K Number
K171499
Device Name
Occlusion Detection Dressing Kit
Manufacturer
Date Cleared
2017-09-22

(122 days)

Product Code
Regulation Number
878.4780
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The Cardinal Health NPWT device is an integrated wound management system, indicated for the application of continual or intermittent negative pressure wound therapy. The system may promote wound healing by the removal of fluids, including wound exudates, irrigation fluids and infectious materials. The system is intended for patients with chronic, acute, traumatic, subacute and dehisced wounds, partial-thickness burns, ulcers (such as diabetic or pressure), flaps and grafts. The system is intended for use in acute, extended and home care settings.
Device Description
The Cardinal Health NPWT system consists of a powered suction pump device that provides continuous or intermittent negative pressure (SVED – K142916, PRO/PRO to GO/PRO at HOME – K143016, PRO HC – K150124) with a built-in placement holder for the fluid collection canister, various sizes and shapes of polyurethane foam dressing, canister tubing with clamps and connectors, polyurethane drape with adhesive, and fluid collection canisters. The pump devices are AC-powered, portable suction devices with battery backup that provide localized negative pressure to remove fluids and infectious materials from the wound. The devices must be used with the Cardinal Health NPWT dressing kits, which are available in various foam sizes. Each Cardinal Health NPWT dressing kit contains an occlusion detection tubing set. various sizes of polyurethane foam, and a polyurethane drape with adhesive. The purpose of this submission is to modify 1) the tubing in the dressing kits and 2) the disposable fluid collection canister to allow detection of blockage or an occlusion that may occur in the dressing or within the tubing, which in turn triggers an alarm on the pump. The modification consists of a dual lumen tubing set with a twist and lock port that attaches to a disposable fluid collection canister. The canister is modified with three ports in the cap of the canister. One port accepts the twist and lock end of the tubing set for collection of exudate from the wound, and two ports connects to sensors within the pump device. The modifications to the tubing set and the fluid collection canister cap do not require any software or hardware changes to the NPWT pump devices. There are no changes to the Indications for Use for any of the NPWT devices.
More Information

No
The description focuses on mechanical and sensor-based modifications for occlusion detection, with no mention of AI or ML algorithms for data analysis or decision-making.

Yes
The "Intended Use / Indications for Use" section explicitly states that the device is "an integrated wound management system, indicated for the application of continual or intermittent negative pressure wound therapy. The system may promote wound healing by the removal of fluids..." and is intended for various types of wounds, ulcers, flaps, and grafts. These functions are therapeutic.

No

The device is a therapeutic device for wound management (Negative Pressure Wound Therapy), not a diagnostic device. It promotes healing by removing fluids and infectious materials from wounds and includes features for detecting blockages, but it does not diagnose medical conditions.

No

The device description explicitly states that the system consists of a powered suction pump device, dressing kits, canister tubing, polyurethane drape, and fluid collection canisters, all of which are hardware components. The submission focuses on modifications to the tubing and canister, which are also hardware.

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In Vitro Diagnostic devices are used to examine specimens taken from the human body (like blood, urine, or tissue) to provide information for diagnosis, monitoring, or screening.
  • Device Function: The Cardinal Health NPWT device is a wound management system that applies negative pressure to a wound to remove fluids and promote healing. It works directly on the wound itself, not by analyzing a specimen taken from the body.
  • Intended Use: The intended use clearly describes a system for wound healing and fluid removal, not for diagnostic testing of bodily fluids or tissues.
  • Device Description: The description details a pump, dressings, tubing, and canisters for collecting wound exudate. These components are for applying therapy and managing the wound environment, not for performing diagnostic tests.

The device is a therapeutic device used for wound management, not a diagnostic device.

N/A

Intended Use / Indications for Use

The Cardinal Health NPWT device is an integrated wound management system, indicated for the application of continual or intermittent negative pressure wound therapy. The system may promote wound healing by the removal of fluids, including wound exudates, irrigation fluids and infectious materials. The system is intended for patients with chronic, acute, traumatic, subacute and dehisced wounds, partial-thickness burns, ulcers (such as diabetic or pressure), flaps and grafts. The system is intended for use in acute, extended and home care settings.

Product codes

OMP

Device Description

The Cardinal Health NPWT system consists of a powered suction pump device that provides continuous or intermittent negative pressure (SVED – K142916, PRO/PRO to GO/PRO at HOME – K143016, PRO HC – K150124) with a built-in placement holder for the fluid collection canister, various sizes and shapes of polyurethane foam dressing, canister tubing with clamps and connectors, polyurethane drape with adhesive, and fluid collection canisters. The pump devices are AC-powered, portable suction devices with battery backup that provide localized negative pressure to remove fluids and infectious materials from the wound. The devices must be used with the Cardinal Health NPWT dressing kits, which are available in various foam sizes. Each Cardinal Health NPWT dressing kit contains an occlusion detection tubing set. various sizes of polyurethane foam, and a polyurethane drape with adhesive.

The purpose of this submission is to modify 1) the tubing in the dressing kits and 2) the disposable fluid collection canister to allow detection of blockage or an occlusion that may occur in the dressing or within the tubing, which in turn triggers an alarm on the pump. The modification consists of a dual lumen tubing set with a twist and lock port that attaches to a disposable fluid collection canister. The canister is modified with three ports in the cap of the canister. One port accepts the twist and lock end of the tubing set for collection of exudate from the wound, and two ports connects to sensors within the pump device. The modifications to the tubing set and the fluid collection canister cap do not require any software or hardware changes to the NPWT pump devices. There are no changes to the Indications for Use for any of the NPWT devices.

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

acute, extended and home care settings.

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

Bench Testing
The following testing has been conducted to verify that the modifications of the Dressing Kit and Canister, allowing the detection of a blockage or occlusion, will perform as intended with the Cardinal Health NPWT devices:

  • Proper functioning of device features and alarms
  • Pressure stability testing
  • Exudate removal testing
  • Usability testing

The performance data demonstrate that the modifications to the NPWT Dressing Kit and Canister function as intended with no change in safety or effectiveness of the system and are considered substantially equivalent to the predicate device.

Key Metrics

Not Found

Predicate Device(s)

K150124 Cardinal Health NPWT PRO HC

Reference Device(s)

K142916, K143016

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 878.4780 Powered suction pump.

(a)
Identification. A powered suction pump is a portable, AC-powered or compressed air-powered device intended to be used to remove infectious materials from wounds or fluids from a patient's airway or respiratory support system. The device may be used during surgery in the operating room or at the patient's bedside. The device may include a microbial filter.(b)
Classification. Class II.

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Image /page/0/Picture/2 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 an abstract symbol that resembles a stylized caduceus or a series of human profiles facing to the right.

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

September 22, 2017

Cardinal Health Beth Foster Regulatory Affairs Manager 1500 S Waukegan Rd Waukegan, Illinois 60085

Re: K171499

Trade/Device Name: Occlusion Detection Dressing Kit Regulation Number: 21 CFR 878.4780 Regulation Name: Powered Suction Pump Regulatory Class: Class II Product Code: OMP Dated: August 29, 2017 Received: August 30, 2017

Dear Beth Foster:

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

1

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 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. 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,

David Krause -S

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

Enclosure

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Indications for Use

510(k) Number (if known) K171499

Device Name

Cardinal Health NPWT Occlusion Detection Dressing Kit and Canister

Indications for Use (Describe)

The Cardinal Health NPWT device is an integrated wound management system, indicated for the application of continual or intermittent negative pressure wound therapy. The system may promote wound healing by the removal of fluids, including wound exudates, irrigation fluids and infectious materials. The system is intended for patients with chronic, acute, traumatic, subacute and dehisced wounds, partial-thickness burns, ulcers (such as diabetic or pressure), flaps and grafts. The system is intended for use in acute, extended and home care settings.

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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Image /page/3/Picture/0 description: The image shows the logo for Cardinal Health. The logo consists of a red graphic element above the company name. The graphic element is composed of three curved lines that converge at a point. The text "CardinalHealth" is written in a sans-serif font, with "Cardinal" in a darker shade than "Health".

Cardinal Health NPWT Dressing Kit and Canister Modification Traditional 510(k)

510(K) SUMMARY OF SAFETY AND EFFECTIVENESS

Cardinal Health NPWT Occlusion Detection Dressing Set and Canister

(A summary of safety and effectiveness information in accordance with the requirements of 21

510(k) Number:K171499
Applicant:Cardinal Health
1500 S Waukegan Road
Waukegan, IL 60085
Establishment
Registration Number:3006367520
Regulatory Affairs
Contact:Beth Foster
Telephone:954-585-5145
Fax:N/A
E-mail:beth.foster@cardinalhealth.com
Date Summary Prepared:May 22, 2017
Trade Name:Cardinal Health NPWT Occlusion Detection Dressing Kit and Canister
Common Name:Negative Pressure Wound Therapy Dressing Kit and Canister
Classification Name:Powered Suction Pump (21 CFR 878.4780)
Classification Panel:General & Plastic Surgery
Regulatory Class:Class II
Product Code(s):OMP
Legally marketed device(s) to which equivalence is claimed:K150124 Cardinal Health NPWT PRO HC
Reason for 510(k) Submission:Modification of the tubing and fluid canister to allow detection of blockage or an occlusion that may occur in the dressing or within the tubing, which in turn triggers an alarm on the pump.
Device Description:The Cardinal Health NPWT system consists of a powered suction pump device that provides continuous or intermittent negative pressure (SVED – K142916, PRO/PRO to GO/PRO at HOME – K143016, PRO HC – K150124) with a built-in placement holder for the fluid collection canister, various sizes and shapes of polyurethane foam dressing, canister tubing with clamps and connectors, polyurethane drape with adhesive, and fluid collection

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Image /page/4/Picture/0 description: The image shows the logo for Cardinal Health. The logo consists of a stylized red bird-like design above the company name. The text "CardinalHealth" is written in a sans-serif font, with the first letter capitalized and the rest in lowercase.

Cardinal Health NPWT Dressing Kit and Canister Modification Traditional 510(k)

canisters. The pump devices are AC-powered, portable suction devices with battery backup that provide localized negative pressure to remove fluids and infectious materials from the wound. The devices must be used with the Cardinal Health NPWT dressing kits, which are available in various foam sizes. Each Cardinal Health NPWT dressing kit contains an occlusion detection tubing set. various sizes of polyurethane foam, and a polyurethane drape with adhesive.

The purpose of this submission is to modify 1) the tubing in the dressing kits and 2) the disposable fluid collection canister to allow detection of blockage or an occlusion that may occur in the dressing or within the tubing, which in turn triggers an alarm on the pump. The modification consists of a dual lumen tubing set with a twist and lock port that attaches to a disposable fluid collection canister. The canister is modified with three ports in the cap of the canister. One port accepts the twist and lock end of the tubing set for collection of exudate from the wound, and two ports connects to sensors within the pump device. The modifications to the tubing set and the fluid collection canister cap do not require any software or hardware changes to the NPWT pump devices. There are no changes to the Indications for Use for any of the NPWT devices.

The Cardinal Health NPWT device is an integrated wound Indications for Use: management system, indicated for the application of continual or intermittent negative pressure wound therapy. The system may promote wound healing by the removal of fluids, including wound exudates, irrigation fluids, body fluids and infectious materials. The system is intended for patients with chronic, acute, traumatic, subacute and dehisced wounds, partial-thickness burns, ulcers (such as diabetic or pressure), flaps and grafts. The system is intended for use in acute, extended and home care settings.

Characteristics
FeatureCardinal Health NPWT Dressing Kit
with Occlusion DetectionCardinal NPWT PRO HC Dressing
Kit without Occlusion Detection
K150124
Indications for UseSame as predicateThe Cardinal Health NPWT SVED
PRO Family and PRO HC are
integrated wound management
systems, indicated for the
application of continual or
intermittent negative pressure
wound therapy to the wound as the
device may promote wound healing
by the removal of fluids, including
wound exudates, irrigation fluids,
body fluids and infectious materials.
The system is intended for patients
with chronic, acute, traumatic,
subacute and dehisced wounds,
partial-thickness burns, ulcers (such
as diabetic pressure), flaps and
grafts. The system is intended for
use in acute, extended and home
care settings.
Product CodeOMPOMP
Patient PopulationSame as predicateAdult single patient
Environment of UseSame as predicateHospitals, Clinics, Long Term Care
and Home Care settings
Used in conjunction with Cardinal
Health NPWT pump devicesSame as predicateYes
Alarms• Low Pressure/Leak
• Canister Full/Blockage
• Low Battery• Low Pressure/Leak
• Canister Full
• Low Battery
DrapeSame as predicatePolyurethane film with gentle
acrylic adhesive
Foam DressingsSame as predicate• Black foam (Polyurethane),
Hydrophobic, Open pore structure
(400-600 microns) with multiple
foam sizes:
Sm: 10x8x3 cm
Med: 20x12.5x3cm
Lg: 25x15x3cm
XLg: 58.5x33x3cm
• White foam hydrophilic, high
density, smaller pore size, flexible
wet or dry
• Black foam (Polyurethane),
Hydrophobic, Open pore structure
(600-900 microns)
Strips -25x3.8 x1.3 cm
Tubing• Polyurethane tubing with ABS
plastic port
• Dual lumen tubing with
SpeedConnect
• Twist and lock port for
attachment to canister• Polyvinyl chloride tubing with
French connect port
• Single lumen tubing with
SpeedConnect
• French connect port to attach for
attachment to canister
Canister• Twist and lock port for
attachment to tubing
• Porous hydrophobic filter to
prevent fluid ingress
• 300cc and 500cc canister volume• Grommet port for attachment to
tubing
• Porous hydrophobic filter to
prevent fluid ingress
• 300cc and 500cc canister volume
BiocompatibilityNon-cytotoxic
Non-sensitizing
Non-irritatingNon-cytotoxic
Non-sensitizing
Non-irritating
SterilizationSame as predicateEtO Sterilization

Comparison of Technological otomiation

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Image /page/5/Picture/0 description: The image contains the Cardinal Health logo. The logo consists of a stylized red graphic above the text "CardinalHealth". The graphic is composed of several curved lines that converge at a point, resembling a stylized bird in flight or a medical symbol. The text is in a sans-serif font, with "Cardinal" in a slightly larger and bolder font than "Health".

Cardinal Health NPWT Dressing Kit and Canister Modification Traditional 510(k)

Performance Data

The following performance data were provided in support of the substantial equivalence determination. There were no Clinical or

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| CardinalHealth | Cardinal Health NPWT Dressing Kit and Canister Modification
Traditional 510(k) |
|----------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | Animal Performance Studies required for substantial equivalence
determination. |
| | Bench Testing
The following testing has been conducted to verify that the
modifications of the Dressing Kit and Canister, allowing the
detection of a blockage or occlusion, will perform as intended with
the Cardinal Health NPWT devices: |
| | Proper functioning of device features and alarms

Pressure stability testing

Exudate removal testing

Usability testing
● |
| Conclusions | The performance data demonstrate that the modifications to the
NPWT Dressing Kit and Canister function as intended with no
change in safety or effectiveness of the system and are considered |

substantially equivalent to the predicate device.