K Number
K172062
Device Name
AllergiEnd ST-9 Multiple Skin Test Applicator, AllergiEnd ST-9 Multiple Well Test Tray
Date Cleared
2018-03-05

(241 days)

Product Code
Regulation Number
880.5570
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The skin test applicator is used for conventional administration (percutaneous application of allergenic extracts directly onto the surface of the skin) of diagnostic allergen extracts for performing allergy skin tests on the typical sites (the back and the volar surfaces of the forearms) for hypersensitivity reactions in individuals suspected of having allergies. The test tray is intended to hold allergenic extracts in a convenient arrangement for storage and use by the clinician.
Device Description
The AllergiEnd allergy skin testing products are supplied sterile and consist of two (2) devices: - Test Applicator - Test Tray The MedScience AllergiEnd Applicator and Tray are used together for the conventional percutaneous application of substance directly onto the surface of the skin of diagnostic allergen extracts for performing skin tests for hypersensitivity reactions in individuals suspected of having allergies. The AllergiEnd ST-9 Applicator has nine (9) test heads arranged in an asymmetrical design two (2) rows of four (4) test heads and a distal ninth test head. The test heads are labeled 1 through 9. Each of the 9 test heads has a "leg." At the tip of each leg is an array of nine (9) protruding test points (tines). The tines utilize capillary action to hold the allergenic material for percutaneous delivery when the applicator is applied to the skin. The test heads are designed to fit into the matching asymmetrical well design of the AllergiEnd ST-9 Test Tray. The applicator loads the allergen from each well in the tray on to each test head. The wells are numbered 1 to 9 to match the numbering on the applicator. When properly applied to the skin, the applicator will leave visible indentations in the patient's skin corresponding to the 9 test heads of each applicator is not intended to pierce the skin. The asymmetric design of the wells allows for only one possible orientation for the applicator to be placed in the tray. It is believed that the asymmetric design may help reduce the potential for operator error inherent in a symmetrical design and may also help the clinician avoid misreading of the skin reactions to the applied allergens. The tray is configured to hold either 36 or 72 test allergens in individual wells. The groups of wells, either 4 groups for 36 test wells or 8 groups for 72 test wells, determine the tray configuration. The clinician's testing preferences will determine which tray configuration to consider. The AllergiEnd ST-9 Multiple Well Test Tray is intended to hold small quantities of allergenic extracts in a convenient arrangement for storage and use. The Test Tray is not preloaded with allergens. The allergens are separately sourced and loaded by the clinician. Regardless of the number of wells, the test tray does not come in direct contact with the patient. The individual wells are numbered with an easily readable alpha-numeric system to facilitate recording reactions to specific allergens. By including an alpha-numeric numbering system in the AllergiEnd ST-9 Multiple Well Test Tray the test administrator has a clear organizational structure for locating each allergen and tracking the patient's response and for correctly documenting in the patient's medical records. The AllergiEnd ST-9 Multiple Well Test Tray also includes a locking lid that engages with a flexible seal. The locking/sealing cover protects the physician-filled allergenic material from contamination and evaporation. Additionally, the locking feature provides for secure handling. The locking feature does not affect the medical procedure, nor does it have any direct interaction with any of the allergenic extracts.
More Information

Not Found

No
The device description and performance studies focus on the mechanical aspects of allergen application and do not mention any computational or data-driven components indicative of AI/ML.

No.

This device is used for diagnostic purposes (performing allergy skin tests), not for treating or alleviating a medical condition.

Yes

The "Intended Use / Indications for Use" section explicitly states that the device is for "conventional administration... of diagnostic allergen extracts for performing allergy skin tests... for hypersensitivity reactions in individuals suspected of having allergies." The purpose of an allergy skin test is to diagnose allergies.

No

The device description clearly outlines physical components (Test Applicator and Test Tray) with specific mechanical features (test heads, tines, wells, locking lid, seal) designed for the physical application and storage of allergenic extracts. There is no mention of any software component.

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

Here's why:

  • IVD Definition: In vitro diagnostics are tests performed on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections. They are performed outside of the living organism.
  • Device Function: The described device (skin test applicator and tray) is used for the percutaneous application of allergenic extracts directly onto the surface of the skin. This is an in vivo procedure, meaning it is performed within the living organism (the patient's skin).
  • Intended Use: The intended use is to perform allergy skin tests for hypersensitivity reactions in individuals. This involves observing a reaction on the patient's skin, not analyzing a sample taken from the patient.

While the device uses diagnostic allergen extracts, the method of diagnosis is through an in vivo skin reaction, not an in vitro analysis of a bodily sample.

N/A

Intended Use / Indications for Use

The skin test applicator is used for conventional administration (percutaneous application of allergenic extracts directly onto the surface of the skin) of diagnostic allergen extracts for performing allergy skin tests on the typical sites (the back and the volar surfaces of the forearms) for hypersensitivity reactions in individuals suspected of having allergies.

The test tray is intended to hold allergenic extracts in a convenient for storage and use by the clinician.

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

SCL, LDH

Device Description

The AllergiEnd allergy skin testing products are supplied sterile and consist of two (2) devices:

  • Test Applicator
  • Test Tray

The MedScience AllergiEnd Applicator and Tray are used together for the conventional percutaneous application of substance directly onto the surface of the skin of diagnostic allergen extracts for performing skin tests for hypersensitivity reactions in individuals suspected of having allergies.

The AllergiEnd ST-9 Applicator has nine (9) test heads arranged in an asymmetrical design two (2) rows of four (4) test heads and a distal ninth test head. The test heads are labeled 1 through 9.

Each of the 9 test heads has a "leg." At the tip of each leg is an array of nine (9) protruding test points (tines). The tines utilize capillary action to hold the allergenic material for percutaneous delivery when the applicator is applied to the skin.

The test heads are designed to fit into the matching asymmetrical well design of the AllergiEnd ST-9 Test Tray. The applicator loads the allergen from each well in the tray on to each test head. The wells are numbered 1 to 9 to match the numbering on the applicator.

When properly applied to the skin, the applicator will leave visible indentations in the patient's skin corresponding to the 9 test heads of each applicator is not intended to pierce the skin.

The asymmetric design of the wells allows for only one possible orientation for the applicator to be placed in the tray. It is believed that the asymmetric design may help reduce the potential for operator error inherent in a symmetrical design and may also help the clinician avoid misreading of the skin reactions to the applied allergens.

The tray is configured to hold either 36 or 72 test allergens in individual wells. The groups of wells, either 4 groups for 36 test wells or 8 groups for 72 test wells, determine the tray configuration. The clinician's testing preferences will determine which tray configuration to consider.

The AllergiEnd ST-9 Multiple Well Test Tray is intended to hold small quantities of allergenic extracts in a convenient arrangement for storage and use. The Test Tray is not preloaded with allergens. The allergens are separately sourced and loaded by the clinician. Regardless of the number of wells, the test tray does not come in direct contact with the patient.

The individual wells are numbered with an easily readable alpha-numeric system to facilitate recording reactions to specific allergens. By including an alpha-numeric numbering system in the AllergiEnd ST-9 Multiple Well Test Tray the test administrator has a clear organizational structure for locating each allergen and tracking the patient's response and for correctly documenting in the patient's medical records.

The AllergiEnd ST-9 Multiple Well Test Tray also includes a locking lid that engages with a flexible seal. The locking/sealing cover protects the physician-filled allergenic material from contamination and evaporation. Additionally, the locking feature provides for secure handling. The locking feature does not affect the medical procedure, nor does it have any direct interaction with any of the allergenic extracts.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

the back and the volar surfaces of the forearms

Indicated Patient Age Range

Not Found

Intended User / Care Setting

medical professionals in a clinical setting.

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)

Clinical testing of the AllergiEnd® ST-9 Multiple Skin Test Applicator and Multiple Well Test Tray was conducted to establish equivalence to the predicate device through side-by-side testing.

Comparative Device Study

The study included 14 patients at a single site. The test locations on the body were divided into right and left sides of the test subject. The AllergiEnd ST-9 applicators were applied on the left side of the subject. The predicate applicators were applied on the right side of the subject. Eight applicators were used for each test subject. The AllergiEnd ST-9 (a 9-head applicator) had a total of four applications in each test; two using histamine applied to each test head, for a total of 18 locations tested with histamine and 2 using the glycerin saline solution applied to each test head, for a total of 18 locations tested with the control glycerin saline. The Greer Skintestor OMNI (a 10-head applicator) also had a total of four applications in each test; two using histamine applied to each test head, for a total of 20 locations tested with histamine and 2 using the glycerin saline solution applied to each test head, for a total of 20 locations tested with the control glycerin saline solution.

Primary effectiveness endpoint:

The subject device is able to administer allergenic extract percutaneously to elicit reactions comparable to predicate.

Primary safety endpoint:

The applicator of the subject device produces a comparable (or lower) sensation/pain rating as the predicate applicator when used to administer allergenic extract percutaneously.

Effectiveness:

Mean wheal diameters of the histamine and the control, glycerin saline were compared. In comparing the subject and predicate devices, there were no statistically significant differences.

Safety:

The average pain reading for AllergiEnd ST-9 Applicator, using the Wong-Baker FACES Pain Rating, was 1.54, which was comparable to the predicate device's Pain Rating of 1.55.

Summary

Mean wheal diameters were compared showing no statistically significant differences of allergen delivery between subject and predicate devices. Pain assessment, using the Wong-Baker FACES Pain Rating Scale, showed no significant differences between ST-9 and Greer applicators. The data supports the clinical use of the device.

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.

K003195

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

§ 880.5570 Hypodermic single lumen needle.

(a)
Identification. A hypodermic single lumen needle is a device intended to inject fluids into, or withdraw fluids from, parts of the body below the surface of the skin. The device consists of a metal tube that is sharpened at one end and at the other end joined to a female connector (hub) designed to mate with a male connector (nozzle) of a piston syringe or an intravascular administration set.(b)
Classification. Class II (performance standards).

0

Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

MedScience Science Research Group, Inc. % Audrey Swearingen Director, Regulatory Affairs Emergo Global Consulting, LLC 2500 Bee Cave Road, Building 1, Suite 300 Austin, Texas 78746

November 1, 2024

Re: K172062

Trade/Device Name: AllergiEnd® ST-9 Multiple Skin Test Applicator. AllergiEnd® ST-9 Multiple Well Test Tray Regulation Number: 21 CFR 880.5570 Regulation Name: Hypodermic single lumen needle Regulatory Class: Class II Product Code: SCL

Dear Audrey Swearingen:

The Food and Drug Administration (FDA) is sending this letter to notify you of an administrative change related to your previous substantial equivalence (SE) determination letter dated March 5, 2018. Specifically, FDA is updating this SE Letter because FDA has better categorized your device technology under product code SCL.

Please note that the 510(k) submission was not re-reviewed. For questions regarding this letter please contact David Wolloscheck, OHT3: Office of GastroRenal, OB-Gyn, General Hospital and Urology Devices, 301-796-1480. David.Wolloscheck@fda.hhs.gov.

Sincerely,

David Wolloscheck -S

David Wolloscheck, Ph.D. Assistant Director DHT3C: Division of Drug Delivery and General Hospital Devices and Human Factors OHT3: Office of GastroRenal, OB-Gyn, General Hospital and Urology Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

1

Image /page/1/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA acronym followed by the full name of the agency on the right. The FDA part of the logo is in blue, with the acronym in a square and the full name written out to the right of it. The full name of the agency is "U.S. Food & Drug Administration".

March 5, 2018

MedScience Science Research Group, Inc. % Audrey Swearingen Emergo Global Consulting, LLC 2500 Bee Cave Road, Building 1, Suite 300 Austin, Texas 78746

Re: K172062

Trade/Device Name: AllergiEnd® ST-9 Multiple Skin Test Applicator, AllergiEnd® ST-9 Multiple Well Test Tray Regulatory Class: Unclassified Product Code: LDH Dated: January 26, 2018 Received: January 29, 2018

Dear Audrey Swearingen:

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.

2

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 (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.

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.

Tina Kiang
-s

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

Enclosure

3

Indications for Use

510(k) Number (if known) K172062

Device Name

AllergiEnd® ST-9 Multiple Skin Test Applicator and AllergiEnd® ST-9 Multiple Well Test Tray

Indications for Use (Describe)

The skin test applicator is used for conventional administration (percutaneous application of allergenic extracts directly onto the surface of the skin) of diagnostic allergen extracts for performing allergy skin tests on the typical sites (the back and the volar surfaces of the forearms) for hypersensitivity reactions in individuals suspected of having allergies.

The test tray is intended to hold allergenic extracts in a convenient for storage and use by the clinician.

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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

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

510(k) Summary

K172062

1. Submission Sponsor

MedScience Research Group, Inc. 16469 Bridlewood Circle Delray Beach, Florida, 33445 USA

Marvin Smollar Co-president Email: marvin.smollar@medscienceinc.com Phone: 561-499-0411

2. Submission Correspondent

Emergo Global Consulting, LLC 2500 Bee Cave Road Building 1, Suite 300 Austin, TX 78746 USA

Office Phone: (512) 327-9997

Contact: Audrey Swearingen, RAC Title: Director, Regulatory Affairs

3. Date Prepared

01/25/2018

4. Device Identification

| Trade/Proprietary Name: | AllergiEnd® ST-9 Multiple Skin Test Applicato
AllergiEnd® ST-9 Multiple Well Test Tray |
|-------------------------|-------------------------------------------------------------------------------------------|
| Common/Usual Name: | System, delivery, allergen and vaccine |
| Regulation Number: | None: Pre-Amendment |
| Product Code: | LDH |
| Device Class: | Unclassified |
| Classification Panel: | General Hospital |

5

5. Legally Marketed Predicate Device(s)

K003195, Greertrack Skin Testing System, currently marked by Greer under the brand name Skintestor OMNI™.

6. Indication for Use Statement

The skin test applicator is used for conventional administration (percutaneous application of allergenic extracts directly onto the surface of the skin) of diagnostic allergen extracts for performing allergy skin tests on the typical sites (the back and the volar surfaces of the forearms) for hypersensitivity reactions in individuals suspected of having allergies.

The test tray is intended to hold allergenic extracts in a convenient arrangement for storage and use by the clinician.

7. Device Description

The AllergiEnd allergy skin testing products are supplied sterile and consist of two (2) devices:

  • Test Applicator
  • Test Tray

The MedScience AllergiEnd Applicator and Tray are used together for the conventional percutaneous application of substance directly onto the surface of the skin of diagnostic allergen extracts for performing skin tests for hypersensitivity reactions in individuals suspected of having allergies.

The AllergiEnd ST-9 Applicator has nine (9) test heads arranged in an asymmetrical design two (2) rows of four (4) test heads and a distal ninth test head. The test heads are labeled 1 through 9.

Each of the 9 test heads has a "leg." At the tip of each leg is an array of nine (9) protruding test points (tines). The tines utilize capillary action to hold the allergenic material for percutaneous delivery when the applicator is applied to the skin.

The test heads are designed to fit into the matching asymmetrical well design of the AllergiEnd ST-9 Test Tray. The applicator loads the allergen from each well in the tray on to each test head. The wells are numbered 1 to 9 to match the numbering on the applicator.

When properly applied to the skin, the applicator will leave visible indentations in the patient's skin corresponding to the 9 test heads of each applicator is not intended to pierce the skin.

The asymmetric design of the wells allows for only one possible orientation for the applicator to be placed in the tray. It is believed that the asymmetric design may help reduce the potential for operator error inherent in a symmetrical design and may also help the clinician avoid misreading of the skin reactions to the applied allergens.

The tray is configured to hold either 36 or 72 test allergens in individual wells. The groups of wells, either 4 groups for 36 test wells or 8 groups for 72 test wells, determine the tray configuration. The clinician's testing preferences will determine which tray configuration to consider.

6

The AllergiEnd ST-9 Multiple Well Test Tray is intended to hold small quantities of allergenic extracts in a convenient arrangement for storage and use. The Test Tray is not preloaded with allergens. The allergens are separately sourced and loaded by the clinician. Regardless of the number of wells, the test tray does not come in direct contact with the patient.

The individual wells are numbered with an easily readable alpha-numeric system to facilitate recording reactions to specific allergens. By including an alpha-numeric numbering system in the AllergiEnd ST-9 Multiple Well Test Tray the test administrator has a clear organizational structure for locating each allergen and tracking the patient's response and for correctly documenting in the patient's medical records.

The AllergiEnd ST-9 Multiple Well Test Tray also includes a locking lid that engages with a flexible seal. The locking/sealing cover protects the physician-filled allergenic material from contamination and evaporation. Additionally, the locking feature provides for secure handling. The locking feature does not affect the medical procedure, nor does it have any direct interaction with any of the allergenic extracts.

8. Substantial Equivalence Discussion

The following table compares the Allergy skin testing device to the predicate device with respect to indications for use, principles of operation, technological characteristics, and materials. The subject devices do not raise any new issues of safety or effectiveness based on the similarities to the predicate device.

ManufacturerMedScienceGreer LaboratoriesDevice Comparison
Trade NameAllergiEnd ST-9 Applicator
and TrayGreertrack Skin Testing
System
Applicator - Model 1000
Tray - Models 1001-36 and 1001Models: GT-IT, GT-IC
510(k) NumberTBDK003195N/A
Product CodeLDHSameSame
Regulation
NumberNone: Pre-AmendmentSameSame
Regulation NameSystem, delivery, allergen
and vaccineSameSame
ManufacturerMedScienceGreer Laboratories
Trade NameAllergiEnd ST-9 Applicator
and Tray
Applicator - Model 1000
Tray - Models 1001-36 and 1001Greertrack Skin Testing
System
Models: GT-IT, GT-ICDevice Comparison
Indications for UseThe skin test applicator is
used for conventional
administration
(percutaneous application
of allergenic extracts
directly onto the surface of
the skin) of diagnostic
allergen extracts for
performing allergy skin
tests on the typical sites
(the back and the volar
surfaces of the forearms)
for hypersensitivity
reactions in individuals
suspected of having
allergies.
The test tray is intended to
hold allergenic extracts in a
convenient arrangement
for storage and use by the
clinician.The device system is for use
in the prick/puncture
application of allergen
extracts to the epicutaneous
layer of the skin in the
performance of skin testing
for immediate type
hypersensitivity reactions in
those individuals suspected
of having allergies.The proposed
Indications for Use is
more descriptive.
Does not raise any
additional questions
of safety or
effectiveness.
AllergensNot supplied: added by
clinicianSameSame
Target PopulationThe device is intended for
use by medical
professionals in a clinical
setting.SameSame
Applicator
General UseApplication of doctor
provided allergenic extracts
used for skin testingSameSame
Method for
loading the
allergenic materialCapillary actionSameSame
Anatomical
site/LocationBack and volar surface of
forearmsSameSame
ManufacturerMedScienceGreer Laboratories
Trade NameAllergiEnd ST-9 Applicator
and Tray
Applicator - Model 1000
Tray - Models 1001-36 and 1001Greertrack Skin Testing
System
Models: GT-IT, GT-ICDevice Comparison
MaterialApplicator is molded from
Dupont Delrin®
(polyoxymethylene)
100P NC010.Per spectral analysis, the
applicator is molded from a
thermoplastic polymer
identified as
polyoxymethylene or
polyacetal.Both are made of
polyoxymethylene.
Any minor differences
in material does not
raise any additional
questions of safety or
effectiveness as the
proposed material
was found to be
biocompatible.
Applicator designRigid center spine that
incorporates the test heads
with tinesSameSame
Number of
applicator heads910Number of applicator
heads does not
provide for a
functional difference,
therefore it does not
raise any additional
questions of safety or
effectiveness.
Applicator Head
patternAsymmetric
9 test heads arranged in 2
rows of 4 test heads with a
single test head distally
located along the center
line of the applicator.Symmetric
5 rows of 2 heads.The arrangement of
applicator heads does
not provide for a
functional difference;
therefore, it does not
raise any additional
questions of safety or
effectiveness.
Spacing between
Heads20 mm18.4 mmThe small increase in
the spacing between
heads does not
provide for a
functional difference;
therefore, it does not
raise any additional
questions of safety or
effectiveness.
ManufacturerMedScienceGreer LaboratoriesDevice Comparison
Trade NameAllergiEnd ST-9 Applicator
and Tray
Applicator - Model 1000
Tray - Models 1001-36 and 1001Greertrack Skin Testing
System
Models: GT-IT, GT-ICDevice Comparison
Number of tines
on each test head97The difference in the
number of tines is not
expected to affect
performance or
safety.
SterileEthylene Oxide (EO)SameSame
Single-UseYesSameSame
Applicator
Complies with ISO
10993-10YesUSP Class VIProposed device was
tested per current
requirements and
shown to pass.
Tray
General UseHolds small quantities of
doctor-provided allergenic
extracts and to allow
allergens to be applied to
the applicator used for skin
testing.SameSame
Tray patternMatches that of applicatorSameSame
Number of tray
wellsCatalogue# 1001-36
has 36 wells
Catalogue# 1001
has 72 wells20 - three trays may be
combined to have 60 wellsThe number of test
wells does not provide
for a functional
difference; therefore,
it does not raise any
additional questions
of safety or
effectiveness.
SterileEthylene Oxide (EO)SameSame
Single UseNoNoSame
Material
CompositionRohm Plexiglas®
Plexiglas SG 10 acrylicPer spectral analysis, the
tray is molded from
Polymethyl methacrylate
(commonly referred to as
acrylic).Difference in material
does not raise any
additional questions
of safety or
effectiveness as the
proposed material
was found to be
biocompatible.
ManufacturerMedScienceGreer Laboratories
Trade NameAllergiEnd ST-9 Applicator
and Tray
Applicator - Model 1000
Tray - Models 1001-36 and 1001Greertrack Skin Testing
System
Models: GT-IT, GT-ICDevice Comparison
Lid FunctionLockingNo LidLid decreases chance
for contamination.
More securely
integrates the test
wells with the cover to
form a sturdier device
allowing for more
secure handling.
Does not raise any
additional questions
of safety or
effectiveness.
Applicator
Complies with ISO
10993-10YesUSP Class VIProposed device was
tested per current
requirements.

Table 5A – Comparison of Characteristics

7

8

9

10

9. Non-Clinical Performance Data

Each lot of the AllergiEnd® ST-9 Multiple Skin Test Applicator and Multiple Well Test Tray are inspected at AQL level 1.0 sampling size.

The following data were provided in support of the substantial equivalence determination:

Biocompatibility Testing

Biocompatibility evaluation of the AllergiEnd® ST-9 Multiple Skin Test Applicator was conducted in accordance with the FDA Guidance Use of International Standard ISO 10993-1, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process" April 23, 2013, and International Standard ISO 10993-1 Biological Evaluation of Medical Devices – Part 1: Evaluation and Testing Within a Risk Management Process, as recognized by FDA.

The AllergiEnd® ST-9 Multiple Skin Test Applicator contacts intact skin for limited duration (