K Number
K162284
Device Name
Puritan Fecal Opti-Swab Collection and Transport System
Date Cleared
2016-11-04

(81 days)

Product Code
Regulation Number
866.2390
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Puritan Fecal Opti-Swab Collection and Transport System is intended for use in the collection and transport of clinical fecal and rectal swab specimens to preserve the viability of enteric bacteria during transport from the collection site to the testing laboratory for bacteriological examination and culture.
Device Description
Puritan Fecal Opti-Swab Collection and Transport System is comprised of a sterile peel pouch containing a sterile polyester flock swab applicator for collecting clinical fecal and rectal specimens and a polypropylene vial containing 2 ml of Fecal Opti-Swab medium. Fecal Opti-Swab medium is a nonnutritive balanced salt solution containing phosphates to provide buffering capability, chloride salts to provide essential ions that help maintain osmotic balance. Agar is a solidifying agent that increases the viscosity of the medium. Sodium thioglycolate and L-cysteine provides an oxygen-reduced environment. It is recommended for maintaining the viability of enteric bacteria during the transport to the laboratory.
More Information

Not Found

No
The device description and performance studies focus on the physical components and chemical medium for specimen collection and transport, with no mention of AI or ML for analysis or processing.

No

This device is intended for the collection and transport of specimens to preserve the viability of bacteria for diagnostic testing, not for treating a disease or condition.

No

The device is intended for the collection and transport of specimens to preserve the viability of bacteria for bacteriological examination and culture in a testing laboratory. It does not perform the diagnostic examination itself.

No

The device description clearly states it is comprised of a sterile peel pouch containing a sterile polyester flock swab applicator and a polypropylene vial containing 2 ml of Fecal Opti-Swab medium, which are physical components, not software.

Yes, this device is an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use explicitly states it's for the "collection and transport of clinical fecal and rectal swab specimens to preserve the viability of enteric bacteria during transport from the collection site to the testing laboratory for bacteriological examination and culture." This clearly indicates its purpose is to prepare a specimen for subsequent in vitro diagnostic testing (bacteriological examination and culture).
  • Device Description: The device includes a "Fecal Opti-Swab medium" which is a transport medium designed to maintain the viability of microorganisms for laboratory testing. This medium is an integral part of the diagnostic process, even though the testing itself happens elsewhere.
  • Performance Studies: The performance studies focus on "Recovery Testing" and "Stability Testing" related to maintaining the viability of enteric bacteria. These studies are directly relevant to ensuring the quality of the specimen for in vitro diagnostic testing.
  • Predicate Device: The predicate device listed (Copan Fecal Swab Collection, Transport and Preservation System) is also a collection and transport system for fecal specimens intended for diagnostic testing, further supporting the classification of this device as an IVD.

While the device itself doesn't perform the diagnostic test (like analyzing the bacteria), it is a crucial component in the in vitro diagnostic process by collecting and preserving the specimen for that testing.

N/A

Intended Use / Indications for Use

Puritan Fecal Opti-Swab Collection and Transport System is intended for use in the collection and transport of clinical fecal and rectal swab specimens to preserve the viability of enteric bacteria during transport from the collection site to the testing laboratory for bacteriological examination and culture.

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

JSM, LIO, JTW, JTX

Device Description

Puritan Fecal Opti-Swab Collection and Transport System is comprised of a sterile peel pouch containing a sterile polyester flock swab applicator for collecting clinical fecal and rectal specimens and a polypropylene vial containing 2 ml of Fecal Opti-Swab medium.

Fecal Opti-Swab medium is a nonnutritive balanced salt solution containing phosphates to provide buffering capability, chloride salts to provide essential ions that help maintain osmotic balance. Agar is a solidifying agent that increases the viscosity of the medium. Sodium thioglycolate and L-cysteine provides an oxygen-reduced environment. It is recommended for maintaining the viability of enteric bacteria during the transport to the laboratory.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

clinical fecal and rectal swab specimens

Indicated Patient Age Range

Not Found

Intended User / Care Setting

collection site to the testing laboratory for bacteriological examination and culture.

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)

Recovery Testing: To determine the ability of the Puritan Fecal Opti-Swab Collection and Transport System to maintain viability of different strains of enteric bacteria, known inoculum of ATCC type culture and clinically significant microorganisms were prepared in a phosphate-buffered saline matrix and inoculated into the Puritan Fecal Opti-Swab Collection and Transport medium and compared to the predicate device following Clinical and Laboratory Standards Institute (CLSI) M40-A2 guidelines. No notable differences in recovery were detected between the Puritan Fecal Opti-Swab Collection and Transport System and the predicate device. Recovery was also evaluated using three representative challenge organisms prepared in a fecal matrix to demonstrate that the performance of the Puritan Fecal Opti-Swab Collection and Transport medium is not adversely affected by fecal material. It was determined that clinical fecal material does not notably alter the recovery of the challenge organisms from the Puritan Fecal Opti-Swab Collection and Transport System.

Stability Testing: Stability tests were performed on Puritan Fecal Opti-Swab Collection and Transport System to verify the ability of the aged products to maintain microbial recovery up to the expiry date.

pH Stability: The pH of the test device was measured at predetermined time intervals for up to 15 months after manufacturing date. The test was performed using calibrated pH meter with random samples from three different lots of Puritan Fecal Opti-Swab Collection and Transport System. All samples tested were found to maintain pH within the specified range.

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

Sterilization: Puritan Fecal Opti-Swab Collection and Transport System is sterilized by gamma irradiation and validated following ANSI/AAMI/ISO 11137:2006, Sterilization of health care products Radiation guidelines.

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.

K142094

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

§ 866.2390 Transport culture medium.

(a)
Identification. A transport culture medium is a device that consists of a semisolid, usually non-nutrient, medium that maintains the viability of suspected pathogens contained in patient specimens while in transit from the specimen collection area to the laboratory. The device aids in the diagnosis of disease caused by pathogenic microorganisms and also provides epidemiological information on these diseases.(b)
Classification. Class I (general controls).

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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 text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" 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

November 4, 2016

PURITAN MEDICAL PRODUCTS LLC MEHDI KARAMCHI VICE PRESIDENT OF SCIENTIFIC AFFAIRS 31 SCHOOL STREET P.O. BOX 149 GUILFORD ME 04443

Re: K162284

Trade/Device Name: Puritan Fecal Opti-swab Collection And Transport System Regulation Number: 21 CFR 866,2390 Regulation Name: Transport culture medium Regulatory Class: I Product Code: JSM, LIO, JTW, JTX Dated: August 11, 2016 Received: August 15, 2016

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. 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 Parts 801 and 809); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (OS) 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 regulations (21 CFR Parts 801 and 809), 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/ResourcesforYou/Industry/default.htm. 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 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,

Ribhi Shawar -S

For Uwe Scherf, M.Sc., Ph.D. Director Division of Microbiology Devices Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K162284

Device Name

Puritan Fecal Opti-Swab Collection and Transport System

Indications for Use (Describe)

Puritan Fecal Opti-Swab Collection and Transport System is intended for use in the collection and transport of clinical fecal and rectal swab specimens to preserve the viability of enteric bacteria during transport from the collection site to the testing laboratory for bacteriological examination and culture.

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)

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510(k) Summary

Puritan® Fecal Opti-Swab™ Collection and Transport System

5.1 Sponsor

5.1Sponsor
Puritan Medical Products LLC
31 School St., Guilford, ME
04443
Contact:Mehdi Karamchi
Telephone Number:207-876-3311
Fax Number:207-876-2680
Date:August 11, 2016
5.2Device Name
Classification Name:Transport Culture Medium
Common Name:Specimen Collection and Transport System
Proprietary Name:Puritan® Fecal Opti-Swab™ Collection and Transport System
5.3Regulatory Information
A. Regulatory Section:21 CFR 866.2390
B. Classification:Class I
C. Product Code:LIO, JSM; JTW; JTX
D. Panel:Microbiology (83)

5.4 Predicate Device

Copan Fecal Swab Collection, Transport and Preservation System manufactured by Copan Diagnostics Inc. of Italy

510K Number: K142094

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5.5 Device Description

Puritan Fecal Opti-Swab Collection and Transport System is comprised of a sterile peel pouch containing a sterile polyester flock swab applicator for collecting clinical fecal and rectal specimens and a polypropylene vial containing 2 ml of Fecal Opti-Swab medium.

Fecal Opti-Swab medium is a nonnutritive balanced salt solution containing phosphates to provide buffering capability, chloride salts to provide essential ions that help maintain osmotic balance. Agar is a solidifying agent that increases the viscosity of the medium. Sodium thioglycolate and L-cysteine provides an oxygen-reduced environment. It is recommended for maintaining the viability of enteric bacteria during the transport to the laboratory.

5.6 Intended Use

Puritan Fecal Opti-Swab Collection and Transport System is intended for use in the collection and transport of clinical fecal and rectal swab specimens to preserve the viability of enteric bacteria during transport from the collection site to the testing laboratory for bacteriological examination and culture.

5.7 Indication(s) For Use

Puritan Fecal Opti-Swab Collection and Transport System is intended for use in the collection and transport of clinical fecal and rectal swab specimens to preserve the viability of enteric bacteria during transport from the collection site to the testing laboratory for bacteriological examination and culture.

5.8. Substantial Equivalence statement

Puritan Fecal Opti-Swab Collection and Transport System is similar in design, manufacturing and intended usage to the predicate device. Both the Puritan and the predicate device are single-use devices intended for collection and transport of clinical fecal and rectal swab specimens to preserve the viability of enteric bacteria during transport from the collection site to the testing laboratory for bacteriological examination and culture.

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Puritan and Predicate Device Comparison
ItemTest DevicePredicate
Intended USEPuritan Fecal Opti-Swab
Collection and Transport System
is a sterile ready-to- use system
intended for collection and
transport of clinical fecal and
rectal swab specimens to
preserve the viability of enteric
bacteria during transport from
the collection site to the testing
laboratory for bacteriological
examination and culture.The Copan FecalSwab
Collection, Transport and
Preservation System is
intended for the collection
of rectal swab and fecal
specimens and to preserve
the viability of enteric
pathogenic bacteria during
transport from the
collection site to the testing
laboratory. In the
laboratory, FecalSwab
specimens are processed
using standard clinical
laboratory operating
procedures for culture.
Single-use DeviceYesSame
Medium FormulationChloride salts
Sodium salts
Phosphate buffer
L-Cysteine
Agar
WaterChloride salts
Sodium salts
Phosphate buffer
L-Cysteine
Agar
Water (different
formulation)
pH6.90-7.50Same
Storage Temperature2-25°C (refrigerated and room
temperature)5-25°C (refrigerated and
room temperature)
ContainerPolypropylene conical bottom
vialSame
Product ConfigurationMedium in vial & cap
System including Medium andSame
swab in peel pouch option.
Swab ShaftPlasticSame
Swab TipFlock SwabSame
Shelf Life15 monthsSame
Specimen StorageFor C. difficile, up to 48 hours at
2 – 8 °C and up to 24 hours at 20
– 25 °C. For other target
organisms organisms: up to 72
hours at 2 – 8 °C and up to 48
hours at 20 – 25 °C.Same
Medium Volume2 mLSame
Organisms TestedCampylobacter jejuni
Clostridium difficile
Enterococcus faecalis
Escherichia coli
Salmonella typhimurium
Shigella sonnei
Vibrio parahaemolyticus
Yersinia enterocoliticaSame

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5.9 Recovery Testing

To determine the ability of the Puritan Fecal Opti-Swab Collection and Transport System to maintain viability of different strains of enteric bacteria, known inoculum of ATCC type culture and clinically significant microorganisms were prepared in a phosphate-buffered saline matrix and inoculated into the Puritan Fecal Opti-Swab Collection and Transport medium and compared to the predicate device following Clinical and Laboratory Standards Institute (CLSI) M40-A2 guidelines. No notable differences in recovery were detected between the Puritan Fecal Opti-Swab Collection and Transport System and the predicate device.

Recovery was also evaluated using three representative challenge organisms prepared in a fecal matrix to demonstrate that the performance of the Puritan Fecal Opti-Swab Collection and Transport medium is not adversely affected by fecal material. It was determined that clinical fecal material does not notably alter the recovery of the challenge organisms from the Puritan Fecal Opti-Swab Collection and Transport System.

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5.10 Stability Testing

Stability tests were performed on Puritan Fecal Opti-Swab Collection and Transport System to verify the ability of the aged products to maintain microbial recovery up to the expiry date.

5.11 pH Stability

The pH of the test device was measured at predetermined time intervals for up to 15 months after manufacturing date. The test was performed using calibrated pH meter with random samples from three different lots of Puritan Fecal Opti-Swab Collection and Transport System. All samples tested were found to maintain pH within the specified range.

Cytotoxicity 5.12

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

5.13 Sterilization

Puritan Fecal Opti-Swab Collection and Transport System is sterilized by gamma irradiation and validated following ANSI/AAMI/ISO 11137:2006, Sterilization of health care products Radiation guidelines.

5.14 Conclusion

The conclusions drawn from the nonclinical tests demonstrate the device is as safe and effective as the legally marketed device identified above.