K Number
K191658
Device Name
IV Sets not made with PVC
Date Cleared
2020-03-19

(272 days)

Product Code
Regulation Number
880.5440
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The IV Administration Sets not made with PVC are intravenous administration sets intended for delivery of fluids from a container into a patient's vascular system. The IV Extension Sets not made with PVC may be used for direct injection, intermittent infusion, continuous infusion or aspiration of fluids, medications, blood and blood products.
Device Description
The IV Sets not made with PVC are gravity, single use, disposable, IV administration sets and extension sets. IV administration sets are used to deliver fluids from a container into a patient's vascular system. The IV extension sets are used for direct injection, intermittent infusion, continuous infusion or aspiration. These sets may be comprised of various components, which are broadly used throughout industry including insertion spikes, drip chambers, clamps, needleless luer access devices, check valves, tubing, filters, stopcocks and luer connections (connector, adaptor). The proposed sets have not been made with polyvinylchloride (PVC). The tubing in these sets is made of polyurethane (PUR).
More Information

Not Found

No
The summary describes standard IV administration and extension sets and does not mention any AI or ML components or functionalities.

No.
The device is used for fluid delivery and aspiration, not for treating a disease or condition.

No

Explanation: The device is an intravenous administration set used for delivering fluids or medications to a patient's vascular system. Its function is to administer, not to diagnose, conditions or diseases.

No

The device description clearly outlines physical components like tubing, spikes, drip chambers, clamps, etc., and the performance studies focus on physical and material properties, not software functionality.

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

Here's why:

  • Intended Use: The intended use clearly states the device is for "delivery of fluids from a container into a patient's vascular system" and for "direct injection, intermittent infusion, continuous infusion or aspiration of fluids, medications, blood and blood products." This describes a device used in vivo (within the body) for administering substances, not for testing samples in vitro (outside the body).
  • Device Description: The description details components like insertion spikes, drip chambers, tubing, and luer connections, all consistent with devices used for intravenous administration.
  • Lack of IVD Characteristics: There is no mention of the device being used to analyze biological samples (like blood, urine, or tissue) to provide diagnostic information. The performance studies focus on the physical and functional performance of the set for fluid delivery, not on the accuracy or reliability of diagnostic results.

Therefore, this device falls under the category of a medical device used for therapeutic or supportive purposes, not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

The IV Administration Sets not made with PVC are intravenous administration sets intended for delivery of fluids from a container into a patient's vascular system.

The IV Extension Sets not made with PVC may be used for direct injection, intermittent infusion, continuous infusion or aspiration of fluids, medications, blood and blood products.

Product codes

FPA

Device Description

The IV Sets not made with PVC are gravity, single use, disposable, IV administration sets and extension sets. IV administration sets are used to deliver fluids from a container into a patient's vascular system. The IV extension sets are used for direct injection, intermittent infusion, continuous infusion or aspiration.

These sets may be comprised of various components, which are broadly used throughout industry including insertion spikes, drip chambers, clamps, needleless luer access devices, check valves, tubing, filters, stopcocks and luer connections (connector, adaptor).

The proposed sets have not been made with polyvinylchloride (PVC). The tubing in these sets is made of polyurethane (PUR).

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

patient's vascular system

Indicated Patient Age Range

for any patient population

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 testing was completed with the proposed IV Sets not made with PVC to demonstrate that the sets perform as intended. The test results demonstrated that the proposed device considered the following standards:
ISO 8536-4: "Infusion equipment for medical use - Part 4: Infusion sets for single use, gravity feed"
ISO 8536-14: "Infusion Equipment For Medical Use – Part 14: Clamps and flow regulator for transfusion and infusion equipment without fluid contact"
ISO 10993-1: "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process"

  • Cytotoxicity Sensitization Irritation Systemic Toxicity Hemocompatibility Genotoxicity Material Mediated Pyrogenicity SubChronic Toxicity
    ISO 11135, "Sterilization of health care products – Ethylene oxide – Requirements for development, validation and routine control of a sterilization process for medical devices"
    ISO 80369-7, "Small-bore connectors for liquids and gases in healthcare applications- Part 7: Connectors for intravascular or hypodermic applications"
    ASTM F2096, "Standard Test Method for Detecting Gross Leaks in Medical Packaging by Internal Pressurization (Bubble Test)"
    In addition, the following functional and performance tests were successfully completed to demonstrate that the IV Administration Sets perform as intended.
  • · Particulate Contamination (USP 788 and ISO 8536-4)
  • · Microbial Ingress (leveraged from K140311)
  • Bacterial Endotoxin Testing .

Results of the testing demonstrate that the proposed device can be used according to its intended use. No clinical testing was performed as this device does not require clinical studies to demonstrate substantial equivalence with the predicate 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.

K170595, K153293

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

§ 880.5440 Intravascular administration set.

(a)
Identification. An intravascular administration set is a device used to administer fluids from a container to a patient's vascular system through a needle or catheter inserted into a vein. The device may include the needle or catheter, tubing, a flow regulator, a drip chamber, an infusion line filter, an I.V. set stopcock, fluid delivery tubing, connectors between parts of the set, a side tube with a cap to serve as an injection site, and a hollow spike to penetrate and connect the tubing to an I.V. bag or other infusion fluid container.(b)
Classification. Class II (special controls). The special control for pharmacy compounding systems within this classification is the FDA guidance document entitled “Class II Special Controls Guidance Document: Pharmacy Compounding Systems; Final Guidance for Industry and FDA Reviewers.” Pharmacy compounding systems classified within the intravascular administration set are exempt from the premarket notification procedures in subpart E of this part and subject to the limitations in § 880.9.

0

Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food & Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

March 19, 2020

B. Braun Medical Inc. Angela Caravella Sr. Regulatory Affairs Specialist 901 Marcon Boulevard Allentown, Pennsylvania 18109

Re: K191658

Trade/Device Name: IV Sets not made with PVC Regulation Number: 21 CFR 880.5440 Regulation Name: Intravascular Administration Set Regulatory Class: Class II Product Code: FPA Dated: February 14, 2020 Received: February 18, 2020

Dear Angela Caravella:

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 mediation-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,

Tina Kiang, Ph.D. Director DHT3C: Division of Drug Delivery and General Hospital Devices. and Human Factors 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) K191658

Device Name IV Sets not made with PVC

Indications for Use (Describe)

The IV Administration Sets not made with PVC are intravenous administration sets intended for delivery of fluids from a container into a patient's vascular system.

The IV Extension Sets not made with PVC may be used for direct injection, intermittent infusion, continuous infusion or aspiration of fluids, medications, blood and blood products.

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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B. Braun Medical Inc. 510(k) Premarket Notification IV Sets not made with PVC

5. 510(k) SUMMARY

510(k) Number:K191658
Date:March 17, 2020
SUBMITTER:B. Braun Medical Inc.
901 Marcon Boulevard
Allentown, PA 18109-9341
610-266-0500
Contact: Angela J. Caravella
Sr. Regulatory Affairs Specialist
Phone: (610) 596-2966
Fax: (610) 266-4962
E-mail: angela.caravella@bbraunusa.com
DEVICE NAME:IV Sets not made with PVC
COMMON NAME:Intravascular Administration Set
CLASSIFICATION:Set, Administration, Intravascular, 21 CFR 880.5440, Class II,
Product Code FPA
PREDICATE DEVICES:K170595, IV Administration Sets, B. Braun Medical Inc.
K153293, Extension Set, B. Braun Medical Inc.

DEVICE DESCRIPTION:

The IV Sets not made with PVC are gravity, single use, disposable, IV administration sets and extension sets. IV administration sets are used to deliver fluids from a container into a patient's vascular system. The IV extension sets are used for direct injection, intermittent infusion, continuous infusion or aspiration.

These sets may be comprised of various components, which are broadly used throughout industry including insertion spikes, drip chambers, clamps, needleless luer access devices, check valves, tubing, filters, stopcocks and luer connections (connector, adaptor).

The proposed sets have not been made with polyvinylchloride (PVC). The tubing in these sets is made of polyurethane (PUR).

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INDICATIONS FOR USE

The IV Administration Sets not made with PVC are intravenous administration sets intended for delivery of fluids from a container into a patient's vascular system.

The IV Extension Sets not made with PVC may be used for direct injection, intermittent infusion, continuous infusion or aspiration of fluids, medications, blood and blood products.

SUBSTANTIAL EQUIVALENCE:

The IV Sets not made with PVC are substantially equivalent to the B. Braun Medical Inc. IV Administration Sets (K170595) and the B. Braun Medical Inc. Extension Sets (K153293) predicate devices.

The predicate devices used for comparison to the IV Sets not made with PVC were utilized to demonstrate the substantial equivalence in indications for use, intended use, and design between the proposed device and the predicate devices.

The proposed IV Sets not made with PVC include IV Administration Sets and IV Extension Sets. The indications for use for the proposed IV Sets includes the indications for use from the predicate devices; IV Administration Sets and Extension Sets. The only exception is the predicate Extension Set indication for power injection compatibility. The proposed IV Sets not made with PVC are not indicated for power injection. This reduction in indications for use does not introduce a new intended use.

The intended use of the proposed IV Administration Sets not made with PVC is identical to the predicate IV Administration Sets: Delivery of fluids from a container into a patient's vascular system. The intended use of the proposed Extension Sets not made with PVC is identical to the predicate Extension Sets: Direct injection, intermittent infusion, continuous infusion or aspiration.

Comparison of Technological Characteristics with the Predicate Devices

The IV Sets not made with PVC possess similar technological characteristics to the predicate devices B. Braun Medical Inc. IV Administration Sets cleared under K170595 and B. Braun Medical Inc. Extension Sets cleared under K153293.

The two main differences between the proposed and predicate devices is in componentry: the proposed device tubing material utilizes polyurethane (PUR) within its formulation instead of polyvinylchloride (PVC) and some of the proposed devices contain an additional in-line AirStop filter. These technological differences between the proposed and predicate devices do not raise new issues of safety and effectiveness. Non-clinical testing was performed to demonstrate the differences

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did not raise new questions.

A table summarizing the comparison between the IV Sets not made with PVC to the predicate devices is provided below:

Substantial Equivalence - Comparison of Proposed Device with Predicate Devices
Proposed Device
IV Sets not made with
PVCPredicate Device
(K170595) IV
Administration SetsPredicate Device
(K153293) Extension Sets
Intended UseThe IV Administration Sets
not made with PVC are
intravenous administration
sets intended for delivery
of fluids from a container
into a patient's vascular
system.
The IV Extension Sets not
made with PVC are
intended for direct
injection, intermittent
infusion, continuous
infusion or aspiration.Delivery of fluids
from a container into a
patient's vascular
system.Intended for direct
injection, intermittent
infusion, continuous
infusion or aspiration.
Indications for
UseThe IV Administration Sets
not made with PVC are
intravenous administration
sets intended for delivery
of fluids from a container
into a patient's vascular
system.
The IV Extension Sets not
made with PVC may be
used for direct injection,
intermittent infusion,
continuous infusion or
aspiration of fluids,
medications, blood and
blood products.The IV
Administration Sets
are intravenous
administration sets
intended for delivery
of fluids from a
container into a
patient's vascular
system.
These devices
may be used for any
patient population
with consideration
given to adequacy of
vascular anatomy and
appropriateness for
the solution being
infused and durationB. Braun Extension Sets
may be used for direct
injection, intermittent
infusion, continuous
infusion or aspiration of
fluids, medications, blood
and blood products. Select
sets may be used with
power injector procedures
to a maximum pressure of
400 psi and a maximum
flow rate of 15 mL per
second. B. Braun's
optional stabilization
component on an
extension set provides
stability to an
intravascular catheter by
supporting the patient
connector.
Substantial Equivalence - Comparison of Proposed Device with Predicate Devices
Proposed Device
IV Sets not made with
PVCPredicate Device
(K170595) IV
Administration SetsPredicate Device
(K153293) Extension Sets
therapy.B. Braun Extension Sets
may be used for any
patient population.
Mode of Fluid
DeliveryGravityGravityGravity or Power
Injection
Set ComponentsSets configured with
various industry
standard components
including:
insertion spike
drip chamber
PUR tubing
luer connections
(connector/adaptor)
needleless luer access
device
stopcocks
clamps
check valve
in line filtersSets configured with
various industry
standard components
including:
insertion spike
drip chamber
PVC tubing
luer connections
(connector/adaptor)
manifold
needleless luer access
device
stopcocks
clamps
check valvePVC tubing
Luer
Slide clamp
Stabilization Component
Spin-lock connector
(patient connector/male
luer adapter)
MaterialsPUR, LDPE, HDPE, PC, PP,
PS, PE, MABS, SBC/SBS,
PTFE, Acrylic, Nylon,
Borosilicate glass fiber paper,
High impact polystyrene,
Polyamide,
Polyethersulphone,
Polyarylsulphone,
Polyvinylpyrrolidone,
Synthetic Polyisoprene,
Cyrolite, Parylene-N, Silicone
rubber, Liquid Silicone
rubber, Polydimethylsiloxane,
Cyclohexanone, Methyl Ethyl
Ketone (MEK), Methylene
Chloride (MC),
Tetrahydrofuran (THF)PVC, LDPE, HDPE,
PC, PP, ABS, Stainless
steel, MABS, Acetal,
Acrylic, Nylon, High
impact polystyrene,
Polyamide, Santoprene,
Synthetic Polyisoprene,
Cyrolite, Parylene-N.
Silicone rubber, Liquid
silicone rubber,
Polydimethylsiloxane,
Cyclohexanone,
Methylene Chloride
(MC), Tetrahydrofuran
(THF)PVC, LDPE, HDPE, PC,
PP, ABS, Methylene
Chloride (MC),
Tetrahydrofuran (THF)
Summary of
non-clinical● Visual Inspection
● IV Spike function● Luer Compliance
● Priming Test / Air● Stabilization
● Component
Substantial Equivalence - Comparison of Proposed Device with Predicate Devices
Proposed Device
IV Sets not made with
PVCPredicate Device
(K170595) IV
Administration SetsPredicate Device
(K153293) Extension Sets
tests for
determination
of substantial
equivalence• Closure-piercing device
dimensions
• Priming/Air
Visualization
• Air-inlet device
function
• Flow Rate
• Filter performance
• Clamp (roller and slide)
function
• Drip Chamber Drop
former function
• Joint/leakage
(occlusion, positive
pressure, negative
pressure, static tensile,
dynamic tensile)
• Particulate
Contamination (USP
788 and ISO 8536-4)
• Microbial Ingress
(leveraged from
K140311)• Visualization
• Flow rate and
occlusion
• Positive pressure
test
• Dynamic Tensile
test
• Static Tensile test• Performance
• Visual
• Catheter Angle
• Flow Rate- No
Catheter
• Flow Rate - With
Catheter
• Tape Removal
• Occlusion
• Negative Pressure
• Positive Pressure
• Clamp and Positive
Pressure
• Tensile Strength
• Power Injection
• Mechanical
• Hemolysis -
Aspiration and
Injection
• Luer Connection
• Gauging
• Liquid and Air
Leakage
• Separation Force
• Stress Cracking
• Collar Retention
• Joint Qualification
• Particulate
Contamination
Patient Contact
category /
durationExternally Communicating,
Blood Path Indirect
prolonged exposureExternally
Communicating,
Blood Path Indirect
prolonged exposureExternally
Communicating, Blood
Path Indirect prolonged
exposure
BiocompatibilityConforms to ISO 10993-1Conforms to ISO
10993-1Conforms to ISO 10993-1
SterilizationEthylene Oxide, SAL 10-6Ethylene Oxide, SAL
10-6Ethylene Oxide, SAL 10-6

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Non Clinical Performance Testing

Non-clinical performance testing was completed with the proposed IV Sets not made with PVC to demonstrate that the sets perform as intended. The test results demonstrated that the proposed device considered the following standards:

ISO 8536-4: "Infusion equipment for medical use - Part 4: Infusion sets for single use, gravity feed"

ISO 8536-14: "Infusion Equipment For Medical Use – Part 14: Clamps and flow regulator for transfusion and infusion equipment without fluid contact"

ISO 10993-1: "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process"

  • Cytotoxicity Sensitization Irritation Systemic Toxicity Hemocompatibility Genotoxicity Material Mediated Pyrogenicity SubChronic Toxicity
    ISO 11135, "Sterilization of health care products – Ethylene oxide – Requirements for development, validation and routine control of a sterilization process for medical devices"

ISO 80369-7, "Small-bore connectors for liquids and gases in healthcare applications- Part 7: Connectors for intravascular or hypodermic applications"

ASTM F2096, "Standard Test Method for Detecting Gross Leaks in Medical Packaging by Internal Pressurization (Bubble Test)"

In addition, the following functional and performance tests were successfully completed to demonstrate that the IV Administration Sets perform as intended.

  • · Particulate Contamination (USP 788 and ISO 8536-4)
  • · Microbial Ingress (leveraged from K140311)
  • Bacterial Endotoxin Testing .

9

Results of the testing demonstrate that the proposed device can be used according to its intended use. No clinical testing was performed as this device does not require clinical studies to demonstrate substantial equivalence with the predicate device.

CONCLUSION:

Results of testing and content within this traditional 510(k) submission demonstrates that the proposed IV Sets not made with PVC are substantially equivalent to the predicate devices.