AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Venner Pneux ™ ETT (Endotracheal Tube) is intended to be used for patients undergoing tracheal intubation during routine anesthesia or over extended periods (not more than 30 days) and for the evacuation or drainage of secretion from the subglottic space.

Device Description

The Venner PneuX ETT (Endotracheal Tube) is a disposable, sterile, single-patient, single-use device. It is a straight, flexible cuffed (low volume, low pressure) Nitinol wire-reinforced tracheal tube with a Murphy Eye. When a patient is intubated with a Venner PneuX ETT and inflated by standard techniques, it can be attached to the Venner PneuX TSM™M via the Venner PneuX™ Extension Tube, to monitor, maintain and regulate cuff pressure. The Venner Pneux TSM, a cuff pressure controller, was cleared for marketing via 510(k) application K110631 and the Venner PneuX Extension Tube is a class I, 510(k) exempt device.

The Venner PneuX ETT is available in four sizes (inner diameters: 6.0, 7.0, 8.0 and 9.0 mm) and is MRI compatible. Depth markings indicate the distal tip of the tube and a printed black line provides a means to orient the tube.

The device provides access to subglottic space by having three additional lumens running along the airway lumen. The three lumens are integrated into the tube wall ending just above the proximal end of the cuff for ease of suction. Connected to the suction tube and subglottic connector, it allows intermittent suctioning of secretions from the subglottic space, and irrigation.

A winged tube holder allows for securement with openings on each end for a head/neck strap to pass through. An integrated bite block with fixation block provides a protective covering and secures the position of the tube to preventunintended movement duringuse. A standard connector (15mm)for universal attachment to a ventilator or anesthesia equipment is present, as well as an inflation line to connect the cuff for inflation and deflation. A pilot balloon connects the cuff to provide an indication of the pressure within the cuff and the pilot valve opens to allow free flow of air to the cuff for inflation when a Luer lock syringe is engaged. When the syringe is removed, the valve closes to prevent leakage of air and ensures the cuff is inflated.

AI/ML Overview

The provided text does not describe a study involving an AI/ML device, but rather a medical device, the Venner PneuX™ ETT (Endotracheal Tube). Therefore, the information requested in the prompt, such as acceptance criteria for AI algorithm performance, sample sizes for test sets, data provenance, number of experts for ground truth, adjudication methods, MRMC studies, standalone performance, and training set details, is not applicable to the provided document.

The document focuses on demonstrating substantial equivalence of the Venner PneuX™ ETT to a predicate device (K093135) through performance testing, biocompatibility evaluation, and material/design comparisons.

Here's the relevant information about the device's acceptance criteria and study proving it meets them, based on the provided text:

Device: Venner PneuX™ ETT (Endotracheal Tube)

Acceptance Criteria and Reported Device Performance (based on this document, primarily focused on equivalence to predicate and relevant standards):

Acceptance Criteria CategorySpecific Acceptance Criteria (Implied/Explicit from document)Reported Device Performance
Premarket ClearanceSubstantial Equivalence to Predicate Device (K093135)Determined as Substantially Equivalent (K192120)
SterilizationSterility Assurance Level (SAL) of 10^-6 (via EO)Met (conformance to ISO 11135:2014)
Ethylene Oxide (EO) Residue Levels meet Tolerable Contact Limit (TCL) for prolonged exposureMet (according to ISO 10993-7)
Shelf Life & Packaging IntegritySupport proposed shelf life (1 year)Met (supported by accelerated and real-time aging studies)
BiocompatibilitySafe, biocompatible, and suitable for intended use (conformance to ISO 10993 & FDA Guidance)All seven tests (MEM Elution Assay, Intracutaneous Reactivity, Guinea Pig Maximum Sensitization, Acute Systemic Toxicity, Subacute/subchronic Toxicity, Genotoxicity – Ames, Material-Mediated Pyrogenicity) "Pass".
Dimensional ConformanceConformance to ISO 5361:2016 for dimensions (bevel angle, curvature, cuff diameter, connectors, murphy eye size/placement)Met the standard.
Mechanical & Functional PerformanceConformance to ISO 5361:2016 for mechanical and functional requirements (cuff leakage, cuff herniation, tube collapse, radiopacity, kink resistance, 15mm connector leakage, seal pressure leakage)Met the standard for both unaged and aged samples.
Pass internal performance specifications for: cuff inflation, leakage and function; lumen function; pull tests for all joints and connections; bite block resistance.Successfully passed each test, meeting its performance specifications.
Meet the same acceptance criteria as the predicate device for functional and mechanical tests.Met the same acceptance criteria as the predicate device.
MRI CompatibilityMR compatible under conditions identified in device labeling (conformance to FDA guidance "Establishing Safety and Compatibility of Passive Implants in the Magnetic Resonance (MR) Environment")Demonstrated to be MR compatible (tests performed: magnetically induced displacement force, magnetically induced torque, heating by radiofrequency fields, and image artifact).

Regarding the non-applicable questions due to the nature of the device (not an AI/ML diagnostic system):

  1. Sample sized used for the test set and the data provenance: Not applicable. The "test set" here refers to physical samples of the medical device, not a data set for an AI algorithm. The document doesn't specify the number of units tested for each performance test, only that "samples" or "device" units were tested. Data provenance typically refers to the origin of data for AI/ML models (e.g., patient demographics, clinical sites), which is not relevant here.
  2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. Ground truth for an AI algorithm is not established for this type of conventional medical device. Performance is measured against engineering specifications and industry standards.
  3. Adjudication method (e.g., 2+1, 3+1, none) for the test set: Not applicable. This refers to expert consensus for labelling data for AI, which is not relevant here.
  4. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance: Not applicable. This is for AI-assisted diagnostic tools.
  5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable. This is for AI algorithms.
  6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.): Not applicable in the context of AI. The "ground truth" for this device's performance is adherence to industry standards (e.g., ISO 5361, ISO 10993) and established engineering specifications.
  7. The sample size for the training set: Not applicable. There is no AI training set.
  8. How the ground truth for the training set was established: Not applicable.

In summary, the provided document describes a premarket notification for a conventional medical device, the Venner PneuX™ ETT, demonstrating its substantial equivalence to a predicate device by meeting various performance, material, and safety standards through physical testing, not through AI/ML model validation.

{0}------------------------------------------------

Image /page/0/Picture/0 description: The image contains two logos. On the left is the Department of Health & Human Services logo. On the right is the FDA logo, which includes the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.

Venner Medical (Singapore) Pte Ltd % Christine Brauer Regulatory Affairs Consultant Brauer Device Consultants, LLC 7 Trail House Court Rockville, Maryland 20850

Re: K192120

Trade/Device Name: Venner PneuX™ ETT Regulation Number: 21 CFR 868.5730 Regulation Name: Tracheal Tube Regulatory Class: Class II Product Code: BTR Dated: January 7, 2020 Received: January 8, 2020

Dear Christine Brauer:

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 requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part

{1}------------------------------------------------

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 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,

Todd Courtney Assistant Director DHT1C: Division of ENT, Sleep Disordered Breathing, Respiratory and Anesthesia Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

{2}------------------------------------------------

Indications for Use

510(k) Number (if known) K192120

Device Name Venner PneuXTM ETT

Indications for Use (Describe)

The Venner Pneux ™ ETT (Endotracheal Tube) is intended to be used for patients undergoing tracheal intubation during routine anesthesia or over extended periods (not more than 30 days) and for the evacuation or drainage of secretion from the subglottic space.

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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

{3}------------------------------------------------

510(k) SUMMARY K192120

1 GENERAL INFORMATION

Submitter and Owner of the 510(k) 1.1

Venner Medical (Singapore) Pte Ltd 35 Joo Koon Circle Singapore 629110 Establishment Registration: 3007740622

Official Correspondent 1.2

Christine L. Brauer, PhD Regulatory Affairs Consultant Brauer Device Consultants, LLC 7 Trail House Court Rockville, MD 20850

Telephone: (301) 545-1990 E-mail: chris.brauer@comcast.net

1.3 Devices Subject of this 510(k)

Venner ProductCodeTradenameProduct Size
901160Venner PneuX™ ETT (Endotracheal Tube)6.0 mm
901170Venner PneuX™ ETT (Endotracheal Tube)7.0 mm
901180Venner PneuX™ ETT (Endotracheal Tube)8.0 mm
901190Venner PneuX™ ETT (Endotracheal Tube)9.0 mm

1.4 510(k) Number and Date of Preparation

Submission Number: K192120 Date of Preparation: 05 January 2020

2 NAME OF THE DEVICE AND CLASSIFICATION INFORMATION

Trade/Proprietary Name 2.1

Venner PneuX™ ETT (Endotracheal Tube)

{4}------------------------------------------------

2.2 Common/Usual Name

Endotracheal Tube - Low Volume, Low Pressure, Cuff

General Information
Trade Name:Venner PneuX™ ETT (Endotracheal Tube)
Classification Regulation:21 CFR 868.5730 Tracheal Tube
Product Code:BTR - Tube, tracheal (w/wo connector)
Class:II
Panel:Anesthesiology

Classification Information 2.3

3 PREDICATE DEVICE

The predicate device is as follows:

  • Venner PneuX ETT (Endotracheal Tube) cleared via K093135 on May 24, 2010

DEVICE DESCRIPTION 4

The Venner Pneux ETT (Endotracheal Tube) is a disposable, sterile, single-patient, single-use device. It is a straight, flexible cuffed (low volume, low pressure) Nitinol wire-reinforced tracheal tube with a Murphy Eye. When a patient is intubated with a Venner PneuX ETT and inflated by standard techniques, it can be attached to the Venner PneuX TSM™M via the Venner PneuX™ Extension Tube, to monitor, maintain and regulate cuff pressure. The Venner Pneux TSM, a cuff pressure controller, was cleared for marketing via 510(k) application K110631 and the Venner PneuX Extension Tube is a class I, 510(k) exempt device.

The Venner PneuX ETT is available in four sizes (inner diameters: 6.0, 7.0, 8.0 and 9.0 mm) and is MRI compatible. Depth markings indicate the distal tip of the tube and a printed black line provides a means to orient the tube.

The device provides access to subglottic space by having three additional lumens running along the airway lumen. The three lumens are integrated into the tube wall ending just above the proximal end of the cuff for ease of suction. Connected to the suction tube and subglottic connector, it allows intermittent suctioning of secretions from the subglottic space, and irrigation.

A winged tube holder allows for securement with openings on each end for a head/neck strap to pass through. An integrated bite block with fixation block provides a protective covering and secures the position of the tube to preventunintended movement duringuse. A standard connector (15mm)for universal attachment to a ventilator or anesthesia equipment is present, as well as an inflation line to connect the cuff for inflation and deflation. A pilot balloon

{5}------------------------------------------------

connects the cuff to provide an indication of the pressure within the cuff and the pilot valve opens to allow free flow of air to the cuff for inflation when a Luer lock syringe is engaged. When the syringe is removed, the valve closes to prevent leakage of air and ensures the cuff is inflated.

5 INDICATIONS FOR USE

Below is the indication for use for the Venner PneuX ETT.

The Venner PneuX™ ETT (Endotracheal Tube) is intended to be used for patients undergoing tracheal intubation during routine anesthesia or over extended periods (not more than 30 days) and for the evacuation or drainage of secretion from the subglottic space.

COMPARISON OF THE INDICATION FOR USE AND INTENDED USE 6 BETWEEN THE VENNER PNEUX ETT AND THE PREDICATE DEVICE

The Venner PneuX ETT and the predicate device share intended use, including the same purpose, function, conditions of use, users, target patient populations, and patient contact (see Table 1).

CharacteristicVenner PneuX ETT(This Application)Venner PneuX ETT(K093135)
Classification Regulation21 CFR 868.573021 CFR 868.5730
Product CodeBTR - Tube, tracheal (w/woconnector)BTR - Tube, tracheal (w/woconnector)
ClassIIII
Indication for Use... is intended to be used forpatients undergoing trachealintubation during routineanesthesia or over extendedperiods (not more than 30days) and for the evacuationor drainage of secretion fromthe subglottic space....intended to be used forpatients undergoing trachealtube intubation duringextended periods (not morethan 30 days) and forevacuation or drainage ofsecretion from the subglotticspace. It is also compatiblewith tracheal intubationduring routine anesthesia.
PurposeTo intubate patients duringroutine anesthesiaTo intubate patients forextended durations but notmore than 30 daysTo intubate patients duringroutine anesthesiaTo intubate patients forextended durations but notmore than 30 days

Table 1. Summary of Intended Use of the Venner PneuX ETT and the Predicate Device

{6}------------------------------------------------

CharacteristicVenner PneuX ETT(This Application)Venner PneuX ETT(K093135)
FunctionTo maintain the airway so thatgases can flow between apatient's lungs and aventilator or anesthesiaequipmentTo provide positive pressureventilationTo support breathing incritically ill patientsTo protect the lungs fromaspirationTo maintain the airway sothat gases can flow between apatient's lungs and aventilator or anesthesiaequipmentTo provide positive pressureventilationTo support breathing incritically ill patientsTo protect the lungs fromaspiration
Target PopulationAdult patients undergoingendotracheal intubationAdult patients who areseverely ill and experiencingbreathing difficultiesAdult patients undergoingendotracheal intubationAdult patients who areseverely ill and experiencingbreathing difficulties
Target UserHealth care professionalstrained in intubationHealth care professionalstrained in intubation
Prescription DeviceYesYes
Intended for Use inClinical EnvironmentYesYes
Body ContactSurface-contacting mucosaltissue - Positioned in thetracheaSurface-contacting mucosaltissue - Positioned in thetrachea
Compatible for Use withthe Venner PneuX TSMTM(K110631)Yes, connects to the VennerPneuX TSM via the VennerPneuX Extension TubeYes, connects to the VennerPneuX TSM via the VennerPneuX Extension Tube
TechnologicalCharacteristicVenner PneuX ETT(This Application)Venner PneuX ETT(K093135)
Design
StraightYes - Multi-lumen, straighttubeYes - Multi-lumen straighttube
Sizes - Inner Diameter(mm)6, 7, 8 and 96, 7, 8, and 9
CuffLow volumeLow pressureLow volumeLow pressure
Tip DesignBoat TipBoat Tip
Murphy EyeYesYes
ReinforcedYes - Nitinol WireYes - Stainless Steel Wire
PortsYes - Three subglottic portsfor removal secretions andirrigationYes - Three subglottic portsfor removal secretions andirrigation
Internal Tube CoatingYes - Inhibit adhesion ofbiological materialYes - Inhibit adhesion ofbiological material
Depth MarkingsYesYes
Integrated Bite BlockYes - Integrated with FixationBlockYes
Standard Connector (15mm)YesYes
Compatible with VennerPneuX TSMYesYes
MRI CompatibleYesNo
Sterile andSterility Assurance LevelYes10-6Yes10-6
Single-UseYesYes
Tissue ContactSurface contacting – TracheaSurface contacting – Trachea
Duration of UseUp to 30 daysUp to 30 days
Materials
Multi-lumen, straight tubeSiliconeSilicone
Wire for ReinforcementNitinol(MRI compatible)Stainless Steel
15 mm ConnectorPolycarbonate (DEHP-free)Polycarbonate
Subglottic LineSiliconeSilicone
Subglottic ConnectorSiliconeSilicone
TechnologicalCharacteristicVenner PneuX ETT(This Application)Venner PneuX ETT(K093135)
Female LuerPolypropyleneN/A
ReservoirSiliconeSilicone
Inflation LineSiliconeSilicone
Pilot BalloonSiliconeSilicone
Pilot Valve (Check Valve)Polypropylene(MRI compatible)Polypropylene
Lock NutPolypropylenePolyoxymethylene copolymer
Winged Tube holderSiliconeSilicone
Integrated Bite Block withFixation BlockPolycarbonate (DEHP-free)Polycarbonate
CuffSiliconeSilicone
Boat Tip with MurphyEyeSiliconeSilicone

COMPARISON OF THE TECHNOLOGICAL CHARACTERISTICS WITH THE 7 PREDICATE DEVICE

The Venner PneuX ETT and the predicate share many of the same technological characteristics although there are some differences (see Table 2). Both systems are multilumen, straight endotracheal tubes with low volume, low pressure cuffs, and compatible for use with the Venner PneuX TSM.

Both are wire-reinforced tubes although different materials are used for the wire. In the modified Venner PneuX ETT, the wire is made from Nitinol, allowing the device to be MRI compatible whereas a stainless-steel wire is used in the predicate device. Other material changes have been made to the Venner PneuX ETT compared to the predicate to support MRI compatibility (pilot valve), to use phthalate (DEHP) free material (15 mm connector and integrated bite block with fixation block), and for commercial reasons such as supplier

{7}------------------------------------------------

preferences. In addition, a new component, a female luer made of polypropylene, has been added to the end of the subglottic line and the design of the winged tube holder has been modified as well for ergonomic reasons.

Table 2. Summary of Technological Characteristics Comparing the Venner PneuX ETT and the Predicate Device

{8}------------------------------------------------

8 PERFORMANCE DATA

This 510(k) notification provided performance data to establish the substantial equivalence of the Venner PneuX ETT.

Sterilization, Shelf Life and Packaging Integrity: The Venner PneuX ETT is provided sterile for single patient use. The device is sterilized using ethylene oxide (EO) to a sterility assurance level (SAL) of 106. The sterilization was performed in conformance to ISO 11135:2014 Sterilization of Health-Care Products - Ethylene Oxide - Requirements for the Development, Validation and Routine Control of a Sterilization Process for Medical Devices, using the half-cycle approach. Ethylene oxide residue levels were evaluated to demonstrate that the Venner PneuX ETT meets the tolerable contact limit (TCL) for prolonged exposure devices (patient contact for more than 24 hours and up to 30 days) for residues according to ISO 10993-7. Accelerated and real time aging studies support the proposed shelf life, including the packaging integrity.

Biocompatibility: Biocompatibility evaluation has been performed to show the device materials are safe, biocompatible and suitable for their intended use. Both ISO 10993 and FDA Guidance "Use of International Standard ISO 10993, Biological Evaluation of Medical Devices Part 1: Evaluation and Testing within a Risk Management Process" have been taken into account to evaluate the biocompatibility of the device materials. The following biocompatibility studies were successfully completed with the Venner PneuX ETT.

Table 3. Summary of the Biocompatibility Tests and Results

Test PerformedTest MethodTest Results
MEM Elution Assay (Cytotoxicity)ISO 10993-5:2009ISO 10993-12:2012Pass

{9}------------------------------------------------

Test PerformedTest MethodTest Results
Intracutaneous ReactivityISO 10993-10:2010ISO 10993-12:2012Pass
Guinea Pig Maximum SensitizationISO 10993-10:2010ISO 10993-12:2012Pass
Acute Systemic ToxicityISO 10993-11:2006ISO 10993-12:2012Pass
Subacute/subchronic Toxicity (14-day)ISO 10993-11:2006ISO 10993-12:2012Pass
Genotoxicity – AmesISO 10993-3:2014ISO 10993-12:2012Pass
Implantation (4-week)ISO 10993-6:2007Pass
Material-Mediated PyrogenicityISO 10993-11:2006ISO 10993-12:2012Pass

Performance Testing: Performance testing was performed to characterize the Venner PneuX ETT, including mechanical and functional testing, MRI compatibility testing and compliance to the standard ISO 5361: 2016 Anaesthetic and respiratory equipment -Tracheal tubes and connectors.

The Venner Pneux ETT has been tested in accordance with the standard ISO 5361: 2016 for dimensions, including bevel angle, curvature, cuff diameter, connectors and murphy eye size/placement. The Venner PneuX ETT met the standard.

The Venner PneuX ETT was evaluated in accordance with the standard ISO 5361:2016 for the following mechanical and functional requirements: and met the standard. This evaluation included an analysis of cuff leakage, cuff herniation, tube collapse, radiopacity, kink resistance, 15mm connector leakage and seal pressure leakage. Terminally sterilized unaged and aged samples were tested. The Venner PneuX ETT both unaged and aged met the standard, supporting the 1-year shelf life.

In addition, the following mechanical tests were performed: cuff inflation, leakage and function, lumen function, pull tests for all joints and connections, and bite block resistance. The device successfully passed each test, meeting its performance specifications.

The Venner PneuX ETT was compared to the predicate device for the functional and mechanical tests and met the same acceptance criteria as the predicate device, demonstrating substantial equivalence.

For MRI compatibility, the device was evaluated for MRI compatibility in accordance with the FDA guidance document entitled "Establishing Safety and Compatibility of Passive Implants in the Magnetic Resonance (MR) Environment - Guidance for Industry and Food and Drug Administration Staff" issued on December 11, 2014. The following types of tests

{10}------------------------------------------------

were performed: magnetically induced displacement force, magnetically induced torque, heating by radiofrequency fields and image artifact. The testing demonstrated that the device is MR compatible under the conditions identified in the device labeling (instructions for use).

CONCLUSIONS 9

Based on the comparison, biocompatibility testing, and performance testing, it has demonstrated that the subject device is substantially equivalent to the predicate device, and does not raise different questions of safety and effectiveness

§ 868.5730 Tracheal tube.

(a)
Identification. A tracheal tube is a device inserted into a patient's trachea via the nose or mouth and used to maintain an open airway.(b)
Classification. Class II (performance standards).