K Number
K181788
Device Name
Lead-free Chemical Indicators for Steam Sterilization
Date Cleared
2019-03-01

(239 days)

Product Code
Regulation Number
880.2800
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The Kem Medical Lead-free Chemical Indicators for Steam Sterilization are designed for use by a health care provider to demonstrate that the unit or load has been exposed to a steam sterilization process, and to distinguish between processed and unprocessed units or loads. Use the Kem Medical Lead-free Chemical Indicators for Steam Sterilization in the validated steam sterilization processes described below: *Gravity: 121 C/250 F - 30 minutes (wrapped/porous) *Gravity: 132 C/270 F - 3 minutes (unwrapped/nonporous) *Gravity: 132 C/270 F - 15 minutes (wrapped/porous) *Gravity: 135 C/275 F - 3 minutes (unwrapped/nonporous) * Gravity: 135 C/275 F - 10 minutes (wrapped/porous or unwrapped/nonporous, mixed load) * Vacuum assisted (prevacuum): 132 C/270 F - 3 minutes (unwrapped/nonporous) * Vacuum assisted (prevacuum): 132 C/270 F - 4 minutes (wrapped/porous) * Vacuum assisted (prevacuum): 134 C/273 F - 4 minutes (wrapped/porous) * Vacuum assisted (prevacuum): 135 C/275 F - 3 minutes (wrapped/porous or unwrapped/nonporous, mixed load)
Device Description
The Kem Medical Lead-free Chemical Indicators for Steam Sterilization provide immediate confirmation of the sterilization process. The indicator ink is lead-free and can be printed onto suitable paper substrates. As an example, the ink is printed onto adhesive-coated paper for autoclave labels, or "dots", which are removed from a poly or paper backing for use.
More Information

Not Found

No
The device is a chemical indicator that changes color based on exposure to steam sterilization parameters, which is a purely chemical and physical process, not involving AI/ML.

No.
This device is designed to indicate exposure to a steam sterilization process, not to treat any medical condition or disease.

No

Explanation: This device is a chemical indicator used to confirm exposure to a steam sterilization process, not to diagnose a disease or medical condition in a patient. It demonstrates whether a sterilization unit has been processed.

No

The device is a chemical indicator printed on paper, which is a physical product, not software.

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

Here's why:

  • Intended Use: The intended use is to demonstrate that a unit or load has been exposed to a steam sterilization process and to distinguish between processed and unprocessed items. This is a quality control measure for sterilization equipment, not a diagnostic test performed on biological samples.
  • Device Description: The device is a chemical indicator that changes color when exposed to steam sterilization conditions. It does not interact with or analyze biological specimens.
  • Lack of IVD Characteristics: The description does not mention any of the typical characteristics of an IVD, such as:
    • Analyzing biological samples (blood, urine, tissue, etc.)
    • Providing information about a patient's health status, disease, or condition
    • Using reagents or assays to detect specific substances in biological samples

The device is clearly designed to monitor the effectiveness of a sterilization process, which is a critical step in healthcare but is not considered an in vitro diagnostic procedure.

N/A

Intended Use / Indications for Use

The Kem Medical Lead-free Chemical Indicators for Steam Sterilization are designed for use by a health care provider to demonstrate that the unit or load has been exposed to a steam sterilization process, and to distinguish between processed and unprocessed units or loads. Use the Kem Medical Lead-free Chemical Indicators for Steam Sterilization in the validated steam sterilization processes described below:

*Gravity: 121 C/250 F - 30 minutes (wrapped/porous)

*Gravity: 132 C/270 F - 3 minutes (unwrapped/nonporous)

*Gravity: 132 C/270 F - 15 minutes (wrapped/porous)

*Gravity: 135 C/275 F - 3 minutes (unwrapped/nonporous)

  • Gravity: 135 C/275 F - 10 minutes (wrapped/porous or unwrapped/nonporous, mixed load)

  • Vacuum assisted (prevacuum): 132 C/270 F - 3 minutes (unwrapped/nonporous)

  • Vacuum assisted (prevacuum): 132 C/270 F - 4 minutes (wrapped/porous)

  • Vacuum assisted (prevacuum): 134 C/273 F - 4 minutes (wrapped/porous)

  • Vacuum assisted (prevacuum): 135 C/275 F - 3 minutes (wrapped/porous or unwrapped/nonporous, mixed load)

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

JOJ

Device Description

The Kem Medical Lead-free Chemical Indicators for Steam Sterilization provide immediate confirmation of the sterilization process. The indicator ink is lead-free and can be printed onto suitable paper substrates. As an example, the ink is printed onto adhesive-coated paper for autoclave labels, or "dots", which are removed from a poly or paper backing for use.

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

health care provider

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 Kem Medical Lead-free Chemical Indicators for Steam Sterilization meet all ISO 11140-1:2014 performance criteria for Type 1 steam sterilization indicators. All BIER Steam Sterilizer cycles resulted in acceptable pass/fail criteria for all temperatures and times specified. Full autoclave cycles for both Gravity and Pre-vacuum were performed showing acceptable results for all temperatures and times specified. Dry heat, Color Change Stability, and Transference/Migration testing also resulted in acceptable results for all performance criteria of 1140-1:2014. The condition of the CI color change after exposure to a steam sterilization process remained unchanged for a period of not less of 6 months from the date of exposure.

The Lexamed® study results demonstrated the Kem Medical Lead-free Type 1 Chemical Indicator can be used as an external or internal chemical indicator for use in monitoring exposure to conditions of steam sterilization for the indicated gravity and pre-vacuum sterilizer cycles and comply with all applicable requirements defined in ISO 11140-1:2014, Sterilization of healthcare products- Chemical Indicators-Part 1 General Requirements.

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.

K101528

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

§ 880.2800 Sterilization process indicator.

(a)
Biological sterilization process indicator —(1)Identification. A biological sterilization process indicator is a device intended for use by a health care provider to accompany products being sterilized through a sterilization procedure and to monitor adequacy of sterilization. The device consists of a known number of microorganisms, of known resistance to the mode of sterilization, in or on a carrier and enclosed in a protective package. Subsequent growth or failure of the microorganisms to grow under suitable conditions indicates the adequacy of sterilization.(2)
Classification. Class II (performance standards).(b)
Physical/chemical sterilization process indicator —(1)Identification. A physical/chemical sterilization process indicator is a device intended for use by a health care provider to accompany products being sterilized through a sterilization procedure and to monitor one or more parameters of the sterilization process. The adequacy of the sterilization conditions as measured by these parameters is indicated by a visible change in the device.(2)
Classification. Class II (performance standards).

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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left, there is a symbol representing the Department of Health & Human Services. To the right of the symbol, there is a blue square with the letters "FDA" in white. Next to the blue square, the words "U.S. FOOD & DRUG" are written in blue, with the word "ADMINISTRATION" written in a smaller font size below.

March 1, 2019

Kem Medical Products Corp. Douglas Kruger President/CEO 400 Broadhollow Road, Suite 2 Farmingdale, New York 11735

Re: K181788

Trade/Device Name: Lead-free Chemical Indicators for Steam Sterilization Regulation Number: 21 CFR 880.2800 Regulation Name: Sterilization Process Indicator Regulatory Class: Class II Product Code: JOJ Dated: January 17, 2019 Received: January 18, 2019

Dear Douglas Kruger:

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 mav, 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 avare 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.html; 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) K181788

Device Name

Lead-free Chemical Indicators for Steam Sterilization

Indications for Use (Describe)

The Kem Medical Lead-free Chemical Indicators for Steam Sterilization are designed for use by a health care provider to demonstrate that the unit or load has been exposed to a steam sterilization process, and to distinguish between processed and unprocessed units or loads. Use the Kem Medical Lead-free Chemical Indicators for Steam Sterilization in the validated steam sterilization processes described below:

*Gravity: 121 C/250 F - 30 minutes (wrapped/porous)

*Gravity: 132 C/270 F - 3 minutes (unwrapped/nonporous)

*Gravity: 132 C/270 F - 15 minutes (wrapped/porous)

*Gravity: 135 C/275 F - 3 minutes (unwrapped/nonporous)

  • Gravity: 135 C/275 F - 10 minutes (wrapped/porous or unwrapped/nonporous, mixed load)

  • Vacuum assisted (prevacuum): 132 C/270 F - 3 minutes (unwrapped/nonporous)

  • Vacuum assisted (prevacuum): 132 C/270 F - 4 minutes (wrapped/porous)

  • Vacuum assisted (prevacuum): 134 C/273 F - 4 minutes (wrapped/porous)

  • Vacuum assisted (prevacuum): 135 C/275 F - 3 minutes (wrapped/nonporous, mixed load)

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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www.kemmed.com

510(k) Summary For Kem Medical Lead-free Chemical Indicators for Steam Sterilization

K181788

Date of Submission: February 28, 2019

Submission Number: K181788

Contact/Owner: Douglas Kruger President/CEO Kem Medical Products Corp. 400 Broadhollow Road, Suite 2 Farmingdale, NY 11735 Phone: (631) 454-6565 Fax: (631) 454-8083 Email: dougk@kemmed.com

Trade Name: Lead-free Chemical Indicators for Steam Sterilization

Common Name: Sterilization Process Indicator for Steam

Classification Name: Indicator, Physical/Chemical Sterilization Process (21 CFR800.2800, Product Code JOJ)

Predicate Device: 3M Comply Lead Free Process Indicators for Steam, K101528

**There have not been any prior submissions for this device. **

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www.kemmed.com

Device Summary: The Kem Medical Lead-free Chemical Indicators for Steam Sterilization provide immediate confirmation of the sterilization process. The indicator ink is lead-free and can be printed onto suitable paper substrates. As an example, the ink is printed onto adhesive-coated paper for autoclave labels, or "dots", which are removed from a poly or paper backing for use.

Technological Comparison: The predicate and our premarket device consist of chemical indicator ink printed onto paper with and without adhesive. The Kem Medical Lead-free Chemical Indicators for Steam Sterilization have the same technological characteristics of the predicate device (3M Comply Lead Free Process Indicators for Steam cleared under K101528), in design, material, chemical composition, and performance characteristics. A stated purpose of the predicate device submission was to replace the lead ink in the Comply Autoclave Tape.

Table 1- Comparison of the New Device to the Predicate
ELEMENTNEW DEVICE
K181788PREDICATE (3M)
K101528
Intended use:process indicator for steam sterilizationprocess indicator for steam sterilization
Device design Aspects:Paper dot/strip/card printed with bismuth
sulfide based chemical indicator inkPaper tape/card printed with bismuth
sulfide based chemical indicator ink
Indicator agent:Lead-free Steam Indicator InkLead-free Steam Indicator Ink
Sterilization method and cycles:*Gravity: 121 C/250 F - 30 minutes
(wrapped/porous)
*Gravity: 132 C/270 F - 3 minutes
(unwrapped/nonporous)
*Gravity: 132 C/270 F - 15 minutes
(wrapped/porous)
*Gravity: 135 C/275 F - 3 minutes
(unwrapped/nonporous)
*Gravity: 135 C/275 F - 10 minutes
(wrapped/porous or unwrapped/nonporous,
mixed load)
*Vacuum assisted (prevacuum): 132 C/270
F - 3 minutes (unwrapped/nonporous)
*Vacuum assisted (prevacuum): 132 C/270
F - 4 minutes (wrapped/porous)
*Vacuum assisted (prevacuum): 134 C/273
F - 4 minutes (wrapped/porous)
*Vacuum assisted (prevacuum): 135 C/275
F - 3 minutes (wrapped/porous or
unwrapped/nonporous, mixed load)*Gravity: 121 C/250 F - 30 minutes
(wrapped)
*Gravity: 132 C/270 F - 3 minutes
(unwrapped)
*Gravity: 132 C/270 F - 15 minutes
(wrapped)
*Gravity: 135 C/275 F - 3 minutes
(unwrapped)
*Gravity: 135 C/275 F - 10 minutes
(wrapped)
*Vacuum assisted (prevacuum): 132 C/270 F - 3 minutes (unwrapped)
*Vacuum assisted (prevacuum): 132 C/270 F - 4 minutes (wrapped)
*Vacuum assisted (prevacuum): 134 C/273 F - 3.5 minutes (unwrapped)
*Vacuum assisted (prevacuum): 134 C/273 F - 4 minutes (wrapped)

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Solutions for safe work environments

www.kemmed.com

| | | *Vacuum assisted (prevacuum): 135
C/275 F - 3 minutes (wrapped or
unwrapped) |
|--------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Endpoint specifications: | Dark brown/black color change | Dark brown/black color change |
| Shelf-life: | 1 year from date of manufacture | 18 months from date of manufacture |
| Performance Standards: | An independent study by Lexamed®
confirms that Kem Medical Lead-free
Chemical Indicators met the requirements
defined in ISO 11140-2014-1;2014
Sterilization of healthcare products-
Chemical Indicators - Part 1 General
Requirements, including:
Data supporting endpoints with
pass/fail criteria Data supporting endpoint color
stability Data supporting integrator
parameters Data supporting shelf-life | Testing that was conducted met the
process indicator requirements of the
FDA's Premarket Notification (510K)
Submissions for Chemical Indicators:
Guidance for Industry and FDA Staff, Dec.
19, 2003 and ANSI/AAMI/ISO 11140-
1:2005 Sterilization of health care
products-Chemical Indicators, Part 1:
General Requirements. |

Indications for Use: The Kem Medical Lead-free Chemical Indicators for Steam Sterilization are designed for use by a health care provider to demonstrate that the unit or load has been exposed to a steam sterilization process, and to distinguish between processed and unprocessed units or loads. Use the Kem Medical Lead-free Chemical Indicators for Steam Sterilization in the validated steam sterilization processes described below:

*Gravity: 121 C/250 F - 30 minutes (wrapped/porous)

*Gravity: 132 C/270 F - 3 minutes (unwrapped/nonporous)

*Gravity: 132 C/270 F - 15 minutes (wrapped/porous)

*Gravity: 135 C/275 F - 3 minutes (unwrapped/nonporous)

*Gravity: 135 C/275 F - 10 minutes (wrapped/porous or unwrapped/nonporous, mixed load)

  • Vacuum assisted (prevacuum): 132 C/270 F - 3 minutes (unwrapped/nonporous)

  • Vacuum assisted (prevacuum): 132 C/270 F - 4 minutes (wrapped/porous)

  • Vacuum assisted (prevacuum): 134 C/273 F - 4 minutes (wrapped/porous)

  • Vacuum assisted (prevacuum): 135 C/275 F - 3 minutes (wrapped/porous or unwrapped/nonporous, mixed load)

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www.kemmed.com

Summary for Non-Clinical Testing:

The Kem Medical Lead-free Chemical Indicators for Steam Sterilization meet all ISO 11140-1:2014 performance criteria for Type 1 steam sterilization indicators. All BIER Steam Sterilizer cycles resulted in acceptable pass/fail criteria for all temperatures and times specified. Full autoclave cycles for both Gravity and Pre-vacuum were performed showing acceptable results for all temperatures and times specified. Dry heat, Color Change Stability, and Transference/Migration testing also resulted in acceptable results for all performance criteria of 1140-1:2014. The condition of the CI color change after exposure to a steam sterilization process remained unchanged for a period of not less of 6 months from the date of exposure.

The Lexamed® study results demonstrated the Kem Medical Lead-free Type 1 Chemical Indicator can be used as an external or internal chemical indicator for use in monitoring exposure to conditions of steam sterilization for the indicated gravity and pre-vacuum sterilizer cycles and comply with all applicable requirements defined in ISO 11140-1:2014, Sterilization of healthcare products- Chemical Indicators-Part 1 General Requirements.

Conclusion: The conclusions drawn from the nonclinical tests demonstrate that Kem Medical Lead-free Chemical Indicators for Steam Sterilization are as safe, as effective, and performs as well as or better than the legally marketed devices cleared under K101528.