K Number
K190152
Device Name
Vit Kit- Freeze NX and Vit Kit- Warm NX
Date Cleared
2019-06-21

(142 days)

Product Code
Regulation Number
884.6180
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Vit Kit - Freeze NX (Vitrification Freeze Kit) is intended for use in the vitrification of oocytes (MI) and pronuclear (PN) zygotes through day 3 cleavage stage embryos and blastocyst stage embryos. Vit Kit - Warm NX (Vitrification Warm Kit) is intended for use in the thawing of vitrified occytes (MII) and pronuclear (PN) zygotes through day 3 cleavage stage embryos and blastocyst stage embryos.
Device Description
The five media products that comprise the two kits, Vit Kit - Freeze NX and Vit Kit -Warm NX, consist of a basal media of Continuous Single Culture Medium (CSCM) which utilizes MOPS, HEPES and sodium bicarbonate buffers, 20% (v/v) DSS, 10μg/mL gentamicin and varying levels of cryoprotectants, including dimethyl sulfoxide (DMSO), trehalose, and ethylene glycol (EG). The two freeze media in the Vit Kit – Freeze NX are intended to be used sequentially for the preparation and cryopreservation of oocytes (MII) and pronuclear (PN) zygotes through day 3 cleavage stage embryos and blastocyst stage embryos. The three media in the Vit Kit - Warm NX are intended for sequential use in the thawing and recovery of cryopreserved oocytes (MII) and pronuclear (PN) zygotes through day 3 cleavage stage embryos and blastocyst stage embryos.
More Information

Not Found

No
The device description focuses on the chemical composition and intended use of cryopreservation media, with no mention of AI or ML technologies.

No
This device is a cryopreservation medium used for vitrification and thawing of oocytes and embryos, which are biological samples, not for directly treating a disease or condition in a patient.

No

This device is intended for the vitrification and thawing of oocytes and embryos, which are preservation and recovery processes, not diagnostic procedures. It does not analyze or interpret biological samples to determine a medical condition or predict an outcome.

No

The device description clearly states that the device consists of "five media products" which are chemical solutions used for vitrification and thawing. This 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 for the vitrification (freezing) and thawing of oocytes and embryos. This is a process performed outside the body to preserve biological material for future use in assisted reproductive technology (ART).
  • Device Description: The device consists of media products containing cryoprotectants. These media are used to facilitate the freezing and thawing process of the biological samples.
  • Lack of Diagnostic Purpose: The description does not mention any intention to diagnose a disease, condition, or state of health. It's a tool for preserving and recovering biological samples.
  • No Analysis of Samples for Diagnostic Information: The device is used to treat the samples (oocytes and embryos) for preservation, not to analyze them to gain diagnostic information about a patient.

IVD devices are typically used to examine specimens (like blood, urine, tissue) in vitro to provide information for the diagnosis, monitoring, or treatment of a disease or condition. This device's function is purely for the preservation and recovery of reproductive cells and embryos.

N/A

Intended Use / Indications for Use

Vit Kit - Freeze NX (Vitrification Freeze Kit) is intended for use in the vitrification of oocytes (MI) and pronuclear (PN) zygotes through day 3 cleavage stage embryos and blastocyst stage embryos.

Vit Kit - Warm NX (Vitrification Warm Kit) is intended for use in the thawing of vitrified occytes (MII) and pronuclear (PN) zygotes through day 3 cleavage stage embryos and blastocyst stage embryos.

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

MQL

Device Description

The five media products that comprise the two kits, Vit Kit - Freeze NX and Vit Kit -Warm NX, consist of a basal media of Continuous Single Culture Medium (CSCM) which utilizes MOPS, HEPES and sodium bicarbonate buffers, 20% (v/v) DSS, 10μg/mL gentamicin and varying levels of cryoprotectants, including dimethyl sulfoxide (DMSO), trehalose, and ethylene glycol (EG).

The two freeze media in the Vit Kit – Freeze NX are intended to be used sequentially for the preparation and cryopreservation of oocytes (MII) and pronuclear (PN) zygotes through day 3 cleavage stage embryos and blastocyst stage embryos.

The three media in the Vit Kit - Warm NX are intended for sequential use in the thawing and recovery of cryopreserved oocytes (MII) and pronuclear (PN) zygotes through day 3 cleavage stage embryos and blastocyst stage embryos.

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

Prescription Use

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)

Non-clinical Performance Data:

Vit Kit - Freeze NX and Vit Kit - Warm NX media were tested for the following performance characteristics at baseline and following accelerated aging (per ASTM F1980-16):

  • . Appearance
  • . pH (per USP )
  • Osmolality (per USP ) .
  • Endotoxin (per USP ) .
  • . Sterility (per USP )
  • . Mouse Embryo Assay

The following additional assessments were performed on the subject device:

  • Simulated Distribution and Handling per ASTM D4169-16 .
    The subject device passed the predefined acceptance criteria for these tests.

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.

K160006

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

§ 884.6180 Reproductive media and supplements.

(a)
Identification. Reproductive media and supplement are products that are used for assisted reproduction procedures. Media include liquid and powder versions of various substances that come in direct physical contact with human gametes or embryos (including water, acid solutions used to treat gametes or embryos, rinsing solutions, sperm separation media, supplements, or oil used to cover the media) for the purposes of preparation, maintenance, transfer or storage. Supplements are specific reagents added to media to enhance specific properties of the media (e.g., proteins, sera, antibiotics, etc.).(b)
Classification. Class II (special controls) (mouse embryo assay information, endotoxin testing, sterilization validation, design specifications, labeling requirements, biocompatibility testing, and clinical testing). The device, when it is phosphate-buffered saline used for washing, and short-term handling and manipulation of gametes and embryos; culture oil used as an overlay for culture media containing gametes and embryos; and water for assisted reproduction applications, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 884.9.

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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 is the Department of Health & Human Services logo. To the right of that is the FDA logo, which consists of the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.

June 21, 2019

FUJIFILM Irvine Scientific, Inc. Jayme Yamaguchi-Owens Regulatory Affairs Manager 2511 Daimler Street Santa Ana, CA 92705

Re: K190152

Trade/Device Name: Vit Kit- Freeze NX and Vit Kit- Warm NX Regulation Number: 21 CFR 884.6180 Regulation Name: Reproductive media and supplements Regulatory Class: II Product Code: MQL Dated: May 17, 2019 Received: May 20, 2019

Dear Jayme Yamaguchi-Owens:

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/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

For Sharon M. Andrews Assistant Division Director DHT3B: Division of Reproductive. Gynecology and Urology Devices OHT3: Office of Gastrorenal, ObGyn, General Hospital and Urology Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K190152

Device Name Vit Kit - Freeze NX Vit Kit - Warm NX

Indications for Use (Describe)

Vit Kit - Freeze NX (Vitrification Freeze Kit) is intended for use in the vitrification of oocytes (MI) and pronuclear (PN) zygotes through day 3 cleavage stage embryos and blastocyst stage embryos.

Vit Kit - Warm NX (Vitrification Warm Kit) is intended for use in the thawing of vitrified occytes (MII) and pronuclear (PN) zygotes through day 3 cleavage stage embryos and blastocyst stage embryos.

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

K190152

l. General Information on Submitter

| Submitted/Address | FUJIFILM, Irvine Scientific, Inc.
2511 Daimler Street
Santa Ana, CA 92705
Telephone: 800-437-5706
Facsimile: 949-261-6522 |

----------------------------------------------------------------------------------------------------------------------------------------------------------

Contact Person: Jayme Yamaguchi-Owens FUJIFILM Irvine Scientific, Inc. 2511 Daimler Street Santa Ana, CA 92705 Telephone: 800-437-5706 949-261-6522 Facsimile: Email: see below Jayme.yamaguchi-owens@fujifilm.com

II.Date Prepared:June 20, 2019
III.General Information
Device Name:Vit Kit - Freeze NX
Vit Kit - Warm NX
Common Name:
Warming KitVitrification Cryopreservation Media and

Regulatory Class: Class II

Regulation Number:

Regulation Name:

MQL (Media, Reproductive) Product Code:

21 CFR 884.6180

Reproductive Media and Supplements

  • IV. Predicate Device: Vit Kit - Freeze, Vit Kit - Thaw K160006, Irvine Scientific
    The predicate device has not been subject to a design related recall.

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V. Description of the Device:

The five media products that comprise the two kits, Vit Kit - Freeze NX and Vit Kit -Warm NX, consist of a basal media of Continuous Single Culture Medium (CSCM) which utilizes MOPS, HEPES and sodium bicarbonate buffers, 20% (v/v) DSS, 10μg/mL gentamicin and varying levels of cryoprotectants, including dimethyl sulfoxide (DMSO), trehalose, and ethylene glycol (EG).

The two freeze media in the Vit Kit – Freeze NX are intended to be used sequentially for the preparation and cryopreservation of oocytes (MII) and pronuclear (PN) zygotes through day 3 cleavage stage embryos and blastocyst stage embryos.

The three media in the Vit Kit - Warm NX are intended for sequential use in the thawing and recovery of cryopreserved oocytes (MII) and pronuclear (PN) zygotes through day 3 cleavage stage embryos and blastocyst stage embryos.

VI. Indications for Use:

Vit Kit - Freeze NX (Vitrification Freeze Kit) is intended for use in the vitrification of oocytes (MII) and pronuclear (PN) zygotes through day 3 cleavage stage embryos and blastocyst stage embryos.

Vit Kit - Warm NX (Vitrification Warm Kit) is intended for use in the thawing of vitrified oocytes (MII) and pronuclear (PN) zygotes through day 3 cleavage stage embryos and blastocyst stage embryos.

VII. Predicate Device Comparison

The table below shows a comparison of the intended use and technological characteristics of the subject device and predicate device.

Table 1: Comparison of Characteristics

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| | Subject Device
K190152 | Predicate Device
K160006 | |
|----------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Characteristic | Vit Kit - Freeze NX
Vit Kit - Warm NX | Vit Kit - Freeze
Vit Kit - Thaw | Comparison |
| Indications for
Use | Vit Kit - Freeze NX
(Vitrification Freeze
Kit) is intended for
use in the
vitrification of
oocytes (MII) and
pronuclear (PN)
zygotes through
day 3 cleavage
stage embryos and
blastocyst stage
embryos.

Vit Kit - Warm NX
(Vitrification Warm
Kit) is intended for
use in the thawing
of vitrified oocytes
(MII) and
pronuclear (PN)
zygotes through
day 3 cleavage
stage embryos and
blastocyst stage
embryos. | Vit Kit - Freeze
(Vitrification Freeze
Kit) is intended for
use in the
vitrification of
oocytes (MII),
pronuclear (PN)
zygotes through
day 3 cleavage
stage embryos and
blastocyst stage
embryos.

Vit Kit - Thaw
(Vitrification Thaw
Kit) is intended for
use in the thawing
of vitrified oocytes
(MII), pronuclear
(PN) zygotes
through day 3
cleavage stage
embryos and
blastocyst stage
embryos. | There are minor
differences in
wording, but the
intended uses are
the same. |
| Components | Vitrification Media | Vitrification Media | Identical |
| | Subject Device
K190152 | Predicate Device
K160006 | Comparison |
| Characteristic | Vit Kit - Freeze NX
Vit Kit - Warm NX | Vit Kit - Freeze
Vit Kit - Thaw | |
| | Thawing Media | Thawing Media | |
| | Media Components | | |
| Vitrification
Media | CSCM | Medium 199 | The predicate and
subject device
formulations are
similar. The
predicate device
uses sucrose instead
of trehalose and it |
| | EG (7.5, 15%) | EG (7.5, 15%) | |
| | DMSO (7.5, 15%) | DMSO (7.5, 15%) | |
| | Trehalose (0.5M) | Sucrose (0.5M) | |
| | DSS | DSS | uses a HEPES buffer |
| | HSA | HSA | |
| | Gentamicin | Gentamicin | instead of a dual
zwitterionic buffer. |
| | Sodium
Bicarbonate | Sodium
Bicarbonate | |
| | HEPES | HEPES | |
| | MOPS | | |
| Thawing
Formulation | CSCM | Medium 199 | The predicate and
subject device
formulations are
similar. The
predicate device
uses sucrose instead
of trehalose and it
uses a HEPES buffer |
| | Trehalose
(0.5M,
1.0M) | Sucrose
(0.5M,
1.0M) | |
| | Dextran | Dextran | |
| | HSA | HSA | |
| | Gentamicin | Gentamicin | instead of a dual |
| | Sodium
Bicarbonate | Sodium
Bicarbonate | zwitterionic buffer. |
| | HEPES | HEPES | |
| Characteristic | Subject Device
K190152 | Predicate Device
K160006 | Comparison |
| | Vit Kit - Freeze NX
Vit Kit - Warm NX
MOPS | Vit Kit - Freeze
Vit Kit - Thaw | |
| Endotoxin | ≤ 0.6 EU/mL | ≤ 0.6 EU/mL | Identical |
| MEA | ≥ 80% expanded
blastocyst after 96
hours in culture | ≥ 80% expanded
blastocyst after 96
hours in culture | Identical |
| pH | ES: 7.05 - 7.44
VS: 7.05 - 7.44
TS: 7.05 - 7.45
DS: 7.05-7.45
WS: 7.05 - 7.45 | ES: 7.05 – 7.54
VS: 7.05 - 7.54
TS: 7.05-7.44
DS: 7.05-7.44
WS: 7.05-7.44 | The predicate and
subject device
specifications are
similar. |
| | | | |
| Osmolality
(mOsm/KgH2O) | ES: 1,150 - 1,1550
VS: 1,220-1,620
TS: 1,550-1,900
DS: 830-930
WS: 265-300 | ES: 1,055-1,445
VS: 1,100-1,588
TS: 1,732-1,912
DS: 857-910
WS: 268-292 | The osmolality
specifications are
similar. |
| | | | |
| Sterilization
Method | Aseptic Filtration | Aseptic Filtration | Identical |

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As shown in the table above, the intended use of the subject and predicate device is the same. The technological characteristics of the subject and predicate device are different - the subject device formulation utilizes trehalose instead of sucrose, has a different basal medium formulation, and different osmolality and pH specifications. However, different types of safety and effectiveness questions are not raised by these differences in technological characteristics.

8

Non-clinical Performance Data:

Vit Kit - Freeze NX and Vit Kit - Warm NX media were tested for the following performance characteristics at baseline and following accelerated aging (per ASTM F1980-16):

  • . Appearance
  • . pH (per USP )
  • Osmolality (per USP ) .
  • Endotoxin (per USP ) .
  • . Sterility (per USP )
  • . Mouse Embryo Assay

The following additional assessments were performed on the subject device:

  • Simulated Distribution and Handling per ASTM D4169-16 .
    The subject device passed the predefined acceptance criteria for these tests.

VIII. Conclusion:

The results of the testing described above provide demonstrate that the subject device is as safe and effective as the predicate device and supports and determination of substantial equivalence.