K Number
K202719
Date Cleared
2021-01-04

(109 days)

Product Code
Regulation Number
878.4040
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The non-sterile disposable medical 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, provided non-sterile.

The sterile disposable medical face masks are intended for single use 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 particulate materials.

Device Description

The proposed device. Disposable medical face masks, is provide in sterile and non-sterile two types.

Both the non-sterile disposable medical face masks and sterile disposable medical face masks are available in five sizes, which are 95mm×155mm, 95mm×140mm, 95mm×145mm and 95mm×160mm. And both the non-sterile disposable medical face masks and sterile disposable medical face masks are available in two ear strap types, Type A, which is ear-loop type, and Type B, which is tie-on type.

AI/ML Overview

This document describes a 510(k) premarket notification for "Disposable Medical Face Masks" (K202719) by Jiangxi Sanxin Medtec Co., Ltd. The submission aims to demonstrate substantial equivalence to legally marketed predicate devices.

Here's an analysis of the acceptance criteria and supporting studies, based on the provided text:

1. Acceptance Criteria and Reported Device Performance

The acceptance criteria for the Disposable Medical Face Masks are based on Level 2 requirements of the ASTM F2100:2019 standard. The study demonstrates that the proposed device meets these requirements.

Table of Acceptance Criteria and Reported Device Performance:

Performance CharacteristicAcceptance Criteria (ASTM F2100:2019 Level 2)Proposed Device Performance (Non-sterile)Proposed Device Performance (Sterile)
Fluid resistancePass at 120 mmHgPass at 120 mmHgPass at 120 mmHg
Particulate Filtration Efficiency (PFE)≥ 98%Average 98.17%Average 98.14%
Bacterial Filtration Efficiency (BFE)≥ 98%Average 98.38%Average 98.64%
Differential Pressure< 5.0 mmH₂O/cm²Average 1.78 mmH₂O/cm²Average 1.78 mmH₂O/cm²
FlammabilityClass 1Class 1Class 1
CytotoxicityNon-cytotoxicNon-cytotoxicNon-cytotoxic
SensitizationNon-sensitizingNon-sensitizingNon-sensitizing
IrritationNon-irritatingNon-irritatingNon-irritating

2. Sample Size and Data Provenance

The document does not explicitly state the specific sample sizes used for each non-clinical test (e.g., for BFE, PFE, fluid resistance). It only presents the "Average" values, implying that multiple samples were tested.

The data provenance is from non-clinical tests conducted by the manufacturer, Jiangxi Sanxin Medtec Co., Ltd., based in China. The studies are retrospective in the sense that they are conducted on the finished device to demonstrate compliance with standards.

3. Number of Experts and Qualifications for Ground Truth

This information is not applicable as the evaluation relies on objective non-clinical performance standards and laboratory testing rather than expert-derived ground truth.

4. Adjudication Method for the Test Set

This is not applicable as the device performance is evaluated against predefined objective standards and laboratory test results, not through expert adjudication of ambiguous cases.

5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

No MRMC comparative effectiveness study was done. The device is a medical face mask, and its evaluation is based on material properties and barrier performance, not on interpretation by human readers.

6. Standalone Performance Study

Yes, a standalone (i.e., algorithm only without human-in-the-loop performance) study was done, though the "algorithm" here refers to the device itself, not a software algorithm. The non-clinical tests assess the inherent performance characteristics of the face mask (e.g., filtration efficiency, fluid resistance) independently of human interaction.

7. Type of Ground Truth Used

The ground truth used is based on objective performance standards and laboratory test results as defined by recognized standards such as ASTM F2100:2019. These standards specify quantitative thresholds for various performance metrics (e.g., filtration percentages, pressure differentials, fluid resistance levels).

8. Sample Size for the Training Set

This information is not applicable. The device is a physical product (medical face mask), not an AI/ML algorithm that requires a "training set." The materials and manufacturing processes are designed to meet the performance criteria, and the non-clinical tests verify this compliance.

9. How the Ground Truth for the Training Set Was Established

This is not applicable as there is no "training set" in the context of this device. The design and manufacturing are based on established engineering principles and material science to achieve the required performance for medical face masks as outlined in relevant standards.

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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.

January 4, 2021

Jiangxi Sanxin Medtec Co., Ltd. % Diana Hong General Manager Mid-Link Consulting Co., Ltd. P.O. Box 120-119 Shanghai, 200120 China

Re: K202719

Trade/Device Name: Disposable Medical Face Masks Regulation Number: 21 CFR 878.4040 Regulation Name: Surgical Apparel Regulatory Class: Class II Product Code: FXX Dated: December 7, 2020 Received: December 11, 2020

Dear Diana Hong:

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

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requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801 and Part 809); 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,

For CAPT Elizabeth F. Claverie 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) K202719

Device Name Disposable Medical Face Masks

Indications for Use (Describe)

The non-sterile disposable medical 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, provided non-sterile.

The sterile disposable medical face masks are intended for single use 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 particulate materials.

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

Prescription Use (Part 21 CFR 801 Subpart D)

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

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510(k) Summary

This 510(k) Summary is being submitted in accordance with requirements of Title 21, CFR Section 807.92.

The assigned 510(k) Number: K202719

    1. Date of Preparation: 1/1/2021
    1. Sponsor Identification

Jiangxi Sanxin Medtec Co., Ltd.

No.999, Fushan Road, Xiaolan Economic Development, Nanchang, Jiangxi, 330200, China.

Establishment Registration Number: 3005246939

Contact Person: Shuiqing Sun Position: Registered Engineer Tel: +86-791-85988111 Fax: +86-791-85988030 Email: 1304921073@qq.com

  • Designated Submission Correspondent 3.
    Ms. Diana Hong (Primary Contact Person) Ms. Jing Cheng (Alternative Contact Person)

Mid-Link Consulting Co., Ltd. P.O. Box 120-119, Shanghai, 200120, China

Tel: +86-21-22815850 Fax: 360-925-3199 Email: info@mid-link.net

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4. Identification of Proposed Device

Trade Name: Disposable Medical Face Masks Common Name: Surgical Face Mask

Regulatory Information Classification Name: Surgical apparel Class: II; Product Code: FXX; Regulation Number: 21CFR 878.4040 Review Panel: General Hospital;

Indication for use

The non-sterile disposable medical 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, provided non-sterile.

The sterile disposable medical face masks are intended for single use 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 particulate materials.

Device Description

The proposed device. Disposable medical face masks, is provide in sterile and non-sterile two types.

Both the non-sterile disposable medical face masks and sterile disposable medical face masks are available in five sizes, which are 95mm×155mm, 95mm×140mm, 95mm×145mm and 95mm×160mm. And both the non-sterile disposable medical face masks and sterile disposable medical face masks are available in two ear strap types, Type A, which is ear-loop type, and Type B, which is tie-on type.

5. Identification of Predicate Devices

Predicate Device 1 510K Number: K153496 Manufacturer: Xiantao Rayxin Medical Products Co., Ltd. Trade Name: Disposable Surgical Face Mask

Predicate Device 2 510K Number: K173062

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Manufacturer: V&Q Manufacturing Corporation Trade Name: Non Woven Face Mask (Models: VON0185W (earloop) and VON0185B (ties))

  • Non-Clinical Testing 6.
    Non clinical tests were conducted to verify that the proposed device met all design specifications as was Substantially Equivalent (SE) to the predicate device. The test results demonstrated that the proposed device complies with the following standards:

  • ISO 10993-7:2018 Biological Evaluation of Medical Device- Part 7: Ethylene Oxide Sterilization Residuals

  • A ASTM F88/F88M-15, Standard Test Method For Seal Strength Of Flexible Barrier Materials.(Sterility)

  • ASTM F1929-15 Standard Test Method for Detecting Seal Leaks in Porous Medical Package by Dye Penetration

  • ISO 10993-5:2009 Biological evaluation of medical device- Part 5: Tests for in vitro cytotoxicity

  • A ISO 10993-10:2010 Biological evaluation of medical device- Part 10: Tests for irritaion and skin sensitization

  • ASTM F1862/F1862M-17 Standard Test Method for Resistance of Medical Face Masks to Penetration by Synthetic Blood (Horizontal Projection of Fixed Volume at a Known Velocity)

  • ASTM F2299/F2299M-03 (2017) Standard Test Method for Determining the Initial Efficiency of Material Used in medical Face Masks to Penetration by Particulates using Latex Spheres

  • ASTM F2101-2019 Standard Test Method for Evaluating the Bacterial Filtration Efficiency (BFE) A of Medical Face Mask Materials, Using a Biological Aerosol of Staphylococcus aureus

  • Annex C, EN 14683:2019 Medical face masks- Requirements and test methods >

  • 16 CFR 1610 Standard for the Flammability of Clothing Textiles Corrections

    1. Clinical Testing

No clinical study is included in this submission.

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8. Technological Characteristics Comparison

TEMProposed DevicePredicate Device 1K153496Remark
Product CodeFXXFXXSame
Regulation No.21 CFR 878.404021 CFR 878.4040Same
ClassIIIISame
Indication for UseThe non-sterile disposable medicalface masks are intended to be worn toprotect both the patient andhealthcare personnel from transfer ofmicroorganisms, body fluids andparticulate material. These facemasks are intended for use ininfection control practices to reducethe potential exposure to blood andbody fluids. This is a single use,disposable device, providednon-sterileThe Disposable Surgical Face Masksare intended to be worn to protectboth the patient and healthcarepersonnel from transfer ofmicroorganisms, body fluids andparticulate material. These facemasks are intended for use ininfection control practices to reducethe potential exposure to blood andbody fluids. This is a single use,disposable device(s), providednon-sterile.Same
Mask styleFlat pleatedFlat pleatedSame
Design FeatureEar-loop or tie-onEar-loop or tie-onSame
Maskbodydimension (mm)95mm×175mm95mm×155mm95mm×140mm95mm×145mm95mm×160mm175mm×95mmDifferent
Ties dimension(mm)Ear-loop type: 175mm, 160mm,155mm, 145mm, 140mmTie-on type: 277.5mmUnknownDifferent
Noseclipdimension (mm)105mmUnknownDifferent
LevelLevel 2Level 2Same
Fluid resistancePass at 120mmHgPass at 120mmHgSame
Particulateefficiency levelAverage 98.17%98.46%Different
Bacterialfiltration levelAverage 98.38%98.7%Different
DifferentialAverage 1.78 mmH₂O/cm²4.2 mmH₂O/cm²Different
Table 1 General comparison for non-sterile disposable medical face masks

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pressure
FlammabilityClass 1Class 1Same
Label/LabelingComplied with 21 CFR part 801Complied with 21 CFR part 801Same
Single useSingle useSingle useSame
ear strap (ear-loop)Polyester and spandexPolyester
ear strap (tie-on)Polypropylene non-woven fabricSpun-bond polypropylene
nose clipGalvanized iron wire coated with polypropyleneMalleable aluminum wireDifferent
mask bodyPolypropylene non-woven fabric and Melt-blown polypropyleneSpun-bond polypropyleneMelt blown polypropylene filter
CytotoxicityUnder the conditions of the study, the proposed device extract was determined to be non-cytotoxic.Under the conditions of the study, not cytotoxicity effectSame
SensitizationUnder the conditions of the study, the proposed device extract was determined to be non-sensitizing.Under the conditions of the study, not a sensitizerSame
IrritationUnder the conditions of the study, the proposed device extract was determined to be non-irritating.Under the conditions of the study, not an irritantSame
SterilityNon-sterileNon-sterileSame

Different - Mask body dimension, Ties dimension and Nose clip dimension

The dimension for the proposed device is different from predicate devices. As the length decreases, the area of the mask decreases gradually. Smaller masks are suitable for patient with smaller face. This difference does not affect intended use and will not raise any safety issues. Therefore, will not affect the safety and effectiveness of the proposed device. Thus, this difference does not affect the substantial equivalence between the proposed device and predicate devices.

Different - Particulate filtration efficiency

The test result for particulate filtration efficiency for the proposed device is different from predicate devices. However, the test result for the proposed device can meet the requirements of level 2 based on ASTM F2100:2019. Therefore, the difference will not affect the safety and effectiveness of the proposed device. Thus, this difference does not affect the substantial equivalence between the proposed device and predicate devices.

Different - Bacterial filtration efficiency

The test result for bacterial filtration efficiency for the proposed device is different from predicate devices. However, the test result for the proposed device can meet the requirements of level 2 based on ASTM F2100:2019. Therefore, the difference will not affect the safety and effectiveness of the proposed

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device. Thus, this difference does not affect the substantial equivalence between the proposed device and predicate devices.

Different - Differential Pressure

The test result for differential pressure for the proposed device is different from predicate devices. However, the test result for the proposed device can meet the requirements of level 2 based on ASTM F2100:2019. Therefore, the difference will not affect the safety and effectiveness of the proposed device. Thus, this difference does not affect the substantial equivalence between the proposed device and predicate devices.

Different - Patient Contacting Material

The patient contacting material for the proposed device is different from predicate devices. However, biocompatibility test has been conducted on the proposed device and the test result does not show any adverse effect. Therefore, the difference will not affect the safety and effectiveness of the proposed device. Thus, this difference does not affect the substantial equivalence between the proposed device and predicate devices

ITEMProposed DevicePredicate Device 2Remark
Product CodeFXXFXXSame
RegulationNo.21 CFR 878.404021 CFR 878.4040Same
ClassIIIISame
Indication forUseThe sterile disposable medical facemasks are intended for single use byoperating room personnel and othergeneral healthcare workers to protectboth patients and healthcare workersagainst transfer of microorganisms,blood and body fluids, andparticulate materials.Non Woven Face Mask (Models:VQN0185W (earloop) andVQN0185B (ties)) is intendedfor single use by operating roompersonnel and other generalhealthcare workers to protectboth patients and healthcareworkers against transfer ofmicroorganisms, blood and bodyfluids, and particulate materials.Same
Mask styleFlat pleatedFlat pleatedSame
Design FeatureEar-loop or tie-onEar-loop or tie-onSame
Dimension(mm)95mm×175mm95mm×155mm95mm×140mm95mm×145mm175mm×95mmDifferent
95mm×160mm
Ties dimension (mm)Ear-loop type: 175mm, 160mm, 155mm, 145mm, 140mmTie-on type: 277.5mmUnknown
Nose clip dimension (mm)105mmUnknown
LevelLevel 2Level 2Same
Fluid resistancePass at 120mmHgPass at 120mmHgSame
Particulate efficiency levelAverage 98.14%Average 99.74%Different
Bacterial filtration levelAverage 98.64%Average 99.4%Different
Differential pressureAverage 1.78 mmH2O/cm²Average 2.7mmH2O/cm²Different
FlammabilityClass 1Class 1Same
Label/LabelingComplied with 21 CFR part 801Complied with 21 CFR part 801Same
Single useSingle useSingle useSame
ear strap (ear-loop)Polyester and spandexUrethane elastic fiber or spun-bond polypropyleneDifferent
ear strap (tie-on)Polypropylene non-woven fabric
nose clipGalvanized iron wire coated with polypropyleneWhite aluminum strip covered by polypropylene covering
mask bodyPolypropylene non-woven fabric and Melt-blown polypropyleneSpun-bond polypropylene
CytotoxicityUnder the conditions of the study, the proposed device extract was determined to be non-cytotoxic.Under the conditions of the study, the proposed device extract was determined to be non-cytotoxic.Same
SensitizationUnder the conditions of the study, the proposed device extract was determined to be non-sensitizing.Under the conditions of the study, the proposed device extract was determined to be non-sensitizing.Same
IrritationUnder the conditions of the study, the proposed device extract was determined to be non irritatingUnder the conditions of the study, the proposed device extract was determined to beSame
non-irritating.
Sterilitysterilenon-sterileDifferent

Table 2 General comparison for sterile disposable medical face masks

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Different - Mask body dimension, Ties dimension and Nose clip dimension

The dimension for the proposed device is different from predicate devices. As the length decreases, the area of the mask decreases gradually. Smaller masks are suitable for patient with smaller face. This difference does not affect intended use and will not raise any safety issues. Therefore, the difference will not affect the safety and effectiveness of the proposed device. Thus, this difference does not affect the substantial equivalence between the proposed device and predicate devices.

Different - Particulate filtration efficiency

The test result for particulate filtration efficiency for the proposed device is different from predicate devices. However, the test result for the proposed device can meet the requirements of level 2 based on ASTM F2100:2019. Therefore, the difference will not affect the safety and effectiveness of the proposed device. Thus, this difference does not affect the substantial equivalence between the proposed device and predicate devices.

Different - Bacterial filtration efficiency

The test result for bacterial filtration efficiency for the proposed device is different from predicate devices. However, the test result for the proposed device can meet the requirements of level 2 based on ASTM F2100:2019. Therefore, the difference will not affect the safety and effectiveness of the proposed device. Thus, this difference does not affect the substantial equivalence between the proposed device and predicate devices.

Different - Differential Pressure

The test result for differential pressure for the proposed device is different from predicate devices. However, the test result for the proposed device can meet the requirements of level 2 based on ASTM F2100:2019. Therefore, the difference will not affect the safety and effectiveness of the proposed device. Thus, this difference does not affect the substantial equivalence between the proposed device and predicate devices.

Different - Patient Contacting Material

The patient contacting material for the proposed device is different from predicate devices. However, biocompatibility test has been conducted on the proposed device and the test result does not show any adverse effect. Therefore, the difference will not affect the safety and effectiveness of the proposed device. Thus, this difference does not affect the substantial equivalence between the proposed device and predicate devices.

Different - Product status

The final product status of the proposed device is different from predicate device, one is sterilized and

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the other is non-sterilized. Sterilization will affect the safety and effective of the mask. The performance testing of the proposed device has been conducted on the final product and the test results show that the proposed sterile mask meets the requirements of ASTM F2100-2019. And biocompatibility testing of the proposed device has also been conducted on the final product and the test results showed that there are no negative impacts from the materials that are used in the proposed sterile mask. Therefore, although the final product status is different between the proposed device and predicate device, the final product status does not affect the safety and effectiveness of the proposed device. Therefore, this difference does not affect the substantial equivalence between the proposed device and predicate device.

9. Conclusions

Based on the comparison and analysis above, the proposed devices are as safe, as effective, and performs as well as the legally marketed predicate devices.

§ 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.