K Number
K191448
Device Name
Barrier Sleeves
Date Cleared
2019-10-08

(130 days)

Product Code
Regulation Number
878.4370
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Barrier Sleeves are intended to serve as a disposable barrier for dental instruments and equipment. This device is non-sterile and intended for single patient use only.
Device Description
Barrier Sleeves are made of polyethylene film and are used as accessories to dental instruments and equipment used during dental procedures. These disposable barrier sleeves are offered in various shapes and sizes to fit over and cover the intended dental instruments and equipment. The disposable Barrier Sleeves slip over the ends of the respective devices, allowing for the attachment of the devices used during dental procedures. Barrier Sleeves act as a physical barrier, augmenting existing infection control techniques, and facilitate clean-up.
More Information

Not Found

No
The device is a simple physical barrier made of polyethylene film and the description and testing focus on material properties and barrier function, with no mention of AI/ML.

No
These barrier sleeves are designed to cover dental instruments and equipment to augment infection control, not to treat a medical condition or disease.

No

The device is described as a disposable barrier for dental instruments, designed to provide a physical barrier augmenting infection control. It does not perform any diagnostic function.

No

The device description clearly states it is made of polyethylene film and is a physical barrier, indicating it is a hardware device. There is no mention of software functionality.

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

Here's why:

  • Intended Use: The intended use is clearly stated as "to serve as a disposable barrier for dental instruments and equipment." This is a physical barrier function, not a diagnostic test performed on samples from the human body.
  • Device Description: The description reinforces the physical barrier function, stating they "slip over the ends of the respective devices" and "act as a physical barrier."
  • Lack of IVD Characteristics: There is no mention of analyzing biological samples (blood, urine, tissue, etc.), detecting specific substances, or providing diagnostic information about a patient's health condition.
  • Performance Studies: The performance studies focus on the physical properties of the barrier material (biocompatibility, resistance to penetration, tensile strength, tear resistance, puncture resistance), which are relevant to its function as a physical barrier, not an IVD.

IVD devices are specifically designed to perform tests on samples taken from the human body to provide information for diagnosis, monitoring, or screening. This device does not fit that description.

N/A

Intended Use / Indications for Use

Barrier Sleeves are intended to serve as a disposable barrier for dental instruments and equipment. This device is nonsterile and intended for single patient use only.

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

PEM

Device Description

Barrier Sleeves are made of polyethylene film and are used as accessories to dental instruments and equipment used during dental procedures. These disposable barrier sleeves are offered in various shapes and sizes to fit over and cover the intended dental instruments and equipment. The disposable Barrier Sleeves slip over the ends of the respective devices, allowing for the attachment of the devices used during dental procedures. Barrier Sleeves act as a physical barrier, augmenting existing infection control techniques, and facilitate clean-up.

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

Not Found

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: The sponsor provided biocompatibility testing for the subject device, including Cytotoxicity study using the ISO Elution Method ISO 10993-5, the ISO 10993-10 Guinea Pig Maximization Sensitization Test and the ISO 10993-10 Intracutaneous Study in Rabbits-Irritation test. A Toxicological statement was also included. The performance of the proposed device, Barrier Sleeves, met the requirements of the biocompatibility testing conducted to support substantial equivalence with the primary predicate, Disposable Barrier Sleeves and Covers (K160232).

Bench testing of the subject device, Barrier Sleeves, met the requirements of the non-clinical bench testing conducted to support substantial equivalence with the primary predicate, Disposable Barrier Sleeves and Covers (K160232). Testing performed included:

  • ASTM F1670/F1670M Standard Test Method for Resistance of Materials Used in Protective Clothing to Penetration by Synthetic Blood
  • ASTM F1671/F1671M Standard Test Method for Resistance of Materials Used in Protective Clothing to Penetration by Blood-Borne Pathogens Using Phi-X174 Bacteriophage Penetration as a Test System
  • ASTM D882 Standard Test Methods for Tensile Properties of Thin Plastic Sheeting
  • ASTM F1342/F1342M Standard Test Method for Protective Clothing Material Resistance to Puncture
  • ASTM D1004 Standard Test Method for Tear Resistance (Graves Tear) of Plastic Film and Sheeting

The range of mechanical properties for the samples of the proposed devices, Barrier Sleeves, is comparable to those reported for the predicate device, Disposable Barrier Sleeves and Covers (K160232). The results indicate the subject device passed performance testing under the conditions of the tests, and support the substantial equivalence of the subject device, Barrier Sleeves to its primary predicate, Disposable Barrier Sleeves and Covers (K160232).

Clinical Performance Data: No data from human clinical studies have been included to support the substantial equivalence of the proposed devices, Barrier Sleeves as clinical studies are not required for this medical device.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K160232

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

§ 878.4370 Surgical drape and drape accessories.

(a)
Identification. A surgical drape and drape accessories is a device made of natural or synthetic materials intended to be used as a protective patient covering, such as to isolate a site of surgical incision from microbial and other contamination. The device includes a plastic wound protector that may adhere to the skin around a surgical incision or be placed in a wound to cover its exposed edges, and a latex drape with a self-retaining finger cot that is intended to allow repeated insertion of the surgeon's finger into the rectum during performance of a transurethral prostatectomy.(b)
Classification. Class II (special controls). The device, when it is an ear, nose, and throat surgical drape, a latex sheet drape with self-retaining finger cot, a disposable urological drape, a Kelly pad, an ophthalmic patient drape, an ophthalmic microscope drape, an internal drape retention ring (wound protector), or a surgical drape that does not include an antimicrobial agent, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 878.9.

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Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo features the letters 'FDA' in a blue square, followed by the words 'U.S. FOOD & DRUG ADMINISTRATION' in blue text.

October 8, 2019

Ivoclar Vivadent, AG % Lori Aleshin Director of Quality & Regulatory Affairs Ivoclar Vivadent, Inc. 175 Pineview Drive Amherst, New York 14228

Re: K191448

Trade/Device Name: Barrier Sleeves Regulation Number: 21 CFR 878.4370 Regulation Name: Surgical Drape and Drape Accessories Regulatory Class: Class II Product Code: PEM Dated: June 26, 2019 Received: July 10, 2019

Dear Lori Aleshin:

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

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statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) 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 (QS) 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 Srinivas Nandkumar, Ph.D. Acting Director DHT1B: Division of Dental Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Quality Center for Devices and Radiological Healthh

Enclosure

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Indications for Use

510(k) Number (if known) K191448

Device Name Barrier Sleeve

Indications for Use (Describe)

Barrier Sleeves are intended to serve as a disposable barrier for dental instruments and equipment. This device is nonsterile and intended for single patient use only.

Type of Use (Select one or both, as applicable)

X Prescription Use (Part 21 CFR 801 Subpart D)

_ Over-The-Counter Use (21 CFR 801 Subpart C)

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Image /page/3/Picture/1 description: The image shows the logo for Ivoclar Vivadent. The logo is in blue and green, with the words "Ivoclar Vivadent" in a bold, sans-serif font. Below the company name is the tagline "passion vision innovation" in a smaller, sans-serif font. The logo also includes a series of green and blue dots and squares arranged in an arc above the company name.

Submitter Information:

Lori Aleshin, Director of Quality and Requlatory Affairs lvoclar Vivadent. Inc. 175 Pineview Drive Amherst, New York 14228 716-264-2045 lori.aleshin@ivoclarvivadent.com

Company: Ivoclar Vivadent, AG Bendererstrasse 2, Schaan, FL-9494, Liechtenstein +423-235-3535

Date Prepared: October 7, 2019

Device Name:

Proprietary Name:Barrier Sleeves
Classification Name:Surgical Drape and Drape Accessories
CFR Number:(878.4370)
Device Class:II
Product CodePEM

Predicate Device: Disposable Barrier Sleeves and Covers (K160232) by DENTSPLY International Inc.

Device Description: Barrier Sleeves are made of polyethylene film and are used as accessories to dental instruments and equipment used during dental procedures. These disposable barrier sleeves are offered in various shapes and sizes to fit over and cover the intended dental instruments and equipment. The disposable Barrier Sleeves slip over the ends of the respective devices, allowing for the attachment of the devices used during dental procedures. Barrier Sleeves act as a physical barrier, augmenting existing infection control techniques, and facilitate clean-up.

Indications for Use: Barrier Sleeves are intended to serve as a disposable barrier for dental instruments and equipment. This device is non-sterile and intended for single patient use only

Intended UsePredicate deviceBarrier Sleeves
IndicationsDisposable Barrier Sleeves and Covers are intended
to serve as a disposable barrier for dental instruments
and equipment. This device is non-sterile and in-
tended for single patient use only.Barrier Sleeves are intended to serve
as a disposable barrier for dental
instruments and equipment. This de-
vice is non-sterile and intended for
single patient use only.
Precaution
Measures/
ContraindicationsNoneNone
Summary of IndicationsThe indications and contraindications for the predicate and the new device are
the same.
TechnologyPredicate deviceBarrier Sleeves
Working principleDisposable Barrier Sleeves and
Covers, are made of
polyethylene film and are used
as accessories to dental
instruments and equipment
used during dental procedures.
These disposable barrier
sleeves and covers are offered
in various shapes and sizes to
fit over and cover the intended
dental instruments and
equipment. The Disposable
Barrier Sleeves slip over the
ends of the respective devices,
allowing for the attachment
and/or protrusion (where
applicable) of those parts of the
devices used during dental
procedures. The Disposable
Barrier Cover is placed over
equipment, such as dental chair
head rests or trays, to cover
those parts.
Disposable Barrier Sleeves
and Covers act as a physical
barrier, augmenting existing
infection control techniques and
facilitate clean-up.Disposable Barrier Sleeves are made of
polyethylene film and are used as
accessories to dental instruments and
equipment used during dental procedures.
These disposable barrier sleeves are
offered in various shapes and sizes to fit
over and cover the intended dental
instruments and equipment. The
Disposable Barrier Sleeves slip over the ends
of the respective de- vices, allowing for the
attachment of those parts of the devices used
during dental procedures.
Disposable Barrier Sleeves act as a physical
barrier, augmenting existing infection control
techniques, and facilitate clean-up.
Summary Principles of
operationThe working principle for both groups of devices is the same: the disposable
barrier sleeves are placed over the devices. The form fits over the intended
devices. The working principle is equivalent.
Delivery forms/dosageThere are several sleeves and
covers for dental instruments
and equipment.There are several sleeves for dental
instruments and equipment.
Summary of Delivery form
contentIn the Clearance letter K160232 several sleeves and covers are listed. For the
new devices (Bluephase Sleeves and Vivapen Sleeves) there are supposed to
be 2 articles, which differ in the size of the sleeve. The sleeves perfectly fit over
Ivoclar Vivadent`s curing lights (Bluephase) and Vivapen (applicator for
liquids).
Shelf lifeSupplier report is 5 years
Summary of shelf lifeShelf life for the predicate is not known. The claimed shelf life for the new
devices (Bluephase and Vivapen Sleeves) is 5 years as recommended by the
manufacturer of the sleeves. Storage Stability report was provided.
Principles of operationThe disposable barrier sleeves and covers fit over and cover the intended dental
instruments and equipment.
Summary of OperationThe principle of operation is the same.
Material CompositionPredicate deviceBarrier Sleeves
MaterialPolyethylene filmPolyethylene film
Material compositionLow density polyethylene filmLow density polyethylene film
Summary of Material
CompositionNo difference. The predicate and the new device are manufactured by the
same supplier (Minitube AB, Sweden) and made of the same material.
BiocompatibilityPredicate deviceBarrier Sleeves
Cytotoxicity - ISO 10993-5Non-cytototoxicNon-cytototoxic
Sensitization/Irritation – ISO
10993-10Non-sensitizing, non-irritatingNon-sensitizing, non-irritating
Summary of BiocompatibilityNo difference. The predicate and the new device are manufactured by the
same supplier (Minitube AB, Sweden) and made of the same material. The
results of Biocompatibility testing are included in this submission.
Performance PropertiesPredicate deviceBarrier Sleeves
Synthetic Blood Penetration
ASTM F1670/F1670MPassPass
Synthetic Blood Penetration at
seams and non-continuous
components ASTM
F1670/F1670MPassPass
Viral penetration ASTM
F1671/F1671MPassPass
Viral penetration at seams and
non- continuous components
ASTM F1671/F1671MPassPass
SummaryNo difference. The predicate and the new device are manufactured by the
same supplier (Minitube AB, Sweden) and made of the same material. The
results of Performance testing are included in this submission.
Mechanical PropertiesPredicate deviceBarrier Sleeves
Tensile strength ASTM D8820.03 mm - acceptable0.03 mm - acceptable
Puncture Resistance ASTM
F1342/F1342M0.03 mm - acceptable0.03 mm - acceptable
Tear Resistance ASTM D10040.03 mm – acceptable0.03 mm - acceptable
SummaryNo difference. The predicate and the new device are manufactured by the same supplier (Minitube AB, Sweden) and made of the same material. The results of Mechanical Properties testing are included in this submission.
Device CharacteristicsPredicate deviceBarrier Sleeves
Thickness0.03 mm (Minitube AB, Sweden)0.03 mm (Minitube AB, Sweden)
ShapeCustom design to fit the intended dental instruments and equipment they coverCustom design to fit the intended dental instruments and equipment they cover
DimensionsDetermined by the size and shape of the dental instruments and equipment they coverDetermined by the size and shape of the dental instruments and equipment they cover
Colorclearclear
SterileNot sterileNot sterile
Single UseSingle use deviceSingle use device
SummaryThe new and the predicate devices are made of the same material by the same supplier (Minitube AB, Sweden). Both devices are not sterile, for single use and differ only in the shape and the dimensions as the need to fit over different types of devices

Comparison to Predicate:

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passion vision innovation

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Image /page/5/Picture/1 description: The image shows the logo for Ivoclar Vivadent, a dental company. The logo features the company name in a stylized font, with the words "passion vision innovation" written below. Above the company name is a series of green and blue dots arranged in an arc. The number 3 is in the upper right corner of the image.

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Image /page/6/Picture/1 description: The image contains the number 4 in the upper right corner. The image also contains the logo for Ivoclar Vivadent. The logo is blue and green and contains the words "Ivoclar Vivadent: passion vision innovation".

Infection Control:

The device is sold in a non-sterile condition.

Non-Clinical Performance Data:

The sponsor provided biocompatibility testing for the subject device. Direct contact with tissue is not intended. Therefore ISO 10993-1 is not applicable. Biocompatibility testing included Cytotoxicity study using the ISO Elution Method ISO 10993-5, the ISO 10993-10 Guinea Pig Maximization Sensitization Test and the ISO 10993-10 Intracutaneous Study in Rabbits-Irritation test. A Toxicological statement was also included. The performance of the proposed device, Barrier Sleeves, met the requirements of the biocompatibility testing conducted to support substantial equivalence with the primary predicate, Disposable Barrier Sleeves and Covers (K160232).

The performance testing (Bench) of the subject device, Barrier Sleeves, met the requirements of the non-clinical bench testing conducted to support substantial equivalence with the primary predicate, Disposable Barrier Sleeves and Covers (K160232). Below is a summary of the testing performed:

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Image /page/7/Picture/1 description: The image shows the logo for Ivoclar Vivadent, a dental company. The logo features the company name in a stylized font, with the words "passion vision innovation" written below. Above the company name is a series of green and blue dots and squares arranged in an arc shape.

  • ASTM F1670/F1670M Standard Test Method for Resistance of Materials Used in ● Protective Clothing to Penetration by Synthetic Blood
  • . ASTM F1671/ F1671M Standard Test Method for Resistance of Materials Used in Protective Clothing to Penetration by Blood-Borne Pathogens Using Phi-X174 Bacteriophage Penetration as a Test System

| Mechanical
Property | Standard | Proposed Device
Barrier Sleeves | Predicate Device
Disposable Barrier
Sleeves and Covers
(K160232) |
|------------------------|--------------------------|-------------------------------------|---------------------------------------------------------------------------|
| Tensile Strength | ASTM D882 | 0.03mm - Comparable
to Predicate | Acceptable for
0.03mm |
| Puncture
Resistance | ASTM
F1342/
F1342M | 0.03mm - Comparable
to Predicate | Acceptable for
0.03mm |
| Tear Resistance | ASTM
D1004 | 0.03mm Comparable
to Predicate | Acceptable for
0.03mm |

The range of mechanical properties for the samples is reported for the proposed devices. Barrier Sleeves. Below is a summary of the testing performed:

  • . ASTM D882 Standard Test Methods for Tensile Properties of Thin Plastic Sheeting
  • ASTM F1342/ F1342M Standard Test Method for Protective Clothing Material ● Resistance to Puncture
  • ASTM D1004 Standard Test Method for Tear Resistance (Graves Tear) of Plastic Film and Sheeting

The range of mechanical properties for the samples of the proposed devices, Barrier Sleeves, is comparable to those reported for the predicate device. Disposable Barrier Sleeves and Covers (K160232). The results indicate the subject device passed performance testing under the conditions of the tests, and support the substantial equivalence of the subject device, Barrier Sleeves to its primary predicate, Disposable Barrier Sleeves and Covers (K160232).

Clinical Performance Data:

No data from human clinical studies have been included to support the substantial equivalence of the proposed devices, Barrier Sleeves as clinical studies are not required for this medical device.

Conclusions Regarding Substantial Equivalence;

The proposed device, Barrier Sleeves, consists of dental barrier sleeves and covers which are intended to serve as a disposable barrier for dental instruments and equipment. These barrier sleeves are non-sterile and are intended for single patient use only. The proposed device, Barrier Sleeves, have the same intended use and indications for use and incorporate the same fundamental technology and working principle, as the primary predicate device, Disposable Barrier Sleeves and Covers, cleared under premarket notification (K160232). Test data to verify the

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Image /page/8/Picture/1 description: The image shows the Ivoclar Vivadent logo. The logo is blue and green. The word "Ivoclar" is on top of the word "Vivadent".

ssion vision innovation

performance of the proposed device, Barrier Sleeves, have been provided, including cytotoxicity, skin sensitization, oral mucosa irritation, synthetic blood penetration, synthetic blood penetration at seams and non-continuous components, viral penetration and viral penetration at seams and non-continuous components. The range of mechanical properties has been provided for puncture resistance, tear resistance, and tensile strength. The test results, combined with the design, intended use and mechanical property comparisons with the primary predicate device, support the substantial equivalence of the proposed Barrier Sleeves with its primary predicate device Disposable Barrier Sleeves and Covers (K160232).

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Image /page/9/Picture/1 description: The image shows the logo for Ivoclar Vivadent, a dental company. The logo features the company name in a stylized font, with the words "passion vision innovation" underneath. To the right of the logo is the number 7.

Chemical composition / Biocompatibility / Shelf life The chemical composition is identical. The biocompatibility of both device groups is the same as the devices are of the same material. The shelf life of the new devices is limited to 5 years on the recommendation of the material supplier.

Device performance The device performance is the same for both groups of barriers and sleeves.