K Number
K202511
Device Name
Disposable Medical Surgical Mask
Date Cleared
2021-02-02

(155 days)

Product Code
Regulation Number
878.4040
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Disposable Medical Surgical Masks are intended to be worn to protect both the patient and healthcare personnel from transfer of microorganisms, body fluids and particulate material. These face masks are intended for use in infection control practices to reduce the potential exposure to blood and body fluids. This is a single use, disposable device(s), provided non-sterile.
Device Description
The proposed device(s) are blue color, and Flat Pleated type mask, utilizing Ear Loops way for wearing, and they all have Nose Piece design for fitting the facemask around the nose. The proposed device(s) are manufactured with three layers, the inner and outer layers are made of spun-bond polypropylene, and the middle layer is made of melt-blown polypropylene filter. The model of proposed device, ear loops, is held in place over the users' mouth and nose by two elastic ear loops welded to the facemask. The elastic ear loops are not made with natural rubber latex. The nose piece contained in the proposed device(s) is in the layers of facemask to allow the user to fit the facemask around their nose, which is made of polyethylene coated steel wire. The proposed device(s) are sold non-sterile and are intended to be single use, disposable device.
More Information

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

No
The device is a surgical mask intended for infection control, not for treating a disease or condition.

No

Explanation: The device is a face mask intended for protection from microorganisms and fluids, not for diagnosing medical conditions.

No

The device description clearly outlines physical components (spun-bond polypropylene, melt-blown polypropylene filter, elastic ear loops, polyethylene coated steel wire nose piece) and performance testing related to these physical characteristics (fluid resistance, filtration efficiency, differential pressure, flammability). This indicates it is a hardware device, not software-only.

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

Here's why:

  • Intended Use: The intended use is to protect the wearer and others from the transfer of microorganisms, body fluids, and particulate material by being worn over the mouth and nose. This is a physical barrier function, not a diagnostic test performed on a sample taken from the body.
  • Device Description: The device is a physical mask made of layers of material designed to filter air. It does not contain reagents, instruments, or software intended for analyzing biological samples.
  • Performance Studies: The performance studies focus on the physical properties of the mask (fluid resistance, filtration efficiency, breathability, flammability) and biocompatibility, not on the accuracy or reliability of a diagnostic test.
  • Lack of IVD Characteristics: There is no mention of analyzing samples (blood, urine, tissue, etc.), detecting specific analytes, or providing diagnostic information about a patient's health status.

In summary, this device is a medical mask intended for infection control, which is a different category of medical device than an In Vitro Diagnostic.

N/A

Intended Use / Indications for Use

The Disposable Medical Surgical Masks are intended to be worn to protect both the patient and healthcare personnel from transfer of microorganisms, body fluids and particulate material. These face masks are intended for use in infection control practices to reduce the potential exposure to blood and body fluids. This is a single use, disposable device(s), provided non-sterile.

Product codes

FXX

Device Description

The proposed device(s) are blue color, and Flat Pleated type mask, utilizing Ear Loops way for wearing, and they all have Nose Piece design for fitting the facemask around the nose. The proposed device(s) are manufactured with three layers, the inner and outer layers are made of spun-bond polypropylene, and the middle layer is made of melt-blown polypropylene filter. The model of proposed device, ear loops, is held in place over the users' mouth and nose by two elastic ear loops welded to the facemask. The elastic ear loops are not made with natural rubber latex. The nose piece contained in the proposed device(s) is in the layers of facemask to allow the user to fit the facemask around their nose, which is made of polyethylene coated steel wire. The proposed device(s) are sold non-sterile and are intended to be single use, disposable device.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

The proposed devices were tested and conformed to the following standards and the requirements stated in the Guidance for Industry and FDA Staff: Surgical Masks – Premarket Notification [510(k)] Submission issued on March 5, 2004.

Biocompatibility testing

The biocompatibility evaluation for the subject device was conducted in accordance with the FDA Biocompatibility guidance, 2016 (Use of International Standard ISO 10993-1, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process") and International Standard ISO 10993-1 "Biological Evaluation of Medical Devices - Part 1: Evaluation and Testing Within a Risk Management Process," as recognized by FDA. Under the condition of this study the device is non-cytotoxic, non-sensitizing and non-irritating.

Clinical data

No clinical study is included in this submission.

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

Fluid Resistance Performance: 32 out of 32 pass at 160 mmHg
Particulate Filtration Efficiency: 98.6%
Bacterial Filtration Efficiency: 99.9%
Differential Pressure (Delta-P) Test: 3.5 mmH2O/cm²
Flammability Testing: Class 1

Predicate Device(s)

K182514

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 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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February 2, 2021

Improve Medical (HuNan) Co., Ltd. % Kevin Wang Consultant Chonconn Medical Device Consulting Co., Ltd. Room 508, Block C, No. 1029 Nanhai Avenue, Nanhan District Shenzhen, Guangdong 518067 China

Re: K202511

Trade/Device Name: Disposable Medical Surgical Mask Regulation Number: 21 CFR 878.4040 Regulation Name: Surgical Apparel Regulatory Class: Class II Product Code: FXX Dated: January 6, 2021 Received: January 6, 2021

Dear Kevin Wang:

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

1

statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

For 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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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2020 See PRA Statement below.

510(k) Number (if known) K202511

Device Name

Disposable Medical Surgical Mask

Indications for Use (Describe)

The Disposable Medical Surgical Masks are intended to be worn to protect both the patient and healthcare personnel from transfer of microorganisms, body fluids and particulate material. These face masks are intended for use in infection control practices to reduce the potential exposure to blood and body fluids. This is a single use, disposable device(s), provided non-sterile.

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

Prescription Use (Part 21 CFR 801 Subpart D)

X 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."

FORM FDA 3881 (7/17)

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510(K) Summary

K202511

Prepared in accordance with the requirements of 21 CFR Part 807.92

Prepared Date: 2020/12/31

Submission sponsor 1.

Name: Improve Medical (HuNan) Co., Ltd.

Address: No. 6. Yizhang East Avenue, Economic Development District, 424200, Yizhang, HuNan, China

Contact person: Wang Jing

Title: RA manager

E-mail: wjing 2008@163.com

2. Submission correspondent

Name: Chonconn Medical Device Consulting Co., Ltd.

Address: Room 508, Block C, No. 1029 Nanhai Avenue, Nanshan District, Shenzhen, Guangdong, P. R. China

Contact person: Kevin Wang

E-mail: kevin(@chonconn.com

Tel: +86-755 33941160

Trade/Device NameDisposable Medical Surgical Mask
ModelFlat (17.5cm*9.5cm)
Common NameSurgical Face Mask
Regulatory ClassClass II
Regulation21CFR 878.4040
Classification nameMask, Surgical
Product codeFXX
Submission typeTraditional 510(K)

Subject Device Information 3.

4. Predicate Device

Manufacturer: Xiantao Zhibo Non-woven Products Co., Ltd. Device: Surgical Face Mask 510(k) No.: K182514.

ട്. Device Description

The proposed device(s) are blue color, and Flat Pleated type mask, utilizing Ear Loops way for wearing, and they all have Nose Piece design for fitting the facemask around the nose.

The proposed device(s) are manufactured with three layers, the inner and outer layers are made of spun-

4

bond polypropylene, and the middle layer is made of melt-blown polypropylene filter.

The model of proposed device, ear loops, is held in place over the users' mouth and nose by two elastic ear loops welded to the facemask. The elastic ear loops are not made with natural rubber latex.

The nose piece contained in the proposed device(s) is in the layers of facemask to allow the user to fit the facemask around their nose, which is made of polyethylene coated steel wire.

The proposed device(s) are sold non-sterile and are intended to be single use, disposable device.

6. Intended use & Indication for use

The Disposable Medical Surgical Masks are intended to be worn to protect both the patient and healthcare personnel from transfer of microorganisms, body fluids and particulate material. These face masks are intended for use in infection control practices to reduce the potential exposure to blood and body fluids. This is a single use, disposable device(s), provided non-sterile.

FeaturesSubject Device K202511Predicate Device K182514Remark
Disposable Medical Surgical
MaskSurgical Face Mask
ApplicantImprove Medical (HuNan) Co.,
Ltd.WUHAN DYMEX
HEALTHCARE
CO., LTD/
Classification
Regulation21CRF 878.404021CRF 878.4040Same
Classification
and CodeClass II,
FXXClass II,
FXXSame
Common nameSurgical Face MaskSurgical Face MaskSame
Indication for
useThe Surgical Face Masks are
intended to be worn to protect both
the patient and healthcare personnel
from transfer of microorganisms,
body fluids and particulate material.
These face masks are intended for
use in infection control practices to
reduce the potential exposure to
blood and body fluids. This is a
single use, disposable device(s),
provided non-sterile.The Surgical Face Masks are
intended to be worn to protect both
the patient and healthcare personnel
from transfer of microorganisms,
body fluids and particulate material.
These face masks are intended for
use in infection control practices to
reduce the potential exposure to
blood and body fluids. This is a
single use, disposable device(s),
provided non-sterile.Same
ModelEar loops, Flat Pleated, 3 layersEar loops, Flat Pleated, 3 layersSame
MaterialOuter facing layer: Spun-bond
polypropylene
Middle layer: Melt-blownOuter facing layer: Spun-bond
polypropylene
Middle layer: Melt-blownSame
polypropylene filterpolypropylene filter
Inner facing layer: Spun-bond
polypropyleneInner facing layer: Spun-bond
polypropyleneSame
Nose wire: Polyethylene coated
steel wireNose wire: Malleable polyethylene
wireDifferent
(1)
Ear loops: PolyesterEar loops: SpandexDifferent
(2)
ColorBlueWhiteDifferent
(3)
Dimension
(Width)17.5cm ± 0.2cm17.5cm ± 0.2cmSame
Dimension
(Length)9.5 ± 0.2cm9.5 ± 0.2cmSame
OTC useYesYesSame
SterilityNon-sterileNon-sterileSame
UsageSingle use, disposableSingle use, disposableSame
ASTM F2100
LevelLevel 3Level 2Similar
Fluid
Resistance
Performance
ASTM F186232 out of 32 pass at 160 mmHg32 out of 32 pass at 120 mmHgSimilar
Particulate
Filtration
Efficiency
ASTM F2299Pass at 98.6%pass at 99.88%Similar
Bacterial
Filtration
Efficiency
ASTM F2101Pass at 99.9%pass at 99.6%Similar
Differential
Pressure (Delta
P) MIL-
M36954CPass at $3.5 mmH2O/cm²$pass at $3.0mmH2O/cm2$Similar
Flammability
16 CFR 1610Class 1Class 1Similar
BiocompatibilityUnder the condition of this study
the device is non-cytotoxic, non-
sensitizing and non-irritating.Under the condition of this study
the device is non-cytotoxic, non-
sensitizing and non-irritating.Same
ItemProposed deviceAcceptance criteriaResult
Fluid Resistance
Performance32 out of 32 pass at 160 mmHg29 out of 32 pass at 160 mmHgPass
Particulate Filtration
Efficiency98.6%$\ge$ 98%Pass
Bacterial Filtration
Efficiency99.9%$\ge$ 98%Pass
Differential Pressure
(Delta-P) Test3.5 mmH2O/cm²