(434 days)
No
The device is a conductivity gel, a passive medium for ultrasound transmission. The description focuses on its physical properties and performance as a coupling agent, with no mention of AI/ML in its function or processing. The image processing mentioned is standard ultrasound signal processing, not AI/ML.
No.
The device is a conductivity gel, which is used to facilitate the sound waves of an ultrasound for diagnostic and therapeutic purposes, but the gel itself is not performing the therapy.
No
Explanation: This device is a conductivity gel used to facilitate ultrasound procedures. It does not perform any diagnostic function itself; rather, it enables other diagnostic devices (ultrasound scanners) to function correctly by providing an acoustic pathway.
No
The device is a conductivity gel, which is a physical substance used to facilitate ultrasound transmission. It is not software.
Based on the provided information, the UltraPhonic® Conductivity Gel is not an In Vitro Diagnostic (IVD) device.
Here's why:
- Definition of IVD: An IVD device is a medical device intended for use in vitro for the examination of specimens, including blood, tissue, and urine, derived from the human body, solely or principally for the purpose of providing information concerning a physiological or pathological state, or a congenital abnormality, or to determine the safety and compatibility with potential recipients, or to monitor therapeutic measures.
- Intended Use of UltraPhonic® Conductivity Gel: The intended use clearly states it is a "transmission media for acoustically coupling a transducer to a human body surface during external therapeutic and diagnostic ultrasound imaging procedures." It is applied to the skin or transducer, not used to examine specimens in vitro.
- Mechanism of Action: The gel's function is to facilitate the transmission of sound waves into and out of the body for imaging purposes. It does not analyze or test biological specimens.
While the device is used in conjunction with diagnostic ultrasound procedures, its role is purely as a physical coupling medium, not as a tool for analyzing biological samples.
N/A
Intended Use / Indications for Use
Ultra/Phonic® Conductivity Gel is intended for general use as a non-sterile transmission media for acoustically coupling a transducer to a human body surface during external therapeutic and diagnostic ultrasound imaging procedures. It is placed on the patient's skin or on the transducer prior to initiating an ultrasound examination. The product is indicated for prescription use only.
Product codes
MUI
Device Description
Ultra/Phonic® Conductivity Gel is an aqueous, non-sterile ultrasound conducting medium for use during non-invasive ultrasonic medical procedures. It is placed between the ultrasound transducer and the patient, eliminating air at the contact surface while providing lubrication. This provides an acoustic pathway between the transducer and the skin. This uninterrupted pathway allows the transducer to send sound waves which enter the body, and to receive echoes from tissues and structures without unexpected interference. When the echoes are received by the scanner, it analyzes them to determine how strong they are, and how long they took to be received after transmission. That information is then processed and outputted to a display as an image which is used for diagnostic and therapeutic purposes by health care professionals.
It is packaged in 4L Cubitainers, 5L Cubitainers, 250 mL bottles, and 250 mL tubes.
Major characteristics include:
- Non-sensitizing, non-irritating ●
- Water soluble, non-staining, and easily cleanable
- Does not contain oil or fatty matter
- Has no odor
- Does not damage the probe
- pH level is 6.25 ± 0.25 @ 25°C
- Resists thinning and decomposition when exposed to perspiration and body heat
- Sheer thinning gel is easy to apply, but doesn't run or drip
- High viscosity allows for thick application, adapting to contours and hair to minimize interference
Mentions image processing
That information is then processed and outputted to a display as an image which is used for diagnostic and therapeutic purposes by health care professionals.
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
ultrasound
Anatomical Site
human body surface
Indicated Patient Age Range
Pediatric and adult
Intended User / Care Setting
Hospital
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 performance:
Acoustic: Ultra/Phonic® Conductivity Gel was evaluated for its acoustic performance. Results indicate that the acoustic properties of the gel are: 1. Virtually identical to that of human skin. 2. Similar to other coupling gels commonly used in the United States. The acoustic properties of the predicate gel and Ultra/Phonic® Conductivity Gel are virtually identical.
Antimicrobial Effectiveness Testing: The USP (Category 2) Antimicrobial Effectiveness Test passed with log reductions greater than 5 for all 14 and 28 day bacterial (Staphylococcus aureus ATCC 6538, Escherichia coli ATCC 8739, Pseudomonas aeruginosa ATCC 9027) counts. Yeasts and molds (Aspergillus brasiliensis ATCC 16404, Candida albicans ATCC 10231) did not increase from initial counts, and in fact considerably decreased.
Animal tests: Biocompatibility (ISO 10993-10) testing was conducted for Skin Irritation and Skin Sensitization. Conclusions from these studies: Ultra/Phonic® Conductivity Gel was found to be non-sensitizing and non-irritating.
In Vitro Cytotoxicity: Cytotoxicity (ISO 10993-5:2009) testing was conducted. Conclusion from this study: The test article meets the requirement of the test as per The International Organization for Standardization (ISO 10993-5 Biological Evaluation of Medical Devices – Part 5: Tests for the In Vitro Cytotoxicity, Reference Number ISO 10993-5:2009), and is not considered cytotoxic.
Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)
Log reductions greater than 5 for bacterial counts in antimicrobial effectiveness testing.
Found to be non-sensitizing and non-irritating in skin irritation and sensitization tests.
Not considered cytotoxic in in vitro cytotoxicity testing.
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.
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.
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
§ 892.1570 Diagnostic ultrasonic transducer.
(a)
Identification. A diagnostic ultrasonic transducer is a device made of a piezoelectric material that converts electrical signals into acoustic signals and acoustic signals into electrical signals and intended for use in diagnostic ultrasonic medical devices. Accessories of this generic type of device may include transmission media for acoustically coupling the transducer to the body surface, such as acoustic gel, paste, or a flexible fluid container.(b)
Classification. Class II.
0
Image /page/0/Picture/0 description: The image contains two logos. The logo on the left is the Department of Health & Human Services - USA logo. The logo on the right is the FDA U.S. Food & Drug Administration logo.
Pharmaceutical Innovations, Inc. c/o Shirley J. Bergman Vice President 897 Frelinghuysen Ave. NEWARK, NJ 07114
Re: K163024
Trade/Device Name: Ultra/Phonic Conductivity Gel Regulation Number: 21 CFR 892.1570 Regulation Name: Diagnostic ultrasonic transducer Regulatory Class: Class II Product Code: MUI Dated: December 8, 2017 Received: December 13, 2017
Dear Ms. Bergman:
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 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);
January 8, 2018
1
Page 2 - Shirley J. Bergman
and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Michael D. O'Hara For
Robert A. Ochs, Ph.D. Director Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health
Enclosure
2
Indications for Use
510(k) Number (if known)
Device Name
Ultra/Phonic® Conductivity Gel
Indications for Use (Describe)
UltraPhonic® Conductivity Gel is intended for general use as a non-sterile transmission media for acoustically coupling a transducer to a human body surface during external therapeutic and diagnostic ultrasound imaging procedures. It is placed on the patient's skin or on the transducer prior to initiating an ultrasound examination.
| 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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3
Image /page/3/Picture/1 description: The image is a logo with a blue outline of a square. Inside the square is a stylized letter 'P' that is also outlined in blue. The 'P' is partially encircled by an oval shape, also outlined in blue, that adds a sense of motion or dynamism to the design.
Image /page/3/Picture/3 description: The image shows a logo for the President of the United States Highest Award for Excellence in Exporting. The logo includes a flag with the letter E and a star on it. The text is in blue and is arranged in a way that emphasizes the importance of exporting.
Newark, New Jersey 07114-2195 · (973) 242-2900 · Fax: (97
510(k) Summary
Ultra/Phonic® Conductivity Gel
I. SUBMITTER
Pharmaceutical Innovations, Inc. 897 Frelinghuysen Ave. Newark, New Jersey 07114-2195 Phone: (973) 242-2900 Fax: (973) 242 0578 Contact Person: Ms. Shirley J Bergman Vice President.
Date Prepared: Friday, October 21, 2016
II. DEVICE
Name of Device: Ultra/Phonic® Conductivity Gel
Classification Name: Diagnostic ultrasonic transducer (accessory) (21 CFR § 892.1570)
Regulatory Class: II
Product Code: MUI
III. PREDICATE DEVICE
Device Name: Sonishield™ 100 Antimicrobial Ultrasound Gel
Classification Name: Diagnostic ultrasonic transducer. (21 CFR 892.1570)
Regulatory Class: II
Product Code: MUI
510K Number: K151070
Reference Device: Ecogel 100 Ultrasound Gel
Classification Name: Diagnostic ultrasonic transducer. (21 CFR 892.1570)
Regulatory Class: II Product Code: ITX
510K Number: K961757
4
Image /page/4/Figure/1 description: The image shows a logo with a stylized letter 'H' inside a rounded square. The 'H' is formed by two vertical lines connected by a horizontal stroke, with curved elements at the top. An oval shape surrounds the top portion of the 'H', adding a sense of motion or emphasis. The logo is outlined in blue, providing a clean and distinct appearance against a white background.
Image /page/4/Picture/3 description: The image shows a logo with a flag on the left and text on the right. The flag has the letter "E" on it and a star above it. The text on the right reads "PRESIDENT OF THE UNITED STATES HIGHEST AWARD FOR EXCELLENCE IN EXPORTING". The logo appears to be an award for excellence in exporting.
Avenue · Newark, New Jersey 07114-2195 · (973) 242-2900 · Fax: (973) 242
IV. DEVICE DESCRIPTION
Ultra/Phonic® Conductivity Gel is an aqueous, non-sterile ultrasound conducting medium for use during non-invasive ultrasonic medical procedures. It is placed between the ultrasound transducer and the patient, eliminating air at the contact surface while providing lubrication. This provides an acoustic pathway between the transducer and the skin. This uninterrupted pathway allows the transducer to send sound waves which enter the body, and to receive echoes from tissues and structures without unexpected interference. When the echoes are received by the scanner, it analyzes them to determine how strong they are, and how long they took to be received after transmission. That information is then processed and outputted to a display as an image which is used for diagnostic and therapeutic purposes by health care professionals.
It is packaged in 4L Cubitainers, 5L Cubitainers, 250 mL bottles, and 250 mL tubes.
Major characteristics include:
- Non-sensitizing, non-irritating ●
- Water soluble, non-staining, and easily cleanable
- Does not contain oil or fatty matter
- Has no odor
- Does not damage the probe
- pH level is 6.25 ± 0.25 @ 25°C
- Resists thinning and decomposition when exposed to perspiration and body heat
- Sheer thinning gel is easy to apply, but doesn't run or drip
- High viscosity allows for thick application, adapting to contours and hair to minimize interference
V. INDICATIONS FOR USE
The Indications for Use statement is as follows:
Ultra/Phonic® Conductivity Gel is intended for general use as a non-sterile transmission media for acoustically coupling a transducer to a human body surface during external therapeutic and diagnostic ultrasound imaging procedures. It is placed on the patient's skin or on the transducer prior to initiating an ultrasound examination. The product is indicated for prescription use only.
5
Image /page/5/Figure/1 description: The image is a logo that features a stylized letter 'P' enclosed within an oval shape, all contained within a square border. The letter 'P' is designed with sharp angles and a double-line effect, giving it a modern and geometric appearance. The oval shape encircles the top portion of the 'P', adding a sense of enclosure and unity to the design. The entire logo is rendered in a light blue color, which contributes to a clean and professional aesthetic.
Image /page/5/Picture/3 description: The image shows a logo with a flag and text. The flag has the letter 'E' on it, along with a star. To the right of the flag, the text reads 'PRESIDENT OF THE UNITED STATES HIGHEST AWARD FOR EXCELLENCE IN EXPORTING'.
897 Frelinghuysen Avenue · Newark, New Jersey 07114-2195 · (973) 242-2900 · Fax: (973) 242-0578
VI. COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE DEVICE
Ultra/Phonic® Conductivity Gel has substantially the same technological characteristics as the predicate device, as well as the reference device. The three are compared below:
| Subject | Ultra/Phonic® Conductivity
Gel | Sonishield™ 100
Antimicrobial Ultrasound
Gel | Ecogel 100
Ultrasound Gel |
|--------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------|
| Intended Use | External | External | External |
| INGREDIENTS | Contains salt | Salt free | Salt free |
| | Green coloring | Dye free | Green coloring* |
| | Alcohol free | Alcohol free | Alcohol free |
| | Formaldehyde free | Formaldehyde free | Formaldehyde free |
| | Perfume free | Perfume free | Perfume free |
| | PHYSICAL
PROPERTIES | Twist cap for accurate
dispensing
(Snap-top on Cubitainers) | Twist cap for accurate
dispensing |
| Twist-off top for quick
refilling. Tubes are not
refillable. | | Flip-top can for quick
refilling | Flip-top can for
quick refilling |
| High clarity | | Very high clarity | Good clarity |
| | Bacteriostatic,
nonsensitizing | Hypoallergenic,
bacteriostatic,
nonsensitizing | Hypoallergenic,
bacteriostatic,
nonsensitizing |
| | pH 6.25 ± 0.25 | pH 4.5 - 6.5 | pH 6.5 ± 0.75 |
| CHEMICAL
PROPERTIES | Density (g/mL) = 1.061 | Density (g/mL) = 1.009 | Density (g/mL) =
0.99 |
| | Stabilized, high viscosity
formulation resists melting
and decomposition from
body heat and perspiration,
providing lasting
conductivity with zero or
minimal reapplication. | Very clear screen image
with high viscosity and
vacuum process. No rapid
melting from high
viscosity gel. | It has low
viscosity. It melts
immediately from
low viscosity |
| | Viscosity 600,000 ± 300,000
CPS | Viscosity 80,000 -
120,000 CPS | Viscosity 35,000 -
40,000 CPS |
| | Boiling Point > 200° C | Boiling point > 200° C | Boiling point 100°
C |
| | Water soluble high MW
polymers | Water soluble high MW
polymer | Water soluble high
MW polymer |
| | No irritation | No irritation | No irritation |
| PROCESS | Normal process | It has a rapid
manufacturing process | Normal process |
| Subject | Ultra/Phonic® Conductivity
Gel | Sonishield™ 100
Antimicrobial Ultrasound
Gel | Ecogel 100
Ultrasound Gel |
| | Standard bottle (also
available in tubes, and
Cubitainers for refilling) | Sonishield™ employs a
soft bottle for ease of
use. | Standard bottle |
| | Normal process | Sonishield™ production
employs a closed-loop
system so there is no
pollution transmission.
Product is manufactured
very cleanly | Normal process |
| | Standard production area | Standard production area | Standard
production area |
| | Standard process
manufactured to release
specifications. | Standard process
manufactured to release
specifications. | Standard process |
| LABEL | Standard information | Standard information on
polyethylene label to
prevent loss of lettering | Standard
information |
| DESIGN | Conical cap on bottles and
tubes. Snap top cap on
Cubitainers. | Bottle diameter designed
to be compatible with
ultrasound device. Bottle
cap is designed for ease
of opening and closing
with one hand. | Conical cap |
| SAFETY | Ultra/Phonic® Conductivity
Gel label contains
appropriate warnings and
characteristics | Sonishield™ label
contains appropriate
warnings and
characteristics (Latex
free, PVC-free) | Standard
information |
| ENVIRONMENT
OF USE | Hospital | Hospital | Hospital |
| TARGET
POPULATION | Pediatric and adult | Pediatric and adult | Pediatric and adult |
| USE | Multiple Uses | Multiple uses | Multiple uses |
| MATERIAL
(PACKAGE) | Polyethylene | Polyethylene | Polyethylene |
| PATIENT
CONTACT
MATERIALS | Probe | Probe | Probe |
6
Image /page/6/Figure/1 description: The image shows a logo with a stylized letter 'H' inside a square with rounded corners. An oval shape surrounds the top portion of the 'H', adding a dynamic element to the design. The logo is outlined in blue, providing a clean and professional look.
CEUTICAL PHARN INNING TONS, INC
Image /page/6/Picture/3 description: The image shows a logo with a flag on the left side and text on the right side. The flag has the letter "E" and a star on it. The text on the right side says "PRESIDENT OF THE UNITED STATES HIGHEST AWARD FOR EXCELLENCE IN EXPORTING".
897 Frelinghuysen Avenue · Newark, New Jersey 07114-2195 · (973) 242-2900 · Fax: (973) 242-0578
7
Image /page/7/Figure/19 description: The image is a logo that features a stylized letter "P" enclosed within an oval shape, all rendered in blue lines. The "P" is designed with a unique, almost double-lined effect, giving it a modern and abstract appearance. The oval shape surrounds the "P", adding a sense of containment and focus to the central element. The entire logo is set against a white background, which provides a clean and contrasting backdrop that makes the blue lines stand out.
Image /page/7/Picture/3 description: The image shows a logo with a flag on the left and text on the right. The flag has the letter "E" on it and a star above it. The text on the right reads "PRESIDENT OF THE UNITED STATES HIGHEST AWARD FOR EXCELLENCE IN EXPORTING".
Newark, New Jersey 07114-2195 · (973) 242-2900 · Fax: (97
| Subject | Ultra/Phonic® Conductivity
Gel | SonishieldTM 100
Antimicrobial Ultrasound
Gel | Ecogel 100
Ultrasound Gel |
|-------------|-----------------------------------------------|-----------------------------------------------------|--------------------------------------------------|
| ENERGY TYPE | Electricity only for the
ultrasound device | Electricity only for the
ultrasound device | Electricity only for
the ultrasound
device |
- The predicate device 510K (K151070) summary lists Ecogel 100 as not containing dye, while the Konix Ultrasound Gel (K101952) 510K summary, which also used Ecogel 100 as a predicate, lists Ecogel 100 as being dyed green. It is in fact, dyed green.
VII. PERFORMANČE DATA
The following performance data was provided in support of the substantial equivalence determination.
Non-clinical performance
Acoustic:
Ultra/Phonic® Conductivity Gel was evaluated for its acoustic performance. Results indicate that the acoustic properties of the gel are:
-
- Virtually identical to that of human skin.
-
- Similar to other coupling gels commonly used in the United States.
The acoustic properties of Ultra/Phonic® Conductivity Gel and Sonishield™ 100 Antimicrobial Ultrasound Gel are as follows:
| Property | Ultra/Phonic®
Conductivity Gel | Sonishield™ 100
Antimicrobial
Ultrasound Gel |
|-------------------------------------------------------------------------|-----------------------------------|----------------------------------------------------|
| Sound velocity (m/sec) | 1594.2 ms-1 at 22.5°C | 1497 ms-1 at 30°C |
| Density (kg/m3) | 1061 kg/ m3 at 22.5°C | 1023 kg/ m3 at 30°C |
| Acoustic impedance (kg/m2 sec) | 1.69 MRayls at 22.5°C | 1.53 MRayls at 30°C |
| Attenuation coefficient as a function of
frequency, a/f (dB/(cm-MHz) | $0.05 + 0.01148 f^{1.213}$ | $0.04 \pm 0.0042 f$ |
The acoustic properties of the predicate gel and Ultra/Phonic® Conductivity Gel are virtually identical. Although the analysis was conducted at different temperatures, both are well within the range of temperatures encountered during clinical use (72.5°F - 80°F). Such variations in temperature do not induce more than small changes in the listed acoustic properties, too small to alter performance, or cast doubt upon the conclusions of this comparison.
Antimicrobial Effectiveness Testing:
The USP (Category 2) Antimicrobial Effectiveness Test passed with log reductions greater than 5 for all 14 and 28 day bacterial (Staphylococcus aureus ATCC 6538, Escherichia coli ATCC 8739, Pseudomonas aeruginosa ATCC 9027) counts. Yeasts and molds (Aspergillus brasiliensis ATCC 16404, Candida albicans ATCC 10231) did not increase from initial counts, and in fact considerably decreased.
8
Image /page/8/Figure/1 description: The image shows a logo with a stylized letter 'H' inside a square frame. An oval shape surrounds the top of the 'H', adding a dynamic element to the design. The logo is rendered in a light blue color, providing a clean and professional appearance.
Image /page/8/Picture/3 description: The image shows a logo with a flag on the left and text on the right. The flag has the letter "E" on it and a star. The text on the right reads "PRESIDENT OF THE UNITED STATES HIGHEST AWARD FOR EXCELLENCE IN EXPORTING".
Avenue · Newark, New Jersey 07114-2195 · (973) 242-2900 · Fax: (973) 242
Animal tests:
Biocompatibility (ISO 10993-10) testing was conducted for Skin Irritation and Skin Sensitization. Conclusions from these studies: Ultra/Phonic® Conductivity Gel was found to be non-sensitizing and non-irritating.
In Vitro Cytotoxicity:
Cytotoxicity (ISO 10993-5:2009) testing was conducted.
Conclusion from this study: The test article meets the requirement of the test as per The International Organization for Standardization (ISO 10993-5 Biological Evaluation of Medical Devices – Part 5: Tests for the In Vitro Cytotoxicity, Reference Number ISO 10993-5:2009), and is not considered cytotoxic.
VIII. CONCLUSIONS
The above-referenced comparisons of the technological and non-clinical performance characteristics indicate that the Ultra/Phonic® Conductivity Gel is comparable to its predicate and reference devices and certainly substantially equivalent to them and other ultrasonic coupling gels commonly used in the United States today.