K Number
K200181
Device Name
Black Colored Powder Free Nitrile Examination Gloves Tested for Use with Chemotherapy Drugs and Fentanyl Citrate
Date Cleared
2020-04-15

(82 days)

Product Code
Regulation Number
880.6250
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Black Colored, Power Free Nitrile Examination Gloves, Non-sterile, and Tested for Use with Chemotherapy Drugs and Fentanyl Citrate is a specialty medical glove which is a disposable device intended for medical purpose that is worn on the examiner's hand or finger to prevent contamination between examiner and patient. In addition, these qloves are worn to protect the wearer aqainst exposure to chemotherapy drugs. Tested for use chemotherapy drugs and Fentanyl Citrate. Tested chemotherapy drugs are as follows: Cisplatin 1.0 mg/ml >= 240 Cyclophosphamide (Cytoxan) 20 mg/ml >= 240 Dacarbazine (DTIC) 10.0 mg/ml >= 240 Doxorubicin Hydrochloride 2.0 mg/ml >= 240 Etoposide (Toposar) 20.0 mg/ml >= 240 Fluorouracil 50.0 mg/ml >= 240 Paclitaxel (Taxol) 6.0 mg/ml >= 240 *Carmustine (BCNU) 3.3mg.ml 54.1 (minutes) *Thiotepa 10.0 mg/ml 6.0 (minutes) *Please note that these drugs have extremely low permeation time CAUTION: Testing showed an average breakthrough time of 54.1 minutes with Carmustine. WARNING: Do not use with Thiotepa. Tested Fentanyl Citrate is as follows: Fentanyl Citrate Injection 100.0 mcg/2ml Average Breakthrough Detection Time (minutes) >= 240
Device Description
Black Colored, Power Free Nitrile Examination Gloves, Non-sterile, and Tested for Use with Chemotherapy Drugs and Fentanyl Citrate meets the requirements of ASTM D6319-10(2015) Standard Specification for Nitrile Examination Gloves for Medical Application.
More Information

Not Found

No
The device is a physical examination glove and the summary describes standard material and performance testing, with no mention of AI or ML.

No.
The device is a glove intended to prevent contamination and protect the wearer, not to treat a disease or condition.

No

This device is a medical glove, described as a "disposable device intended for medical purpose that is worn on the examiner's hand or finger to prevent contamination between examiner and patient." Its primary function is protection, not diagnosis.

No

The device description and performance studies clearly indicate that this is a physical medical device (examination gloves) and not a software-only device. The testing focuses on material properties and resistance to chemicals, 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 a "disposable device intended for medical purpose that is worn on the examiner's hand or finger to prevent contamination between examiner and patient." It also mentions protection against chemotherapy drugs and Fentanyl Citrate. This describes a barrier device used for protection during medical procedures.
  • IVD Definition: An In Vitro Diagnostic device is defined as a medical device that is used to perform tests on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections.
  • Lack of IVD Characteristics: The description of the device, its intended use, and the performance studies do not involve testing samples from the human body or diagnosing any condition. The tests performed are related to the physical properties of the glove and its resistance to chemical permeation.

Therefore, the Black Colored, Power Free Nitrile Examination Gloves, Non-sterile, and Tested for Use with Chemotherapy Drugs and Fentanyl Citrate is a medical device, but it falls under the category of a protective barrier device, not an In Vitro Diagnostic.

N/A

Intended Use / Indications for Use

The Black Colored, Power Free Nitrile Examination Gloves, Non-sterile, and Tested for Use with Chemotherapy Drugs and Fentanyl Citrate is a specialty medical glove which is a disposable device intended for medical purpose that is worn on the examiner's hand or finger to prevent contamination between examiner and patient. In addition, these qloves are worn to protect the wearer aqainst exposure to chemotherapy drugs. Tested for use chemotherapy drugs and Fentanyl Citrate. Tested chemotherapy drugs are as follows:
Cisplatin 1.0 mg/ml ≥ 240
Cyclophosphamide (Cytoxan) 20 mg/ml ≥ 240
Dacarbazine (DTIC) 10.0 mg/ml ≥ 240
Doxorubicin Hydrochloride 2.0 mg/ml ≥ 240
Etoposide (Toposar) 20.0 mg/ml ≥ 240
Fluorouracil 50.0 mg/ml ≥ 240
Paclitaxel (Taxol) 6.0 mg/ml ≥ 240
*Carmustine (BCNU) 3.3mg.ml 54.1 (minutes)
*Thiotepa 10.0 mg/ml 6.0 (minutes)
*Please note that these drugs have extremely low permeation time CAUTION: Testing showed an average breakthrough time of 54.1 minutes with Carmustine. WARNING: Do not use with Thiotepa.
Tested Fentanyl Citrate is as follows: Fentanyl Citrate Injection 100.0 mcg/2ml ≥ 240

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

LZA, LZC

Device Description

Black Colored, Power Free Nitrile Examination Gloves, Non-sterile, and Tested for Use with Chemotherapy Drugs and Fentanyl Citrate meets the requirements of ASTM D6319-10(2015) Standard Specification for Nitrile Examination Gloves for Medical Application.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

hand or finger

Indicated Patient Age Range

Not Found

Intended User / Care Setting

examiner

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 tests were conducted to demonstrate that the proposed device met design specifications. The test results demonstrated that the proposed device met the performance criteria with the following standards:

  • ASTM D412-2016 Standard Test Methods for Vulcanized Rubber and Thermoplastic . Elastomers-Tension
  • ASTM D573-2004 (Reapproved 2010) Standard Test Method for Rubber- Deterioration . in an Air Oven
  • ASTM D3767-03 Standard Practice for Rubber Measurement of Dimensions ●
  • ASTM D5151-2006 (Reapproved 2015) Standard Test Method for Detection of Holes in . Medical Gloves
  • ASTM D6124-2006 (Reapproved 2001) Standard Tested Method for Residual Powder on ● Medical Gloves
  • ASTM D6319-10 Standard Specification for Nitrile Examination Gloves for Medical ● Application
  • ASTM D6978-2005(Reapproved 2019) Standard Practice for Assessment of Resistance . of Medical Gloves to Permeation by Chemotherapy Drugs
  • ISO 2859 Sampling Procedures and Tables for Inspection by Attributes ●
  • ISO 10993-5 Biological evaluation of medical devices-Part5 Tests for in vivo cytotoxicity ●
  • ISO 10993-10 Biological evaluation of medical devices-Part 10 Test for irritation and . delayed-type hypersensitivity

Key results:

  • Dimension (length, width, thickness): Met Acceptance Number based on ASTM D6319-10(2015) ANSI / ASQC 21.4-2003 with Inspection Level S-2 and AQL 4.0.
  • Tensile strength and Ultimate elongation: Met Acceptance Number based on ASTM D 6319 - 10(2015) ANSI / ASQC 21.4-2003 with Inspection Level S-2 and AQL 4.0.
    • Tensile Strength: Mean of 21.36 MPA (Unaged) and 20.49 MPA (Aged, 70°C). Minimum of 15.32 MPA (Unaged) and 16.44 MPA (Aged). Pass (Minimum 16.44 MPa).
    • Elongation At Break: Mean of 585% (Unaged) and 475% (Aged, 70°C). Minimum of 520% (Unaged) and 427% (Aged). Pass (Minimum 427 %).
  • Water Leak: Met Acceptance Number based on FDA 1000ml water leak test method (21CFR 800.20) ANSI / ASQC 21.4-2003 with Inspection Level G-1 and AQL 1.5.
  • Powder Residue: 2 mg/glove based on ASTM D6124 - 06(2011). Test Result: 0.50 mg/glove.
  • Freedom From Holes: Pass (No. Of Defective = 0) from 80 samples tested.
  • Chemotherapy Drugs Permeation:
    • Carmustine (BCNU) (3.3 mg/ml): 54.1 minutes (average breakthrough detection time); Steady State Perm. Rate: 0.6 µg/Cm2/Minute. Moderate swelling and slight degradation observed.
    • Cisplatin (1.0 mg/ml): >240 minutes; N/A Steady State Perm. Rate. No significant changes.
    • Cyclophosphamide (Cytoxan) (20 mg/ml): >240 minutes; N/A Steady State Perm. Rate. No significant changes.
    • Dacarbazine (10 mg/ml): >240 minutes; N/A Steady State Perm. Rate. No significant changes.
    • Doxorubicin Hydrochloride (2.0 mg/ml): >240 minutes; N/A Steady State Perm. Rate. No significant changes.
    • Etoposide (Toposar) (20.0 mg/ml): >240 minutes; N/A Steady State Perm. Rate. No significant changes.
    • Fluorouracil (50 mg/ml): >240 minutes; N/A Steady State Perm. Rate. No significant changes.
    • Paclitaxel (Taxol) (6.0 mg/ml): >240 minutes; N/A Steady State Perm. Rate. Slight swelling and no degradation.
    • Thiotepa (THT) (10 mg/ml): 16.0 minutes (average breakthrough detection time); Steady State Perm. Rate: 0.4 µg/Cm2/Minute. No significant changes.
  • Fentanyl Drug Permeation:
    • Fentanyl Citrate Injection (100mcg/2mL): >240 minutes; N/A Steady State Perm. Rate. Slight swelling; no degradation.
  • Biocompatibility: Non-irritating and non-sensitizing based on ISO 10993-10: 2010. Non-cytotoxic based on ISO 10993-5: 2009.

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.

K183287

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

§ 880.6250 Non-powdered patient examination glove.

(a)
Identification. A non-powdered patient examination glove is a disposable device intended for medical purposes that is worn on the examiner's hand or finger to prevent contamination between patient and examiner. A non-powdered patient examination glove does not incorporate powder for purposes other than manufacturing. The final finished glove includes only residual powder from manufacturing.(b)
Classification. Class I (general controls). The device, when it is a finger cot, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 880.9.

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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 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.

August 29, 2022

Comfort Rubber Gloves Industries Sdn. Bhd. Ng Howe QA Manager Lot 821, Jalan Matang Matang, Perak 34750 Malaysia

Re: K200181

Trade/Device Name: Black Colored, Powder Free Nitrile Examination Gloves, Non-sterile, Tested for Use with Chemotherapy Drugs and Fentanyl Citrate Regulation Number: 21 CFR 880.6250 Regulation Name: Non-powdered patient examination glove Regulatory Class: Class I, reserved Product Code: LZA, LZC

Dear Ng Howe:

The Food and Drug Administration (FDA) is sending this letter to notify you of an administrative change related to your previous substantial equivalence (SE) determination letter dated April 15, 2020. Specifically, FDA is updating this SE Letter for a typographical error contained in the Indications for Use, as an administrative correction.

Please note that the 510(k) submission was not re-reviewed. For questions regarding this letter please contact Bifeng Qian, Office of Surgical and Infection Control Devices, at: (301) 796-2261 or bifeng.qian@fda.hhs.gov.

Sincerely,

Bifeng Qian -S

Bifeng Qian, M.D., Ph.D. Assistant Director DHT4B: Division of Infection Control and Plastic Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

1

Image /page/1/Picture/0 description: The image contains the logos of the Department of Health and Human Services (HHS) and the Food and Drug Administration (FDA). The HHS logo is on the left, featuring a stylized graphic of a human figure. To the right is the FDA logo, with the letters "FDA" in a blue square and the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.

April 15, 2020

Comfort Rubber Gloves Industries Sdn. Bhd. Ng Howe QA Manager Lot 821, Jalan Matang Matang, 34750 My

Re: K200181

Trade/Device Name: Black Colored, Powder Free Nitrile Examination Gloves, Non-sterile, Tested for Use with Chemotherapy Drugs and Fentanyl Citrate Regulation Number: 21 CFR 880.6250 Regulation Name: Non-Powdered Patient Examination Glove Regulatory Class: Class I, reserved Product Code: LZA, LZC Dated: January 22, 2020 Received: January 24, 2020

Dear Ng Howe:

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/ofdocs/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

2

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,

Image /page/2/Picture/5 description: The image shows the name "Elizabeth F. Claverie -S" in a simple, sans-serif font. The text is arranged vertically, with "Elizabeth F." on the first line and "Claverie -S" on the second line. The background is plain white.

CAPT Elizabeth Claverie, M.S. Assistant Director DHT4B: Division of Infection Control and Plastic Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

3

Indications for Use

510(k) Number (if known)

K200181

Device Name

Black Colored, Power Free Nitrile Examination Gloves, Non-sterile, and Tested for Use with Chemotherapy Drugs and Fentanyl Citrate

Indications for Use (Describe)

The Black Colored, Power Free Nitrile Examination Gloves, Non-sterile, and Tested for Use with Chemotherapy Drugs and Fentanyl Citrate is a specialty medical glove which is a disposable device intended for medical purpose that is worn on the examiner's hand or finger to prevent contamination between examiner and patient. In addition, these qloves are worn to protect the wearer aqainst exposure to chemotherapy drugs. Tested for use chemotherapy drugs and Fentanyl Citrate. Tested chemotherapy drugs are as follows:

Average Breakthrough Detection Time (minutes)
Cisplatin 1.0 mg/ml≥ 240
Cyclophosphamide (Cytoxan) 20 mg/ml≥ 240
Dacarbazine (DTIC) 10.0 mg/ml≥ 240
Doxorubicin Hydrochloride 2.0 mg/ml≥ 240
Etoposide (Toposar) 20.0 mg/ml≥ 240
Fluorouracil 50.0 mg/ml≥ 240
Paclitaxel (Taxol) 6.0 mg/ml≥ 240
*Carmustine (BCNU) 3.3mg.ml54.1 (minutes)
*Thiotepa 10.0 mg/ml6.0 (minutes)

*Please note that these drugs have extremely low permeation time CAUTION: Testing showed an average breakthrough time of 54.1 minutes with Carmustine. WARNING: Do not use with Thiotepa.

Tested Fentanyl Citrate is as follows:Fentanyl Citrate Injection 100.0 mcg/2ml
Average Breakthrough Detection Time (minutes)≥ 240

Prescription Use (Part 21 CFR 801 Subpart D)

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

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510(K) SUMMARY

K200181

Prepared according to 21 CFR § 807.92 Preparation Date: April 10, 2020

1. Submitter

Name: Comfort Rubber Gloves Industries Sdn. Bhd. Address: Lot 821, Jalan Matang, 34750 Matang, Perak, Malaysia. Phone No.: 605-847 2777 Fax No .: 605-847 9108 Contact Person: Ng Kok Howe (Mr.)

2. Identification of the Device

Device name: Black Colored, Power Free Nitrile Examination Gloves, Non-sterile, and Tested for Use with Chemotherapy Drugs and Fentanyl Citrate

Common Name: Patient Examination Gloves

Classification Name: Patient Examination Gloves

Regulation: 21 CFR 880.6250

Product code: LZA

Classification Name: Patient Examination Gloves Specialty

Regulation: 21 CFR 880.6250

Product code: LZC

3. Identification of the Legally Marketed Device as Predicate

Predicate Device Name: Powder Free Nitrile Patient Examination Glove, Blue Colored, Non-Sterile, Tested for Use with Chemotherapy Drugs and Fentanyl Citrate, Powder Free Nitrile Patient Examination Glove, White Colored, Non-Sterile, Tested for Use with Chemotherapy Drugs and Fentanyl Citrate, Powder Free Nitrile Patient Examination Glove, Black Colored, Non-Sterile, Tested for Use with Chemotherapy Drugs and Fentanyl Citrate

Company: Kossan International Sdn. Bhd.

Predicate 510(K) No.: K183287

4. Description of the Device:

Black Colored, Power Free Nitrile Examination Gloves, Non-sterile, and Tested for Use with Chemotherapy Drugs and Fentanyl Citrate meets the requirements of ASTM D6319-10(2015) Standard Specification for Nitrile Examination Gloves for Medical Application.

5

| Reference

StandardGlove sizeStandard Requirements
Palm width (mm)Length (mm)
ASTM 6319XS$75 \pm 5$ mmMin 240
S$85 \pm 5$ mm
M$95 \pm 5$ mm
L$105 \pm 5$ mm
XL$115 \pm 5$ mm

Table 1. Glove Specifications for different models

5. Indications for Use

The Black Colored, Power Free Nitrile Examination Gloves, Non-sterile, and Tested for Use with Chemotherapy Drugs and Fentanyl Citrate are a specialty medical glove which is a disposable device intended for medical purpose that is worn on the examiner's hand or finger to prevent contamination between examiner and patient. In addition, these gloves are worn to protect the wearer against exposure to chemotherapy drugs and Fentanyl Citrate. Tested for use with chemotherapy drugs and fentanyl citrate.

6. Comparison of the Technological Characteristics between the Subject and Predicate Devices

The Black Colored, Power Free Nitrile Examination Gloves, Non-sterile, and Tested for Use with Chemotherapy Drugs and Fentanyl Citrate are summarized with the following technological characteristics compared to ASTM D6319 - 10(2015) Standard Specification for Nitrile Examination Gloves for Medical Application or equivalent standards as shown in Table 1. Chemotherapy claim is similar to the predicate.

CharacteristicsStandardsDevice performanceRemarks
Predicate deviceSubject device
Manufacturer(s)Kossan International Sdn.
Bhd.Comfort Rubber Gloves
Industries Sdn. Bhd-
510(k) numberK183287K200181-
Indication for UseA patient examination
glove is a disposable device
intended for medical
purpose that is worn on the
examiner's hand to prevent
contamination between
patient and examiner.The Black Colored, Power
Free Nitrile Examination
Gloves, Non-sterile, and
Tested for Use with
Chemotherapy Drugs and
Fentanyl Citrate is a
specialty medical glove
which is a disposable device
intended for medical purpose
that is worn on the
examiner's hand or finger to
prevent contamination
between examiner and
patient. In addition, these
gloves are worn to protect
the wearer against exposure
to chemotherapy drugs and
Fentanyl Citrate. Tested for
use with chemotherapy drugs
and Fentanyl Citrate. Tested
chemotherapy drugs are as
follows:Same
These gloves were tested
for use with chemotherapy
drugs and Fentanyl Citrate
per ASTM D6978-05
(Reapproved 2013)
Standard Practice for
Assessment of Medical
Gloves to Permeation by
Chemotherapy Drugs.
Minimum Breakthrough
Detection Time in minutes
Carmustine (BCNU)
(3.3mg/ml) - 10.1 Cisplatin,
(1.0 mg/ml) - >=240
CyclophosphamideAverage Breakthrough
(Cytoxan), 20.0 mg/ml - >=Detection Time (minutes)
240 Cytarabine (100 mg/ml)Cisplatin, 1.0 mg/ml -
>=240>=240
Dacarbazine (DTIC), 10.0Cyclophosphamide
mg/ml >=240(Cytoxan), 20.0 mg/ml
Doxorubicin Hydrochloride,->=240
(2.0 mg/ml) >=240Dacarbazine (DTIC),
Etoposide, (20.0 mg/ml)10.0 mg/ml - >=240
>=240Doxorubicin Hydrochloride,
Fluorouracil, (50.0 mg/ml)2.0 mg/ml ->=240
>=240Etoposide (Toposar), 20.0
lfosfamide (50.0 mg/ml)mg/ml ->=240
>=240Fluorouracil, 50.0mg/ml -
Methotrexate (25.0 mg/ml)>=240
>=240Paclitaxel (Taxol), 6.0mg/ml
Mitomycin C (0.5 mg/ml)>=240
>=240*Carmustine (BCNU)
Mitoxantrone (2.0 mg/ml)3.3mg/ml - 54.1 (mins)
>=240*Thiotepa 10.0 mg/ml
Paclitaxel (Taxol), 6.0 mg/ml- 16.0 (mins)
>=240*Please note that these drugs
Thiotepa (10.0 mg/ml) - 30.2have extremely low
Vincristine Sulfate (1.0mg/ml)permeation time.
>=240.CAUTION: Testing showed
Please note that Carmustinean average breakthrough
(BCNU) has extremely lowtime of 54.1 minutes with
permeation time of 10.1Carmustine; WARNING: Do
minutes. Fentanyl Citrate andnot use with Thiotepa.
Concertation Fentanyl CitrateTested Fentanyl Citrate is as
Injection (100.0 mcg/2ml)follows: Fentanyl Citrate
Minimum BreakthroughInjection 100.0 mcg/2ml
Detection Time inAverage Breakthrough
minutes>=240Detection Time
(minutes) >=240
ASTM D6319-Length-Min 240mmLength-Min 240mm Thickness
Dimension10(2015)Thickness palm and finger-palm and finger- Min 0.05mmSimilar
Min 0.05mm
Physical PropertiesASTM D6319-MeetsMeetsSimilar
10(2015)
Thickness - Finger-ASTM D6319-MeetsMeetsSimilar
Palm10(2015)
Powder ContentASTM D6124-MeetsMeetsSimilar
06(2011)
ChemotherapyConcentrationMinimum Breakthrough Detection Time (min)
Drugs
Cisolatin1.0 mg/ml>240>240Same
Cyclophosphamide20 mg/ml>240>240Same
(Cvtoxan)
Dacarbazine (DTIC)10.0 mg/ml>240>240Same
Doxorubicin2 0 mg/ml>240>240Same
Hvdrochloride
Etoooside (Toposar)20.0 ma/ml>240>240Same
Fluorouracil50.0 ma/ml>240>240Same
Paclitaxel (Taxol)6.0 mg/ml>240>240Same
lfosfamide50.0 ma/ml>240-Different
Mitoxantrone2.0 mg/ml>240-Different
Vincristine Sulfate1.0 mg/ml>240-Different
Carmustine (BCNU)3.3 mg/ml15.054.1Similar
Thiotepa10.0 mg/ml2.016.0Similar
Fentanyl Citrate100mcq/2ml->240Different
BiocompatibilityISO10993-10: 2010
Biological
evaluation of
medical devices --
Part 10: Tests for
irritation and skin
SensitizationUnder the conditions of the
study, the subject device is
non-irritatingUnder the conditions of the
study, the subject device is
non- irritatingSame
ISO10993-5: 2009Under the conditions of the
study, the subject device is
non- sensitizationUnder the conditions of the
study, the subject device is
non- sensitizationSame
Biological
Evaluation of
Medical Devices-
Part 5: Test for In
Vitro CytotoxicityUnder the conditions of the
study, the subject device is
non- cytotoxicUnder the conditions of the
study, the subject device is non-
cytotoxicSame
Watertight (1000ml)21 CFR 800.20
ASTM D5151PassesPassesSame
MaterialASTM 06319 -
10(2015)NitrileNitriteSame
Color-Blue White BlackBlackSame
SizeMedical Glove
Guidance Manual
  • Labeling | Extra small
    Small
    Medium
    Large
    Extra Large | Extra Small
    Small
    Medium
    Large
    Extra Large | Same |
    | Single Use | Medical Glove
    Guidance Manual
  • Labeling | Single Use | Single Use | Same |

Table 2. Comparison of the Technological Characteristics

6

7

The subject device and the predicate device share the same indication for use, same material, same specifications for thickness and length, similar permeation rate for chemotherapy drugs, similar labeling properties, powder free, biocompatibility and water tight test.

7. Summary of Non-Clinical tests

Non-clinical tests were conducted to demonstrate that the proposed device met design specifications. The test results demonstrated that the proposed device met the performance criteria with the following standards:

  • ASTM D412-2016 Standard Test Methods for Vulcanized Rubber and Thermoplastic . Elastomers-Tension
  • ASTM D573-2004 (Reapproved 2010) Standard Test Method for Rubber- Deterioration . in an Air Oven
  • ASTM D3767-03 Standard Practice for Rubber Measurement of Dimensions ●
  • ASTM D5151-2006 (Reapproved 2015) Standard Test Method for Detection of Holes in . Medical Gloves
  • ASTM D6124-2006 (Reapproved 2001) Standard Tested Method for Residual Powder on ● Medical Gloves
  • ASTM D6319-10 Standard Specification for Nitrile Examination Gloves for Medical ● Application
  • ASTM D6978-2005(Reapproved 2019) Standard Practice for Assessment of Resistance . of Medical Gloves to Permeation by Chemotherapy Drugs
  • ISO 2859 Sampling Procedures and Tables for Inspection by Attributes ●
  • ISO 10993-5 Biological evaluation of medical devices-Part5 Tests for in vivo cytotoxicity ●

8

  • ISO 10993-10 Biological evaluation of medical devices-Part 10 Test for irritation and . delayed-type hypersensitivity
CharacteristicsReference Test Method &SamplingInspection LevelAQLAcceptance Criteria
Dimension (length, width, thickness)ASTM D6319 - 10(2015)
ANSI / ASQC 21.4-2003S-24.0Meet Acceptance Number
Tensile strength and
Ultimate elongationASTM D 6319 - 10(2015)
ANSI / ASQC 21.4-2003S-24.0Meet Acceptance Number
Water LeakFDA 1000ml water leak test method
(21CFR 800.20)
ANSI / ASQC 21.4-2003G-11.5Meet Acceptance Number
Powder ResidueASTM D6124 - 06(2011)N/AN/A2 mg/glove

Table 3. Quality Assurance Testing For Finished Gloves

Table 4. Physical Property

SampleUnagedAged (7 Days, 70°C)
Tensile Strength
(MPA)Elongation At
Break (%)Tensile Strength
(MPA)Elongation At Break
(%)
122.8659620.80447
215.3252019.73462
316.7952324.81518
415.8157520.49459
523.6058524.92518
622.0055020.49487
721.3653120.94475
820.7863720.47499
922.9560219.03459
1022.1154124.29493
1121.2361516.44427
1220.4355219.88466
1322.8463319.13487
Mean21.3658520.49475
Minimum15.3252016.44427

Table 5. Freedom From Holes

TestNumber Tested/BatchResults
Tensile Strength13Pass (Minimum 16.44 MPa)
Ultimate Elongation13Pass (Minimum 427 %)
Freedom From Holes80Pass (No. Of Defective = 0)

| No | Sample | Size | Length
(mm) | Weight of
Filter+
Dried
Residue (A) | Weight of
Filter (B) | Weight of
H20 +
Dried
Residue (C) | A-B-C
X 1000
(mg) | Residual
Powder
Content
(mg/glove) |
|----|------------------------|------|----------------|----------------------------------------------|-------------------------|--------------------------------------------|-------------------------|---------------------------------------------|
| 1 | Lot No.
81107F50510 | M | 240 | 0.0970 | 0.0945 | 0.0000 | 2.5 | 0.50 |

Table 6. Powder Residual Test Result

9

| Test Chemotherapy Drugs | Minimum Breakthrough
Detection Time
(Specimen 1/2/3) (Minutes) | Steady State Perm. Rate
(Specimen 1/2/3)
(µg/Cm2/Minute) | Other
Observations |
|---------------------------------------------------------|----------------------------------------------------------------------|----------------------------------------------------------------|------------------------------------------------|
| Carmustine (BCNU),
3.3 mg/ml (3,300ppm) | 54.1
(56.4, 54.1, 56.7) | 0.6
(0.6, 0.6, 0.6) | Moderate swelling
and slight
degradation |
| Cisplatin,
1.0 mg/ml (1,000 ppm) | >240 | N/A | No significant
changes |
| Cyclophosphamide
(Cytoxan), 20 mg/ml
(20,000 ppm) | >240 | N/A | No significant
changes |
| Dacarbazine,
10 mg/ml (10,000 ppm) | >240 | N/A | No significant
changes |
| Doxorubicin Hydrochloride,
2.0 mg/ml (2,000 ppm) | >240 | N/A | No significant
changes |
| Etoposide (Toposar),
20.0 mg/ml (20 000 ppm) | >240 | N/A | No significant
changes |
| Fluorouracil,
50 mg/ml (50,000ppm) | >240 | N/A | No significant
changes |
| Paclitaxel (Taxol),
6.0 mg/ml (6,000ppm) | >240 | N/A | Slight swelling
and no
degradation |
| Thiotepa (THT),
10 mg/ml (10,000ppm) | 16.0
(16.0,26.8,17.7) | 0.4
(0.5,0.3,0.4) | No significant
changes |

Table 7. Chemotherapy Drug Permeation Test Results

Table 8. Fentanyl Drug Permeation Test Result

| Test Drug And
Concentration | Minimum Breakthrough
Detection Time
(Specimen 1/2/3) (Minutes) | Steady State Perm. Rate
(Specimen 1/2/3)
(µg/Cm2/Minute) | Other
Observations |
|-------------------------------------------|----------------------------------------------------------------------|----------------------------------------------------------------|------------------------------------|
| Fentanyl Citrate Injection,
100mcg/2mL | >240 | N/A | Slight swelling; no
degradation |

8. Conclusion

The conclusions drawn from the non-clinical tests demonstrate that the subject device, the Black Colored, Power Free Nitrile Examination Gloves, Non-sterile, and Tested for Use with Chemotherapy Drugs and Fentanyl Citrate is as safe, as effective, and performs as well as or better than the legally marketed predicate device cleared under 510(K) submission K183287.