K Number
K201732
Device Name
Dukal Corporation Level 3 Surgical Face Masks with Ear loop, Dukal Corporation Level 3 Surgical Face Masks with Tie On
Manufacturer
Date Cleared
2021-02-16

(236 days)

Product Code
Regulation Number
878.4040
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Dukal Corporation Level 3 Surgical Face Masks are intended to be worn by operating room personnel during surgical procedures to protect both the surgical patient and the operating room personnel from transfer of microorganisms, body fluids, and particulate material.
Device Description
Face Masks intended to protect health care patients and personnel from the transfer of microorganisms, body fluids and particulate material.
More Information

Not Found

No
The device description and performance studies focus on the physical filtration and fluid resistance properties of a surgical face mask, with no mention of AI or ML.

No
The device is a surgical face mask intended to protect both the wearer and the patient from the transfer of microorganisms, body fluids, and particulate material, not to treat or cure a disease or condition.

No
The device is a surgical face mask, which is a protective barrier, not a tool used to identify or analyze medical conditions. Its purpose is to prevent the transfer of microorganisms, not to diagnose a disease or condition.

No

The device description and performance studies clearly indicate this is a physical face mask, not a software product.

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

Here's why:

  • Intended Use: The intended use clearly states the masks are for protecting operating room personnel and patients from the transfer of microorganisms, body fluids, and particulate material during surgical procedures. This is a barrier function, not a diagnostic one.
  • Device Description: The description reinforces the protective barrier function.
  • Lack of Diagnostic Elements: There is no mention of analyzing samples (blood, urine, tissue, etc.), detecting specific analytes, or providing diagnostic information about a patient's condition.
  • Performance Studies: The performance studies focus on filtration efficiency, fluid resistance, flammability, and biocompatibility – all characteristics relevant to a protective barrier device, not a diagnostic one.

IVD devices are used to examine specimens derived from the human body to provide information for diagnostic, monitoring, or compatibility purposes. This surgical mask does not perform any such function.

N/A

Intended Use / Indications for Use

The Dukal Corporation Level 3 Surgical Face Masks are intended to be worn by operating room personnel during surgical procedures to protect both the surgical patient and the operating room personnel from transfer of microorganisms, body fluids, and particulate material.

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

FXX

Device Description

Face Masks intended to protect health care patients and personnel from the transfer of microorganisms, body fluids and particulate material.

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

operating room personnel

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)

The following performance data were provided in support of the substantial equivalence determination:
Test: ASTM F2101-Bacterial Filtration Efficiency (BFE)
Test Results of Subject Device: >99.9%
Test Results of Predicate Device: 99.7% (average)

Test: ASTM F2299-Particulate Filtration Efficiency
Test Results of Subject Device: >99%
Test Results of Predicate Device: 99.2% (average)

Test: EN 14683-Differential Pressure
Test Results of Subject Device:

§ 878.4040 Surgical apparel.

(a)
Identification. Surgical apparel are devices that are intended to be worn by operating room personnel during surgical procedures to protect both the surgical patient and the operating room personnel from transfer of microorganisms, body fluids, and particulate material. Examples include surgical caps, hoods, masks, gowns, operating room shoes and shoe covers, and isolation masks and gowns. Surgical suits and dresses, commonly known as scrub suits, are excluded.(b)
Classification. (1) Class II (special controls) for surgical gowns and surgical masks. A surgical N95 respirator or N95 filtering facepiece respirator is not exempt if it is intended to prevent specific diseases or infections, or it is labeled or otherwise represented as filtering surgical smoke or plumes, filtering specific amounts of viruses or bacteria, reducing the amount of and/or killing viruses, bacteria, or fungi, or affecting allergenicity, or it contains coating technologies unrelated to filtration (e.g., to reduce and or kill microorganisms). Surgical N95 respirators and N95 filtering facepiece respirators are exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to § 878.9, and the following conditions for exemption:(i) The user contacting components of the device must be demonstrated to be biocompatible.
(ii) Analysis and nonclinical testing must:
(A) Characterize flammability and be demonstrated to be appropriate for the intended environment of use; and
(B) Demonstrate the ability of the device to resist penetration by fluids, such as blood and body fluids, at a velocity consistent with the intended use of the device.
(iii) NIOSH approved under its regulation.
(2) Class I (general controls) for surgical apparel other than surgical gowns and surgical masks. The class I device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to § 878.9.

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March 4, 2021

Dukal Corporation Megan Quevedo Ouality and Regulatory Affairs Engineer 2 Fleetwood Court Ronkonkoma, New York 11779

Re: K201732

Trade/Device Name: Dukal Corporation Level 3 Surgical Face Masks with Ear loop, Dukal Corporation Level 3 Surgical Face Masks with Tie On Regulation Number: 21 CFR 878.4040 Regulation Name: Surgical Apparel Regulatory Class: Class II Product Code: FXX

Dear Megan Quevedo:

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 February 16, 2021. Specifically, FDA is updating this SE Letter to remove proprietary information from the 510k summary as an administrative correction.

Please note that the 510(k) submission was not re-reviewed. For questions regarding this letter please contact Ryan Ortega, PhD, OHT4: Office of Surgical and Infection Control Devices, (240-402-2303), Email Ryan.Ortega@fda.hhs.gov.

Sincerely,

Image /page/0/Picture/9 description: The image shows the name "Jessica Mavadia-shukla -S" in a clear, sans-serif font. The text is horizontally oriented and appears to be a title or heading. The name is written in black, and the background is plain.

For Ryan Ortega, PhD

Acting 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

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Image /page/1/Picture/0 description: The image contains the logos of the Department of Health & Human Services and the Food and Drug Administration (FDA). The Department of Health & Human Services logo is on the left, and the FDA logo is on the right. The FDA logo includes the FDA acronym in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.

February 16, 2021

Dukal Corporation Megan Quevedo Ouality and Regulatory Affairs Engineer 2 Fleetwood Court Ronkonkoma, New York 11779

Re: K201732

Trade/Device Name: Dukal Corporation Level 3 Surgical Face Masks with Ear Loop, Dukal Corporation Level 3 Surgical Face Masks with Tie On Regulation Number: 21 CFR 878.4040 Regulation Name: Surgical Apparel Regulatory Class: Class II Product Code: FXX Dated: February 8, 2021 Received: February 11, 2021

Dear Megan Quevedo:

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,

Jessica Mavadia-shukla -S

For 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

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Indications for Use

510(k) Number (if known) K201732

Device Name

Dukal Corporation Level 3 Surgical Face Masks with Ear Loop and Dukal Corporation Level 3 Surgical Face Masks with Tie On

Indications for Use (Describe)

The Dukal Corporation Level 3 Surgical Face Masks are intended to be worn by operating room personnel during surgical procedures to protect both the surgical patient and the operating room personnel from transfer of microorganisms, body fluids, and particulate material.

Prescription Use (Part 21 CFR 801 Subpart D)

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

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K201732 510(k) SUMMARY

510(k) Premarket Notification for Dukal Corporation Level 3 Surgical Face Masks with Ear Loop and Level 3 Surgical Face Masks with Tie On

In accordance with the requirements set forth in Title 21 CFR §807.92, we are providing this 510(k) Summary and also notifying you of our intent to manufacture, package, and put into commercial distribution Level 3 Surgical Face Mask with Ear Loop and Level 3 Surgical Mask with Tie On.

1.Submitter:Dukal Corporation
2 Fleetwood Court
Ronkonkoma NY 11779
Phone: 631-656-3800
Fax: 631-656-3810
2.FDA Registration Number:2435946
3.Regulatory Affairs Contact:Megan Quevedo
Quality and Regulatory Affairs Engineer
2 Fleetwood Court
Ronkonkoma NY 11779
Telephone Number: 631-656-3800 ext. 133
Fax Number: 631-656-3810
4.Date Summary Prepared:February 16, 2021
5.Name of Device:Dukal Corporation Level 3 Surgical Face Masks with
Ear Loop, Dukal Corporation Level 3 Surgical Face
Masks with Tie On
6.Trade Name:Dukal Corporation Level 3 Surgical Face Masks with
Ear Loop, Dukal Corporation Level 3 Surgical Face
Masks with Tie On
7.Common/Classification Name:Surgical Mask
8.Regulation Number:21 CFR §878.4040
9.Device Class:Class II
10.Regulation Name:Surgical Apparel
11.Product Code:FXX
12.Predicate Device:Cardinal Health Level 3 Surgical Mask with Anti-Fog Foam Strip
(Catalog # AT73635)
510k: K192374
13.Device Description:Face Masks intended to protect health care patients and
personnel from the transfer of microorganisms, body
fluids and particulate material.

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    1. Packaging:
      50 masks/box
  1. Indications for Use: The Dukal Corporation surgical masks are intended to be worn by operating room personnel during surgical procedures to protect both the surgical patient and the operating room personnel from transfer of microorganisms, body fluids, and particulate material.

16. Comparison of Technological Characteristics with the Predicate Device:

Identification of legally marketed device to which Dukal Corporation is claiming equivalence:

For the Level 3 Surgical Face Masks with Ear loop and Tie On:

Cardinal Health Level 3 Surgical Mask with Anti-Fog Foam Strip (Catalog # AT73635)

17. Substantial Equivalence Comparison Table (Ear loop and Tie On):

| Element of
Comparison | Predicate Device Cardinal Health
(K192374) Level 3 Surgical Mask with
Anti-Fog Foam Strip (Catalog # AT73635) | Subject Device Dukal Corporation
(K201732) Level 3 Surgical Face
Masks with Ear Loop and Level 3
Surgical Face Masks with Tie On | Comparison |
|--------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|
| Intended Use | Cardinal Health Level 3 Surgical Masks
with Anti-Fog Foam Strip are intended to
be worn by operating room personnel
and other general healthcare workers to
protect both patients and healthcare
workers against transfer of
microorganisms, blood and body fluids,
and airborne particulates. | The Dukal Corporation Level 3
surgical masks are intended to be
worn by operating room personnel
during surgical procedures to
protect both the surgical patient
and the operating room personnel
from transfer of microorganisms,
body fluids, and particulate
material. | Similar |
| Material
Composition | Four-layer mask constructed of:
1 layer of nonwoven
polyester/polyethylene blend (inner
facing)
1 layer of nonwoven polyolefin melt
blown (filter media)
1 layer of nonwoven
polyester/polyethylene blend (middle
layer)
1 layer of polyolefin spunbond material
(outer facing) | Outer and Inner Material:
Polypropylene (Spunbond)
Filter Material: Polypropylene
(Meltblown)
Nose Piece Material: Malleable
aluminum wire
Ear loop Material: Spandex elastic,
polyester
Tie On Material: Polypropylene
(Spunbond) | Similar |
| Dimensions | 7 inches x 4 inches | 17.5 x 9.5 cm | Similar |
| Mask Style | Pleated | Pleated | Same |
| Design Features | Anti-fog foam strip, ties and malleable
nosepiece | Option for Ear Loop & Option for Tie
On (both with malleable aluminum
wire) | Similar |
| Sterility | Non-Sterile | Non-Sterile | Same |

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UseSingle Use; DisposableSingle Use; DisposableSame
BiocompatibilityThe Cardinal Health Level 3 Surgical
Mask with Anti-Fog Foam Strip was
tested in accordance with ISO 10993
and passed acceptance criteria.The device was tested in accordance
with ISO 10993 and passed
acceptance criteria under the
conditions of the studies.
• Under the conditions of the
study, the device did not show
potential toxicity to L929 cells.
Per ISO 10993- 5 Cytotoxicity test
• Under the conditions of the
study, the response of the device
was categorized as negligible for
skin irritation per 10993- 10
Irritation test
• Under the conditions of the
study, the device showed no
significant evidence of causing
skin Sensitization per 10993- 10
Sensitization testSimilar
    1. Technical Characteristics: The Dukal Corporation Level 3 Surgical Face Masks with Ear Loop and Level 3 Surgical Face Masks with Tie On have similar technological characteristics as and are substantially equivalent to the above respective Cardinal Health Level 3 Surgical Mask with Anti- Fog Foam Strip.
    1. Performance Data: The following performance data were provided in support of the substantial equivalence determination:

Comparison Summary of ASTM F2100 Performance Testing and Biocompatibility Testing Results

| Test | Test Results of Subject Device
Dukal Corporation (K201732)
Level 3 Surgical Face Masks with
Ear Loop and Level 3 Surgical
Face Masks with Tie On
(conforms to ASTM F2100-19
Level 3 requirements) | Test Results of Predicate
Device Cardinal Health
(K192374) Level 3 Surgical
Mask with Anti- Fog Foam
Strip (Catalog # AT73635)
(conforms to ASTM F2100-
11 Level 3 requirements) | Comparison |
|-----------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|
| ASTM F2101-Bacterial
Filtration Efficiency (BFE) | >99.9% | 99.7% (average) | Similar |
| ASTM F2299-Particulate
Filtration Efficiency | >99% | 99.2% (average) | Similar |
| EN 14683-Differential
Pressure | ≤4.6 mmH2O/cm2 | (Referencing Mil-M- 36954C)
2.8 mmH2O/cm2 (average) | Similar |
| ASTM F1862-Fluid
Resistance | Pass at 160mmHg (29 out of 32
test articles passed) | Pass at 160 mmHg (31 out of
32 test articles passed) | Similar |
| 16 CFR 1610-
Flammability | Class I | Class I | Same |

20. Conclusions:

The conclusion drawn from the nonclinical tests demonstrates that the subject device in 510(K)

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submission K201732, Dukal Corporation Level 3 Surgical Face Masks with Ear Loop and Level 3 Surgical Face Masks with Tie On are as safe, as effective, and perform as well as or better than the legally marketed predicate device cleared under K192374.