(371 days)
The BH sterilization pouch is intended to provide dentists with an effective method to enclose devices intended for sterilization in steam auto claves. The recommended pre-vacuum steam sterilization cycle parameters are 4 minutes at 132°C (270°F). The sterilization pouch maintains the enclosed devices up until 180 days post sterilization. Lastly, the pouch's external chemical ink indicators are designed to indicate to the pouch has undergone a steam sterilization process. Only one instrument can be sterilized in one pouch and only instruments that are be metal, hinged, or knurled can be sterilized in the pouch.
The pouches are made from a medical grade paper and plastic film that is heat sealed on three sides. The forth side has an adhesive strip that is used to seal the paper to the film prior to sterilization of the enclosed medical device. The medical grade paper conforms to recognized material standards and can be steam sterilized. The process indicator ink printed on the medical paper will exhibit a color change after the pouch is exposed to steam sterilization. The device is disposable, single use only.
Here's a breakdown of the acceptance criteria and the study information for the BH Sterilization Pouch, based on the provided document:
Acceptance Criteria and Device Performance
The document summarizes that the device demonstrated it met the acceptance criteria for each test performed. While specific numerical acceptance criteria are not explicitly detailed in a separate table within the document, the "Summary of Non-Clinical Testing" and "Conclusion" sections confirm that testing was conducted and passed. The criteria are implied by compliance with the referenced standards.
| Test Category | Implied Acceptance Criteria (Based on Standards) | Reported Device Performance |
|---|---|---|
| Sterility Maintenance | Maintain sterility for the specified shelf life (180 days). | Demonstrated maintenance of sterility for 180 days. |
| Thermal Profile / Sterilant Penetration | Achieve adequate sterilant penetration and maintain steady-state thermal conditions throughout the recommended sterilization cycle. | Sterilant penetration demonstrated; maintained steady-state thermal conditions. |
| Pouch Performance (Seal Integrity) | Meet specified strength and integrity requirements for seals (e.g., as per ASTM F88, F1929, F1140). | Met requirements (implied by passing tests). |
| Microbial Barrier (Packaging Material) | Provide an effective barrier against microbial penetration (as per ASTM 1608). | Met requirements (implied by passing test). |
| Steam Chemical Indicator Efficacy | Indicator must show a clear and discernible color change after exposure to steam sterilization, meeting ISO 11140-1:2014 requirements. | Indicator exhibited a color change after steam sterilization; compliant with ISO 11140-1. |
| Biocompatibility | Non-cytotoxic, non-sensitizing, and non-irritating (as per ISO 10993-5 and ISO 10993-10). | Device found to be non-cytotoxic, non-sensitizing, and non-irritating. |
| Shelf Life (Pouch & Indicator) | Pouch: Maintain usability and integrity for the specified shelf life (2 years). Indicator: Maintain efficacy for the specified shelf life (2 years). | Pouch: 2 years (implied by comparison to predicate). Indicator: 2 years (implied by comparison to predicate). |
| Process Type 1 Chemical Indicator Efficacy Endpoint Stability | Maintain indicator efficacy for the specified duration (180 days). | 180 days (implied by comparison to predicate). |
Study Details
The provided document describes a non-clinical testing summary for the BH Sterilization Pouch to demonstrate substantial equivalence to a predicate device (Medicom Self Sealing Sterilization Pouch, K070428).
1. Sample sizes used for the test set and data provenance:
- Sample Size: The document does not explicitly state numerical sample sizes for each test (e.g., how many pouches were tested for seal strength). It only lists the test methods used.
- Data Provenance: The studies were non-clinical performance tests conducted for regulatory submission (510(k)) in the People's Republic of China (manufacturer location). It is prospective testing designed to characterize the device's performance according to established standards.
2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
* This is not applicable as the studies are in vitro (non-clinical/bench testing) and do not involve human readers, clinical images, or expert interpretation for ground truth establishment. The "ground truth" is determined by established performance metrics and adherence to international technical standards (e.g., ASTM, ISO).
3. Adjudication method for the test set:
* Not applicable, as there are no human interpretations or disagreements to adjudicate. The tests have predefined pass/fail criteria based on the relevant standards.
4. 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:
* No. This is a non-clinical in vitro study of a sterilization pouch, not an AI-powered diagnostic device. MRMC studies are irrelevant in this context.
5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
* Not applicable. This device does not involve an algorithm or AI.
6. The type of ground truth used:
* The "ground truth" for the non-clinical tests is based on objective, verifiable measurements and comparisons against established international standards and specifications. For instance:
* Seal Integrity: Measured seal strength via ASTM F88, dye penetration via ASTM F1929, and internal pressurization failure via ASTM F1140. The ground truth is the performance metric defined by these standards.
* Sterilant Penetration/Thermal Profile: Measured physical parameters against established successful sterilization conditions.
* Microbial Barrier: Measured resistance to microbial penetration against a defined metric (ASTM 1608).
* Chemical Indicator: Visual observation of color change and comparison against established criteria for a successful indicator as per ISO 11140-1.
* Biocompatibility: Laboratory assays for cytotoxicity, sensitization, and irritation interpreted against the criteria of ISO 10993-5 and ISO 10993-10.
7. The sample size for the training set:
* Not applicable. This device does not use machine learning or AI, and therefore has no "training set."
8. How the ground truth for the training set was established:
* Not applicable, for the reason stated above.
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Image /page/0/Picture/0 description: The image contains the logos of the Department of Health and Human Services and the Food and Drug Administration (FDA). The Department of Health and 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. Next to the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
BH Medical Products Co., Ltd. Edward Tao Manager No.90 Shenjiang Villagers Group, Zhangjiacunwei, Xilin Street Changzhou, 213024 Cn
Re: K172280
Trade/Device Name: BH Sterilization Pouch Regulation Number: 21 CFR 880.6850 Regulation Name: Sterilization Wrap Regulatory Class: Class II Product Code: KCT, JOJ Dated: July 7, 2018 Received: July 9, 2018
Dear Edward Tao:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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
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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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.htm); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; 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 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,
Clarence W. Murray lii III -S
For 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
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Indications for Use
510(k) Number (if known) K172280
Device Name BH Sterilization Pouch
Indications for Use (Describe)
The BH sterilization pouch is intended to provide dentists with an effective method to enclose devices intended for sterilization in steam auto claves. The recommended pre-vacuum steam sterilization cycle parameters are 4 minutes at 132°C (270°F). The sterilization pouch maintains the enclosed devices up until 180 days post sterilization. Lastly, the pouch's external chemical ink indicators are designed to indicate to the pouch has undergone a steam sterilization process. Only one instrument can be sterilized in one pouch and only instruments that are be metal, hinged, or knurled can be sterilized in the pouch.
| Product Code # | Size | Maximum load size(LxWxH)/mm | Maximum load weight/kg |
|---|---|---|---|
| 990618 | 7 1/2"x13"(190mmx330mm) | 147mmx255mmx18mm | 2 |
| 990617 | 5 1/4"x10"(135mmx260mm) | 92mmx190mmx18mm | 2 |
| 990613 | 4 1/4"x11"(110mmx300mm) | 73mmx240mmx12mm | 2 |
| 990616 | 3 1/2"x9"(90mmx230mm) | 47mmx175mmx18mm | 1.2 |
Type of Use (Select one or both, as applicable)
| Prescription Use (Part 21 CFR 801 Subpart D) |
|---|
| Over-The-Counter Use (21 CFR 801 Subpart C) |
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510(k) Summary
[As Required by 21 CFR 807.92]
Submission Number: K172280
- BH Medical Products Co., Ltd. Submitter: No.90 Shenjiang Villagers' group, Zhangjiacunwei, Xilin Street, Zhonglou District, Changzhou City, Jiangsu Province, People's Republic of China (Establishment registration number: 3009307523)
- Contact Person: Xiaohua TAO President Tel: 86-519-83978705 Fax: 86-519-83978717 Email: tao@bhmedical.com.cn
Device/Trade Name: BH Sterilization Pouch Common Name: Sterilization wrap Device Panel: General Hospital Basis for Submission: New Device Regulation Name: 1) Sterilization wrap 2) Physical/chemical sterilization process indicator
Device Classification: Class II
Regulation Number: 21 CFR 880.6850 Product Code: 1) KCT
21CFR 880.2800 Product Code: 2) JOJ
Predicate Device to BH Sterilization Pouch:
Trade Name: Medicom Self Sealing Sterilization Pouch 510(k) Number: K070428 Manufactured by: A.R. Medicom Inc. 1200 55th Avenue, Lachine, Quebec, H8T 3J8, Canada
Device Description:
The pouches are made from a medical grade paper and plastic film that is heat sealed on three sides. The forth side has an adhesive strip that is used to seal the paper to the film prior to sterilization of the enclosed medical device. The medical grade paper conforms to recognized material standards and can be steam sterilized. The process indicator ink printed on the medical paper will exhibit a color change after the pouch is exposed to steam sterilization. The device is disposable, single use only.
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The process indicator of the pouch is a necessary visual component utilized by endusers to identify devices or products that have been subjected to a sterilization process. It complies with the requirements of ISO 11140-1 and the Guidance for Industry and FDA staff: Premarket Notification [510(k)] Submission for Chemical Indicators.
Indications for Use:
The BH sterilization pouch is intended to provide dentists with an effective method to enclose devices intended for sterilization in steam autoclaves. The recommended prevacuum steam sterilization cycle parameters are 4 minutes at 132°C (270°F). The sterilization pouch maintains the enclosed devices up until 180 days post sterilization. Lastly, the pouch's external chemical ink indicators are designed to indicate to the user that the pouch has undergone a steam sterilization process. Only one instrument can be sterilized in one pouch and only instruments that are be metal, hinged, or knurled can be sterilized in the pouch.
| Product Code# | Size | Maximum loadweight/kg |
|---|---|---|
| 990618 | 7 1/2"x13"(190mmx330mm) | 2 |
| 990617 | 5 1/4"x10"(135mmx260mm) | 2 |
| 990613 | 4 1/4"x11"(110mmx300mm) | 2 |
| 990616 | 3 1/2"x9"(90mmx230mm) | 1.2 |
The BH sterilization pouch varies in the following sizes:
Comparison of Technological Characteristics:
| Predicate Device | Subject Device | Comments | |
|---|---|---|---|
| Device | Medicom Self SealingSterilizationPouch(K070428) | BH Sterilization Pouch | / |
| Product Code | KCT & JOJ | KCT & JOJ | Same |
| Indications forUse | The self-sealingsterilization pouches areintended to providehealth care workers withan effective method toenclose devices intendedfor sterilization in steamauto claves and viaEthylene Oxide(EO). Therecommended steamsterilization cycleparameters are 30 | The BH sterilization pouchis intended to providedentists with an effectivemethod to enclose devicesintended for sterilization insteam auto claves. Therecommended pre-vacuumsteam sterilization cycleparameters are 4 minutesat 132°C (270°F). Thesterilization pouchmaintains the encloseddevices up until 180 days | Similar |
| minutes at 121°C. The | post sterilization. Lastly, the pouch's external chemical ink indicators are designed to indicate to the user that the pouch has undergone a steam sterilization process. | ||
| recommended EOsterilization cycle is100-120 minutes at 50°Cwith a relative humiditybetween 60-85% and asterilant concentration of600mg/L. Furthermore,the sterilization pouchmaintains the encloseddevices sterile up untilone year poststerilization. Lastly, thepouch's externalchemical ink indicatorsare designed to indicateto the user that the pouchhas undergone either asteam or EO sterilizationprocess. | |||
| MaterialComposition | Medical Grade Paper,CPP, PET, PU adhesive,EO and Steam ProcessIndicator Print Ink | Medical Grade Paper,Film(CPP/PET), PUadhesive, Steam ProcessIndicator Print Ink | Similar |
| Sterilizationcycles | The recommended steamsterilization cycleparameters are 30minutes at 121°C. Therecommended EOsterilization cycle is100-120 minutes at 50°Cwith a relative humiditybetween 60%-85% and asterilant concentration of600mg/L. | The recommendedPre-vacuum steamsterilization cycleparameters are 4 minutesat 132°C. | Differentsterilizationcycles |
| Design features | The pouches aremanufactured from amedical grade paper thatis thermally sealed to a | The pouches are madefrom a medical gradepaper and plastic film thatis heat sealed on three | Same |
| left, right, and bottom of | adhesive strip that is used | ||
| pouch. The fourth side | to seal the paper to the | ||
| has an adhesive strip that | film prior to sterilization | ||
| is used to seal the paper | of the enclosed medical | ||
| to the film prior to | device. The medical grade | ||
| sterilization of the | paper conforms to | ||
| enclosed medical device. | recognized material | ||
| The pouches contain | standards and can be steam | ||
| external indicators used | sterilized. The process | ||
| to indicate the pouches | indicator ink printed on the | ||
| were processed via steam | |||
| medical paper will exhibit | |||
| or EO sterilization. | a color change after the | ||
| pouch is exposed to steam | |||
| sterilization. | |||
| Sterility | Pouches maintain | Pouches maintain sterility | Similar |
| maintenance | sterility of the enclosure | of the enclosure device for | |
| device for up to one year | up to 180 days post | ||
| post sterilization. | sterilization. | ||
| Process | ANSI/AAMI/ISO | ANSI/AAMI/ISO | Same |
| Type 1 | 11140-1:2014 | 11140-1:2014 | |
| Chemical | Sterilization of health | Sterilization of health | |
| Indicator | care products- | care products- | |
| Efficacy | Chemical indicators- | Chemical indicators- | |
| Part 1: General | Part 1:General | ||
| requirements. | requirements | ||
| Process Type 1ChemicalIndicatorEfficacyEndpointStability | 6 months | 180 days | Same |
| Process Type 1ChemicalIndicator ShelfLife | 2 years | 2 years | Same |
| Pouchperformance | The following testmethods were used in thepouch performancetesting:1. ASTM F882. ASTM F19293. ASTM F1140In addition, theprocess indicatorswere evaluated in theclaimed EO andSteam sterilizationcycle. | The following testmethods were used inpouch performancetesting:1. ASTM F882. ASTM F19293. ASTM F1140In addition, the processindicators wereevaluated in theclaimed steamsterilization cycle. | Same |
| Sterilantpenetration | Sterilant penetration wasdemonstrated in thedevice. | Test results indicate thatsterilant penetration wasdemonstrated Also thedevice maintained steadystate thermal conditionsthroughout therecommended sterilizationcycle. | Same |
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| Biocompatibility | The followingbiocompatibility testingwere performed on thisdevice:1. ISO 10993-52. ISO10993-10Based on the testconditions of the test thedevice was found to benon-cytotoxic, non-sensitizing and non-irritating. | The followingbiocompatibility testingwere performed on thisdevice:1. ISO 10993-52. ISO10993-10Based on the testconditions the device wasfound to be non-cytotoxic,non-sensitizing and non-irritating. | Same |
|---|---|---|---|
| Usage | For single use only | For single use only | Same |
| Device models | Code Dimension | Model Size | Similar |
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| 68015 | 35mmx73mm | 990613 | 110mmx300mm |
|---|---|---|---|
| 68000 | 49mmx200mm | 990616 | 90mmx230mm |
| 88015 | 57mmx100mm | 990617 | 135mmx260mm |
| 68005 | 62mmx103mm | 990618 | 190mmx330mm |
| 68020 | 62mmx220mm | ||
| 68010 | 69mmx200mm | ||
| 88000 | 70mmx229mm | ||
| 88005 | 89mmx133mm | ||
| 88010 | 89mmx229mm | ||
| 68025 | 116mmx219mm | ||
| 88025 | 133mmx254mm | ||
| 68030 | 170mmx237mm | ||
| 88030 | 190mmx330mm | ||
| 88035 | 254mmx356mm | ||
| 68035 | 305mmx432mm | ||
| 88040 | 230mmx305mm | ||
| 68040 | 285mmx370mm |
Discussion of similarities and differences between the Proposed Device and the Predicate Device
The BH sterilization pouch and Self Sealing Sterilization Pouch are both intended for provide end users with an effective method to enclose devices intended for sterilization. The pouch's process indicators are designed to indicate to the user that the pouch has undergone a sterilization process.
The most different technological characteristic between the predicate device and the subject device is the sterilization method. The predicate device is intended for both sterilization in steam autoclaves and via EO, but the subject device is only intended for steam sterilization. The target users of the subject device are dentists, and steam sterilization is the most common sterilization method used by dentists. As the sterilization method is different, the chemical indicators of the two devices are also different. The indicator of the predicate device is EO and steam process indicator, as for the subject device, it is steam process indicator. The sterilization parameters are different, but the sterilization cycles are validated.
Besides the differences, there are many similarities. The devices have similar indications for use, materials and sterilant maintenance period. Also, the devices both have the same design features, material compatibility, and biocompatibility. Furthermore, the process indicators and performance of the two devices are qualified in accordance with ISO
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standards. Finally, the devices are both devices are single use devices and come in various model sizes as described in this summary.
Biocompatibility Test:
Tests were conducted to evaluate the potential cytotoxicity, hypersensitivity and irritation of the BH Sterilization Pouch based on the requirements of ISO
10993-5:2009 Biological evaluation of medical devices-Part 5: Tests for in vitro cytotoxicity, ISO 10993-10:2010 Biological evaluation of medical device - Part 10: Tests for irritation and delayed -- type hypersensitivity. The tests results indicate that the device does not have the potential cytotoxicity, hypersensitivity and irritation.
Performance Test:
The following tests were conducted to evaluate the performance of BH Sterilization Pouch:
- . 180 Day Shelf Life of Sterility Maintenance Test (ANSI/AAMI ST 79:2010 Comprehensive guide to steam sterilization and sterility assurance in health care facilities.)
- . Thermal Profile / Sterilant Penetration Test (ANSI/AAMI ST8:2008 Hospital Steam Sterilizers), ANSI/AAMI ST 79:2010 Comprehensive guide to steam sterilization and sterility assurance in health care facilities.
- . Microbial Aerosol Challenge Test (ASTM 1608 Standard Test Method for Microbial Ranking of Porous Packaging Materials)
- Performance Property Test (ASTM F88- Standard Test Method for Seal Strength of ● Flexible Barrier Materials (Peel Test), ASTM F1929- Standard Test Method for Detecting Seal Leaks in Porous Medical Packaging by Dye Penetration (Dye Migration), ASTM F1140- Standard Test Methods for Internal Pressurization Failure Resistance of Unrestrained Packages))
- Steam Chemical Indicator Test (ANSI/AAMI/ISO 11140-1:2014 Sterilization of . health care products-Chemical Indicators-Part 1: General requirement)
Summary of Non-Clinical Testing:
Based on the results of the non-clinical testing which included: maintenance of sterility testing, chemical indicator testing, shelf life testing, pouch performance testing, sterilant penetration testing and biocompatibility testing, the subject device demonstrated that it met the acceptance criteria for each test.
Conclusion:
The conclusions drawn from the non-clinical tests demonstrate that the subject device (K172280) is as safe, as effective and performs as well or better than the legally marketed predicate device (K070428).
§ 880.6850 Sterilization wrap.
(a)
Identification. A sterilization wrap (pack, sterilization wrapper, bag, or accessories, is a device intended to be used to enclose another medical device that is to be sterilized by a health care provider. It is intended to allow sterilization of the enclosed medical device and also to maintain sterility of the enclosed device until used.(b)
Classification. Class II (performance standards).