AN87 Dosimeter is a single-use color change chemical indicator that is calibrated for sterilization temperature and used to verify adequate cumulative ethylene oxide exposure in the 12 hour sterilization cycle at 20-29°C in the Anprolene AN75 Ethylene Oxide Gas Sterilizer manufactured by Andersen Sterilizers, Inc.

Device Description

The AN87 Dosimeter is a single-use chemical indicator for cumulative ethylene oxide exposure. It is an accessory for the Anprolene AN75 Ethylene Oxide Gas Sterilizer.

The AN87 Dosimeter contains a proprietary pH indicator in a glass capillary tube that is sealed on one end and mounted on a plastic tray. It is calibrated for a 20-29°C sterilization temperature, and responds to ethylene oxide concentration and sterilization time. With exposure to ethylene oxide, the indicator turns from yellow-orange to a dark blue color from the open end toward the closed end. The extent of the color change is proportional to the cumulative ethylene oxide exposure. The calibration mark represents adequate cumulative ethylene oxide exposure to inactivate a 6-Log Bacillus atrophaeus biological indicator at the location of the AN87 Dosimeter. The AN87 Dosimeter is not a replacement for a biological indicator.

AI/ML Overview

The provided text describes the AN87 Dosimeter, a single-use chemical indicator for verifying adequate cumulative ethylene oxide exposure in the Anprolene AN75 Ethylene Oxide Gas sterilizer. The device is claimed to be substantially equivalent to the predicate AN1087 Dosimeter (K150645).

Here's an analysis of the acceptance criteria and study information based on the provided text:

1. Table of Acceptance Criteria and Reported Device Performance

The acceptance criteria are derived from the performance testing described in section 5.9 of the 510(k) summary, specifically from Table 5-3.

Acceptance Criteria (Test Description)	Reported Device Performance (Result)
Functionality:	Pass:
1. Critical parameters include temperature, time, and gas concentration at a relative humidity of 35-90%.	Performance characterized in an Andersen Chemical Indicator Evaluator Resistometer and in an Anprolene AN75 Ethylene Oxide Gas Sterilizer using the 12-hour cycle at 20-29°C. The critical parameters to which the AN87 responds include temperature, time, and gas concentration in a relative humidity controlled environment.
2. Performance parallels that of a biological indicator.	The AN87 indicates adequate cumulative EO exposure in the cycle for all validated loads in the Anprolene AN75 sterilizer. The AN87 performance parallels the performance of a 6-Log Bacillus atrophaeus biological indicator.
3. A correlation exists between the extent the blue color travels and cumulative EO exposure.	A strong correlation is observed between cumulative EO exposure and the distance the blue color travels in the AN87 Dosimeter.
Biocompatibility: Not direct or indirect patient-contacting devices; Non-toxic ingredients; Provides reasonable assurance for safety.	Pass: Not direct or indirect patient-contacting devices; Non-toxic ingredients; Provides reasonable assurance for safety. (This is a statement of compliance rather than a test result.)
Endpoint Color Stability: Stable for at least 28 days at 20-25°C; Stability demonstrates reasonable assurance for effectiveness.	Pass: Using the AN87 Dosimeter at various stages of shelf life, the distance the blue line travels is stable for a minimum of 28 days after the sterilization cycle when AN87 Dosimeters are stored at room temperature (20-25°C).
Shelf Life: Maintains performance specifications throughout the stated shelf life of 3 years.	Pass: Real-time shelf stability testing with the AN87 Dosimeter supports a shelf life of 3 years.

2. Sample size used for the test set and the data provenance

The document does not specify the sample size used for the test set for any of the performance tests. It also does not explicitly state the data provenance (e.g., country of origin). The testing was conducted by Andersen Sterilizers, Inc., the manufacturer, implying internal data collection. The tests sound like prospective laboratory experiments rather than retrospective analysis of existing data.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

The document does not provide information on the number or qualifications of experts used to establish the ground truth for the test set.

4. Adjudication method for the test set

The document does not describe any adjudication method for the test set.

5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

A multi-reader multi-case (MRMC) comparative effectiveness study was not done. This device is a chemical indicator, not an AI-assisted diagnostic tool for human readers.

6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

Yes, standalone performance testing was done. The device itself (the AN87 Dosimeter, which is a chemical indicator and not an algorithm in the typical software sense) provides a direct visual indication (color change). The performance tests described characterize the device's ability to accurately reflect cumulative EO exposure without human interpretation beyond observing the color change against a calibration mark. The "algorithm" here is the chemical reaction itself.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

The ground truth for the functionality testing was established by correlating the AN87 Dosimeter's color change with:

The critical process parameters of the sterilization cycle (temperature, time, gas concentration, humidity).
The performance of a 6-Log Bacillus atrophaeus biological indicator, which is a widely accepted standard for demonstrating sterilization efficacy. This acts as the direct ground truth for sterilization effectiveness.

8. The sample size for the training set

The concept of a "training set" is not applicable in the context of this chemical indicator. Chemical indicators operate based on predetermined chemical reactions and calibration, not machine learning or AI models that require training data.

9. How the ground truth for the training set was established

As there is no training set for this device, this question is not applicable. The device's calibration and performance are validated against physical and biological standards.

Summary

{0}------------------------------------------------

Image /page/0/Picture/0 description: The image contains the logos of the Department of Health & Human Services and the Food and Drug Administration (FDA). The Department of Health & Human Services logo is on the left, and the FDA logo is on the right. The FDA logo is a blue square with the letters "FDA" in white, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue.

November 1, 2017

Andersen Sterilizers, Inc. William Andersen President 3154 Caroline Drive Haw River, North Carolina 27258

Re: K170439

Trade/Device Name: AN87 Dosimeter Regulation Number: 21 CFR 880.2800 Regulation Name: Sterilization Process Indicator Regulatory Class: Class II Product Code: JOJ Dated: September 28, 2017 Received: October 6, 2017

Dear William Andersen:

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); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

U.S. Food & Drug Administration 10903 New Hampshire Avenue Silver Spring, MD 20993 www.fda.qov

{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 (DICE) at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevicesforYou/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 (DICE) 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,

Michael J. Ryan -S

for Tina Kiang Acting Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control, and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

{2}------------------------------------------------

DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

indica

Device Name AN87 Dosimeter

Indications for Use (Describe)

Critical process parameters for the cycle are summarized in Table 1.

Table 1. Critical sterilization cycle parameters in the Anprolene AN75 Ethylene Oxide Gas Sterilizer

Ethylene Oxide	Temperature	Relative Humidity	Ethylene Oxide Exposure Time	Total Cycle Time
17.6 g $\pm$ 5%	20-29°C	35-90%	12 hours	14 hours

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}------------------------------------------------

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

{4}------------------------------------------------

K170439 510(k) Summary

5.1 Applicant's Name and Address	Andersen Sterilizers, Inc.Establishment Registration Number 30046347103154 Caroline DriveHaw River, NC 27258
5.2 Contact Person	William K. Andersen, BE, MD, FAAOSPresidentPhone: 336-376-8622; Fax: 336-376-5428
5.3 Date of Preparation	September 28, 2017
5.4 Device
	Proprietary Name AN87 Dosimeter®Common Name Indicator, Physical/Chemical Sterilization ProcessClassification Class II (21 CFR 880.2800) Chemical IndicatorProduct Code JOJ
5.5 Predicate Device
	Device Name AN1087 Dosimeter®510(k) number K150645Manufacturer Andersen Sterilizers, Inc.

The predicate AN1087 Dosimeters are approved for use with the EOGas 4® Ethylene Oxide Gas Sterilization system manufactured by Andersen Sterilizers, Inc.

The sterilization temperature and time claims of the predicate devices were modified in order to indicate the AN87 Dosimeters for use in the Anprolene Oxide Gas Sterilization System. No modifications were made to the manufacturing method, technology, or intended use.

5.6 Device Description

The AN87 Dosimeter is a single-use chemical indicator for cumulative ethylene oxide exposure. It is an accessory for the Anprolene AN75 Ethylene Oxide Gas Sterilizer.

{5}------------------------------------------------

5.7 Indications for Use

Critical process parameters for the cycle are summarized in Table 5-1.

Table 5-1. Critical sterilization cycle parameters in the Anprolene AN75 Ethylene Oxide Gas Sterilizer

Ethylene Oxide	Temperature	RelativeHumidity	Ethylene OxideExposure Time	Total Cycle Time
17.6 g ± 5%	20-29°C	35-90%	12 hours	14 hours

5.8 Substantial Equivalence Comparison

The AN87 Dosimeter is substantially equivalent to the predicate device - AN1087 Dosimeter (K150645): there is no difference in intended use, design, technical characteristics, or performance between the devices. The differences between the AN1087 and AN87 Dosimeters are the sterilization temperature and time in the indications for use; the differences raise no issues related to safety or effectiveness because the devices are calibrated and validated for the sterilization temperatures and times claimed. A comparison between the indicators is listed in Table 5-2.

	Predicate AN1087 Dosimeter(K150645)	Subject AN87 Dosimeter	Comparison
Intended Use	Chemical indicator forcumulative EO exposure in theEOGas 4 sterilizer	Chemical indicator forcumulative EO exposure in theAnprolene AN75 sterilizer	SubstantiallyEquivalent
Design	A pH indicator changes colorwhen exposed to EO;The extent of the color changesis proportional to cumulativeEO exposure;Calibrated for use at 50±3°C.	A pH indicator changes colorwhen exposed to EO;The extent of the colorchanges is proportional tocumulative EO exposure;Calibrated for use at 20-29°C.	SubstantiallyEquivalent
Technology	Chemical reactions with EOchange the pH, and thereforethe color, of the indicator ink	Chemical reactions with EOchange the pH, and thereforethe color, of the indicator ink	Identical
Performance	Accurately indicatescumulative EO exposure	Accurately indicatescumulative EO exposure	Equivalent
Shelf Life	3 years	3 years	Equivalent
EndpointSpecifications	Endpoint blue color is stablefor at least 28 days at 20-25°C	Endpoint blue color is stablefor at least 28 days at 20-25°Cand 3 days at 50°C	Equivalent

Table 5-2. Comparison between AN87 Dosimeter and the predicate AN1087 Dosimeter

{6}------------------------------------------------

5.9 Performance Testing

The AN87 Dosimeters were validated using applicable tests in:

1. FDA 2003 guideline, "Premarket Notification [510(k)] Submissions for Chemical Indicators: Guidance for Industry and FDA Staff"; and
1. AAMI/ANSI/ISO 11140-1, "Sterilization of health care products Chemical Indicators -Part 1: General requirements" (FDA Recognition Number 14-459).

The performance of the AN87 Dosimeter was characterized in an Andersen Chemical Indicator Evaluator Resistometer as well as in an Anprolene AN75 Ethylene Oxide Gas Sterilizer using the 12 hour cycle at 20-29°C. The critical parameters to which the AN87 responds include temperature, time, and gas concentration in a relative humidity controlled environment. The AN87 indicates adequate cumulative EO exposure in the cycle for all validated loads in the Anprolene AN75 sterilizer. The AN87 performance parallels the performance of a 6-Log Bacillus atrophaeus biological indicator. A strong correlation is observed between cumulative EO exposure and the distance the blue color travels in the AN87 Dosimeter. Using the AN87 Dosimeter at various stages of shelf life, the distance the blue line travels is stable for a minimum of 28 days after the sterilization cycle when AN87 Dosimeters are stored at room temperature (20-25°C). Real-time shelf stability testing with the AN87 Dosimeter supports a shelf life of 3 years.

Performance testing is summarized in Table 5-3.

Test	Description	Result
Functionality	1) Critical parameters include temperature, time, and gas concentrationat a relative humidity of 35-90%;2) Performance parallels that of a biological indicator;3) A correlation exists between the extent the blue color travels andcumulative EO exposure.	Pass
Biocompatibility	Not direct or indirect patient-contacting devices;Non-toxic ingredients;Provides reasonable assurance for safety	Pass
Endpoint ColorStability	Stable for at least 28 days at 20-25°C;Stability demonstrates reasonable assurance for effectiveness	Pass
Shelf Life	Maintains performance specifications throughout the stated shelf life of3 years	Pass

Table 5-3. Summary of bench tests performed to demonstrate safety and effectiveness of the AN87 Dosimeter

The nonclinical tests demonstrate that the AN87 Dosimeter, used in the Anprolene AN75 Ethylene Oxide Gas Sterilizer, is as safe, as effective, and performs as well as the legally marketed device, the AN1087 Dosimeter (K150645) used in the EOGas 4 Ethylene Oxide Gas Sterilizer.

Regulation Number and Section

§ 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).