sterilization is a green, pressure sensitive adhesive tape with yellow stripes that can be used to secure packages for EO sterilization. Post-sterilization the yellow stripes turn to red-maroon.

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)

The effectiveness of the 3M ComplyTM 1224 Indicator Tape for Ethylene Oxide (EO) Sterilization is demonstrated by the application of testing described in the Recognized Consensus Standard:

ISO 11140-1:2005/R2010; Sterilization of Health Care Products - Chemical Indicators -Part 1: General Requirements,

  • Color Change in Resistometer Samples from 3 different lots were verified to meet the requirements for detectable color change post-exposure to ISO conditions in a resistometer.
  • Color Change in Health Care Facility Cycle Samples from 3 different lots were verified to meet the requirements for detectable color change post-exposure in an FDA cleared 3M Steri-Vac 5XL sterilizer cycle.
  • End-point Color Stability Samples from 3 different lots were verified to be stable to storage under typical office lighting conditions up to 6 months post-exposure in an FDA cleared 3M Steri-Vac 5XL sterilizer cycle.

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.

Indox Ethylene Oxide Indicator Tape

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

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

July 2, 2015

3M Health Care Matt Mortensen, PhD, RAC Regulatory Affairs Lead 3M Center Building 275-5W-06 St. Paul. MN 55144

Re: K150477

Trade/Device Name: 3M Comply™ 1224 Indicator Tape for Ethylene Oxide (EO) Sterilization Regulation Number: 21 CFR 880.2800 Regulation Name: Physical/chemical sterilization process indicator Regulatory Class: II Product Code: JOJ Dated: June 4, 2015 Received: June 5, 2015

Dear Dr. Mortensen:

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

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 Small Manufacturers, International and Consumer Assistance at its tollfree 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 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,

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

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Indications for Use

510(k) Number (if known) K150477

Device Name

3M Comply 1224 Indicator Tape for Ethylene Oxide (EO) Sterilization

Indications for Use (Describe)

The tape is designed to secure packs wrapped with untreated woven (i.e., reusable 100% cotton and cotton/poly blends) and disposable non-woven, paper/plastic, and spunbond polyolefin/plastic wraps.

United States

Use the EO indicator tape to demonstrate that packs have been exposed to one of the EO sterilization processes in the table below and to distinguish between processed and unprocessed packs.

EO Gas ConcentrationExposure TimeTemperatureRelative Humidity %
736 mg/L4.5 hours38°C40 - 80 %
736 mg/L1 hour55°C40 - 80 %
759 mg/L4.5 hours38°C40 - 80 %
759 mg/L1 hour55°C40 - 80 %
736 mg/L1 hour54°C>35%
736 mg/L4.5 hours38°C>35%
736 mg/L1 hour55°C>35%
736 mg/L3 hours37°C>35%
759 mg/L1 hour55°C>35%
759 mg/L3 hours37°C>35%

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)

3

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4

Premarket Notification (510(k)) Summary

Image /page/4/Picture/1 description: The image shows the 3M logo. The logo is in red and features the number "3" followed by the letter "M". The logo is simple and recognizable, and it is often used to represent the company 3M.

Sponsor Information:

3M Health Care 3M Center, Bldg. 275-5W-06 St. Paul, MN 55144-1000

Contact Person: Matt S. Mortensen, Ph.D., RAC Regulatory Affairs Phone Number: (651) 737-2670 FAX Number: (651) 737-5320

Date of Summary: June 15, 2015

Device Name and Classification:

Common or Usual Name: EO Process Indicator Tape

Proprietary Name: 3M Comply™ 1224 Indicator Tape for Ethylene Oxide (EO) Sterilization

Classification Name: Indicator, physical/chemical sterilization process (21 CFR § 880.2800)

Device Classification: Class II

Product Code: JOJ

Predicate Devices:

  • . Indox Ethylene Oxide Indicator Tape - pre-amendment

Description of Device:

The 3M Comply 10 1224 Indicator Tape for Ethylene Oxide (EO) Sterilization is a green, pressure sensitive adhesive tape with yellow stripes that can be used to secure packages for EO sterilization. Post-sterilization the yellow stripes turn to red-maroon.

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Nonclinical Comparison to the Predicate Device

The 3M Comply™ 1224 Indicator Tape for Ethylene Oxide (EO) Sterilization is similar in design to the previous generation of this product (the predicate) which was sold under the tradename Indox Ethylene Oxide Indicator Tape. In 2012 this previous version was determined by the Agency to meet the definition of a pre-amendment device. The product has been reformulated to lessen the environmental impact of solvents used in the manufacturing process. The new tape has the same intended use as the predicate.

Summary of Clinical Testing

No clinical data was included in this premarket application submission.

Indications for Use

The tape is designed to secure packs wrapped with untreated woven (i.e., reusable 100% cotton and cotton/poly blends) and disposable non-woven, paper, paper/plastic, and spunbond polyolefin/plastic wraps.

United States

Use the EO indicator tape to demonstrate that packs have been exposed to one of the EO sterilization processes in the table below and to distinguish between processed and unprocessed packs.

| EO Gas
Concentration | Exposure
Time | Temperature | Relative
Humidity % |
|-------------------------|------------------|-------------|------------------------|
| 736 mg/L | 4.5 hours | 38°C | 40 - 80 % |
| 736 mg/L | 1 hour | 55°C | 40 - 80 % |
| 759 mg/L | 4.5 hours | 38°C | 40 - 80 % |
| 759 mg/L | 1 hour | 55°C | 40 - 80 % |
| 736 mg/L | 1 hour | 54°C | >35% |
| 736 mg/L | 4.5 hours | 38°C | >35% |
| 736 mg/L | 1 hour | 55°C | >35% |
| 736 mg/L | 3 hours | 37°C | >35% |
| 759 mg/L | 1 hour | 55°C | >35% |
| 759 mg/L | 3 hours | 37°C | >35% |

Comparison to Predicate Devices

FeatureSubmission Device: 3M Comply 1224 Indicator Tape for Ethylene Oxide (EO) SterilizationPredicate Device (Pre-
-------------------------------------------------------------------------------------------------------------------------

6

| amendment):
Indox Ethylene
Oxide Indicator

Tape
The tape is designed to secure packs wrapped with untreated
woven (i.e., reusable 100% cotton and cotton/poly blends) and
disposable non-woven, paper, paper/plastic, and spunbond
polyolefin/plastic wraps.
United States
Use the EO indicator tape to demonstrate that packs have been
exposed to one of the EO sterilization processes in the table below
and to distinguish between processed and unprocessed packs.Use the EO
indicator tape to
demonstrate that
packs have been
exposed to the
sterilization
process and to
distinguish
between processed
and unprocessed
packs. The tape is
designed to secure
packs wrapped
with treated and
untreated woven,
with treated and
untreated non-
woven, paper,
paper/plastic, and
Tyvek®/plastic
wraps.
Indications
for useEO Gas
ConcentrationExposure
TimeTemperatureRelative
Humidity %
736 mg/L4.5 hours38°C40 - 80 %
736 mg/L1 hour55°C40 - 80 %
759 mg/L4.5 hours38°C40 - 80 %
759 mg/L1 hour55°C40 - 80 %
736 mg/L1 hour54°C>35%
736 mg/L4.5 hours38°C>35%
736 mg/L1 hour55°C>35%
736 mg/L3 hours37°>35%
759 mg/L1 hour55°C>35%
759 mg/L3 hours37°>35%
Indicator
AgentPhenol red1,8-
dihydroxyanthroquinone
Minimum
exposure to
critical
parameters
for color
changeDesigned to meet ISO 11140-1 Class 1 EO process indicator
requirementsIdentical
Recommended storageBest stored at normal room temperature conditions, 15-30°C (59-
86°F) and