K Number
K161658
Device Name
Anexa Wound Flush, Sterile Water & Sterile Normal Saline
Date Cleared
2016-09-14

(90 days)

Product Code
Regulation Number
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
For moistening of absorbent wound dressings and irrigation to remove loose debris and dirt from the wound.
Device Description
The Wound Flush, Sterile Water & Sterile Normal Saline device can be used 1) for moistening a dry sterile dressing for wound cleansing and 2) irrigation to remove loose debris and dirt from the wound. The mechanical action of fluid moving across the wound provides the mechanism of action and aids in the removal of loose foreign material such as dirt and debris. The product has a shelf life of 2-years. The solution is available as sterile saline for irrigation and is gamma sterilized. The subject device is offered in various bottle sizes of 100ml, 250ml, and 500ml and cup sizes of 120ml.
More Information

Not Found

No
The device description and intended use focus solely on the mechanical action of fluid for wound cleansing and irrigation. There is no mention of AI, ML, image processing, or any other computational analysis of data.

No
The device is described as aiding in the removal of loose foreign material from wounds through mechanical action, which is typically considered a cleansing or irrigation function, not a therapeutic treatment for a disease or condition.

No
The device is described for moistening dressings and wound irrigation to remove debris, which are therapeutic and cleansing actions, not diagnostic.

No

The device description clearly states it is a physical product (sterile saline solution in bottles and cups) used for wound irrigation and moistening, not a software application.

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

Here's why:

  • Intended Use: The intended use is for moistening wound dressings and irrigating wounds to remove debris. This is a topical application and mechanical action on the wound itself.
  • Device Description: The description reinforces the intended use, focusing on the physical action of the fluid on the wound.
  • Lack of Diagnostic Purpose: There is no mention of the device being used to analyze samples from the body (like blood, urine, tissue, etc.) to provide information about a patient's health status, disease, or condition. IVDs are specifically designed for this type of in vitro analysis.
  • No Mention of Biological Samples: The description only refers to the solution and its application to the wound, not the collection or analysis of biological samples.

Therefore, this device falls under the category of a medical device used for wound care, not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

For moistening of absorbent wound dressings and irrigation to remove loose debris and dirt from the wound.

Product codes

FRO

Device Description

The Wound Flush, Sterile Water & Sterile Normal Saline device can be used 1) for moistening a dry sterile dressing for wound cleansing and 2) irrigation to remove loose debris and dirt from the wound. The mechanical action of fluid moving across the wound provides the mechanism of action and aids in the removal of loose foreign material such as dirt and debris. The product has a shelf life of 2-years.

The solution is available as sterile saline for irrigation and is gamma sterilized. The subject device is offered in various bottle sizes of 100ml, 250ml, and 500ml and cup sizes of 120ml.

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)

Non Clinical Testing was conducted against various ASTM, AAMI/ANSI/ISO standards. Anexa conducted and passed the following biocompatibility tests: cytotoxicity, dermal sensitization, intracutaneous test (direct injection), acute systemic toxicity and bacterial endotoxin test.

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

Not Found

Predicate Device(s)

K083042

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

N/A

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 text "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 one behind the other.

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

September 14, 2016

Anexa Biomedical, Inc. % Ms. Yolanda Smith Smith Associates 1468 Harwell Avenue Crofton, MD 21114

Re: K161658

Trade/Device Name: Anexa Wound Flush, Sterile Water & Sterile Normal Saline Regulatory Class: Unclassified Product Code: FRO Dated: June 14, 2016 Received: June 16, 2016

Dear Ms. Smith:

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.

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.

1

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,

David Krause -S

Binita S. Ashar, M.D., M.B.A., F.A.C.S. for Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement on last page.

510(k) Number (if known) K161658

Device Name

Wound Flush, Sterile Water & Normal Saline

Indications for Use (Describe)

For moistening of absorbent wound dressings and irrigation to remove loose debris and dirt from the wound.

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)

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510(k) Summary K161658 (As Per 21 CFR 807.92)

SPONSOR CompanyName: Anexa Biomedical, Inc. Company Address: 40423 Air Time Ave Zephyrhills, Florida 33542 Telephone: 813-780-7927 813-780-7930 Fax: ContactPerson: Lenny Budloo SummaryPrepared September 12, 2016 TradeName: Anexa Sterile Water, Normal Saline Sterile Water, Normal Saline, Wound Common/UsualName: Flush Solution Classification Name: Dressing, Wound, Drug Product Code: FRO Device Class: Unclassified Regulation Number: Predicate Device Company Product 510(k)# Nurse Assist, Inc. Wound Flush, Sterile Water

& Sterile Normal Saline

K083042

4

Device Description

The Wound Flush, Sterile Water & Sterile Normal Saline device can be used 1) for moistening a dry sterile dressing for wound cleansing and 2) irrigation to remove loose debris and dirt from the wound. The mechanical action of fluid moving across the wound provides the mechanism of action and aids in the removal of loose foreign material such as dirt and debris. The product has a shelf life of 2-years.

The solution is available as sterile saline for irrigation and is gamma sterilized. The subject device is offered in various bottle sizes of 100ml, 250ml, and 500ml and cup sizes of 120ml.

Indications for Use

For moistening of absorbent wound dressings and irrigation to remove loose debris and dirt from the wound.

Comparison of Technological Characteristics

| | Subject | Predicate
Nurse Assist, Inc. | Similarities
and
Difference |
|--------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------|
| K Number | | K083042 | |
| Brand Name | Anexa Wound Flush, Sterile Water
& Sterile Normal Saline | Nurse Assist Wound Flush, Sterile
Water & Sterile Normal Saline | |
| Classification
Product Code | FRO | FRO | Same |
| Classification | Pre-amendment | Pre-amendment | Same |
| Indications
for Use | For moistening of absorbent wound
dressings and irrigation to remove
loose debris and dirt from the
wound. | Over the counter Use
For moistening absorbent wound
dressings and cleaning minor cuts,
minor burns, superficial abrasions
and minor irritations of the skin.

For Prescription Use
For moistening absorbent wound
dressings and for moistening,
debriding and cleaning acute and
chronic dermal lesions, such as
Stage I-IV pressure ulcers, stasis
ulcers, diabetic ulcers, foot ulcers,
post-surgical wounds, first and
second degree burns, cuts,
abrasions and minor skin irritations
and for device irrigation. | Similar |
| Principle of
Operation | Mechanical action of fluid moving
across the wound or device aids
in the removal of foreign objects
such as loose dirt and debris | Mechanical action of fluid moving
across the wound or device aids
in the removal of foreign objects
such as dirt and debris | Similar |
| Chemical
Composition | 0.9% Sterile Saline or Sterile
Water; no antimicrobial or other
substance added | 0.9% Sterile Saline or Sterile
Water; no antimicrobial or other
substance added | Same |

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Models8100 100 mL Sterile Water6210 120 mL Sterile WaterSame
9100 100 mL Sterile Saline6220 120 mL Normal Saline
8250 250 mL Sterile Water6240 100 mL Normal Saline
9250 250 mL Sterile Saline6250 100 mL Sterile Water
8500 500 mL Sterile Water6260 250 mL Sterile Water
9500 500 mL Sterile Saline6270 250 mL Normal Saline
8120 120 mL Sterile Water6280 500 mL Normal Saline
9120 120 mL Sterile Saline6290 500 mL Sterile Water

Discussion of Technological Differences

The subject device and the predicate have similar indications for use and intended use. Both offer bottles with induction sealed pull tab with screw cap closure and high impact polystyrene cups with heat sealed foil lid. The mechanical action is the same for both the subject device and the predicate, as it relates to Sterile Water and Normal Saline bottles and cups. The materials and methods used in the manufacturing and sterilization (gamma) are the same for both devices.

Non Clinical Testing

ASTM F1980-07 (Reapproved 2011)
AAMI/ANSI/ISO 11607-1:2006/(R)2010
AAMI/ANSI/ISO 11607-2:2006/(R)2010
AAMI/ANSI / ISO 11137-1:2006/(R)2010
AAMI/ANSI/ ISO 11137-2:2013
AAMI / ANSI / ISO 11737-1:2006 (R)2011
AAMI / ANSI / ISO 11737-2:2009/(R)2014
AAMI/ANSI/ISO 10993-1:2009/(R) 2013
AAMI / ANSI/ISO 10993-5:2009/(R) 2014
ISO 10993-10 Third Edition 2010-08-01
AAMI/ANSI/ISO 10993-11:2006/(R)2010
AAMI TIR 22:2007
AAMI TIR 33:2005
AAMI/ANSI/ISO TIR 13004:2013

Anexa conducted and passed the following biocompatibility tests; cytotoxicity, dermal sensitization, intracutaneous test (direct injection), acute systemic toxicity and bacterial endotoxin test.

Substantial Equivalence Conclusion

The Anexa products passed all the referenced biocompatibility tests, uses the same materials and container designs, same method of sterilization, same principle of operation, and the same intended use(s). Through safety and performance testing, Anexa Biomedical has concluded that the device does not introduce any significant new questions of safety and is substantially equivalent to the predicate device.