K Number
K172280
Device Name
BH Sterilization Pouch
Date Cleared
2018-08-03

(371 days)

Product Code
Regulation Number
880.6850
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
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.
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.
More Information

Not Found

No
The device is a sterilization pouch with a chemical indicator, which is a passive physical/chemical process and does not involve AI or ML.

No
The device is a sterilization pouch used to enclose other devices for sterilization. It does not provide any therapeutic benefit to a patient.

No
The device is a sterilization pouch used to enclose and maintain sterility of medical devices, and its purpose is not to diagnose any condition or disease.

No

The device is a physical sterilization pouch made of paper and plastic film, not software.

Based on the provided information, 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 about a person's health.
  • Device Function: The BH sterilization pouch is designed to enclose and maintain the sterility of medical devices (specifically dental instruments) during and after steam sterilization. It does not analyze or test any biological specimens.
  • Intended Use: The intended use clearly states its purpose is for sterilizing dental instruments, not for diagnosing or monitoring a patient's health through in vitro testing.

The device is a sterilization accessory used in a healthcare setting, but its function is related to the sterilization process itself, not to in vitro diagnostic testing.

N/A

Intended Use / Indications for Use

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

KCT, JOJ

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.

The process indicator of the pouch is a necessary visual component utilized by end-users 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.

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

Dentists

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)

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)

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.

Key results: 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.

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.

K070428

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

§ 880.6850 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).

0

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

1

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

2

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 #SizeMaximum load size(LxWxH)/mmMaximum load weight/kg
9906187 1/2"x13"(190mmx330mm)147mmx255mmx18mm2
9906175 1/4"x10"(135mmx260mm)92mmx190mmx18mm2
9906134 1/4"x11"(110mmx300mm)73mmx240mmx12mm2
9906163 1/2"x9"(90mmx230mm)47mmx175mmx18mm1.2

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.

4

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 load

weight/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 DeviceSubject DeviceComments
DeviceMedicom Self Sealing
Sterilization
Pouch(K070428)BH Sterilization Pouch/
Product CodeKCT & JOJKCT & JOJSame
Indications for
UseThe self-sealing
sterilization pouches are
intended to provide
health care workers with
an effective method to
enclose devices intended
for sterilization in steam
auto claves and via
Ethylene Oxide(EO). The
recommended steam
sterilization cycle
parameters are 30The 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 daysSimilar
minutes at 121°C. Thepost 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 EO
sterilization cycle is
100-120 minutes at 50°C
with a relative humidity
between 60-85% and a
sterilant concentration of
600mg/L. Furthermore,
the sterilization pouch
maintains the enclosed
devices sterile up until
one year post
sterilization. Lastly, the
pouch's external
chemical ink indicators
are designed to indicate
to the user that the pouch
has undergone either a
steam or EO sterilization
process.
Material
CompositionMedical Grade Paper,
CPP, PET, PU adhesive,
EO and Steam Process
Indicator Print InkMedical Grade Paper,
Film(CPP/PET), PU
adhesive, Steam Process
Indicator Print InkSimilar
Sterilization
cyclesThe recommended steam
sterilization cycle
parameters are 30
minutes at 121°C. The
recommended EO
sterilization cycle is
100-120 minutes at 50°C
with a relative humidity
between 60%-85% and a
sterilant concentration of
600mg/L.The recommended
Pre-vacuum steam
sterilization cycle
parameters are 4 minutes
at 132°C.Different
sterilization
cycles
Design featuresThe pouches are
manufactured from a
medical grade paper that
is thermally sealed to aThe pouches are made
from a medical grade
paper and plastic film that
is heat sealed on threeSame
left, right, and bottom ofadhesive strip that is used
pouch. The fourth sideto seal the paper to the
has an adhesive strip thatfilm prior to sterilization
is used to seal the paperof the enclosed medical
to the film prior todevice. The medical grade
sterilization of thepaper conforms to
enclosed medical device.recognized material
The pouches containstandards and can be steam
external indicators usedsterilized. The process
to indicate the pouchesindicator 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.
SterilityPouches maintainPouches maintain sterilitySimilar
maintenancesterility of the enclosureof the enclosure device for
device for up to one yearup to 180 days post
post sterilization.sterilization.
ProcessANSI/AAMI/ISOANSI/AAMI/ISOSame
Type 111140-1:201411140-1:2014
ChemicalSterilization of healthSterilization of health
Indicatorcare products-care products-
EfficacyChemical indicators-Chemical indicators-
Part 1: GeneralPart 1:General
requirements.requirements
Process Type 1
Chemical
Indicator
Efficacy
Endpoint
Stability6 months180 daysSame
Process Type 1
Chemical
Indicator Shelf
Life2 years2 yearsSame
Pouch
performanceThe following test
methods were used in the
pouch performance
testing:
  1. ASTM F88
  2. ASTM F1929
  3. ASTM F1140
    In addition, the
    process indicators
    were evaluated in the
    claimed EO and
    Steam sterilization
    cycle. | The following test
    methods were used in
    pouch performance
    testing:
  4. ASTM F88
  5. ASTM F1929
  6. ASTM F1140
    In addition, the process
    indicators were
    evaluated in the
    claimed steam
    sterilization cycle. | Same |
    | Sterilant
    penetration | Sterilant penetration was
    demonstrated in the
    device. | Test results indicate that
    sterilant penetration was
    demonstrated Also the
    device maintained steady
    state thermal conditions
    throughout the
    recommended sterilization
    cycle. | Same |

5

6

7

8

| Biocompatibility | The following
biocompatibility testing
were performed on this
device:

  1. ISO 10993-5
  2. ISO10993-10
    Based on the test
    conditions of the test the
    device was found to be
    non-cytotoxic, non-
    sensitizing and non-
    irritating. | The following
    biocompatibility testing
    were performed on this
    device:
  3. ISO 10993-5
  4. ISO10993-10
    Based on the test
    conditions the device was
    found 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 |

9

6801535mmx73mm990613110mmx300mm
6800049mmx200mm99061690mmx230mm
8801557mmx100mm990617135mmx260mm
6800562mmx103mm990618190mmx330mm
6802062mmx220mm
6801069mmx200mm
8800070mmx229mm
8800589mmx133mm
8801089mmx229mm
68025116mmx219mm
88025133mmx254mm
68030170mmx237mm
88030190mmx330mm
88035254mmx356mm
68035305mmx432mm
88040230mmx305mm
68040285mmx370mm

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

10

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).