K Number
K202899
Date Cleared
2021-05-20

(233 days)

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

The Procedure Masks / 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 Procedure Masks (68-8506-G (Green, ear loop, level 1) & 68-8508-G (Green, ear loop, level 3) are single use, three-layer, flat-folded masks with ear loops, and nose wire. The Procedure Masks are manufactured with three layers, the inner and outer layers are made of spun- bond polypropylene, and the middle layer is made of meltblown polypropylene filter. The ear loops welded are used to keep the mask close to the nose. The elastic ear loops are not made with natural rubber latex. The nose wire is to allow the user to fit the facemask around their nose, which is made of polyethylene wire. The procedure masks will be provided in green. The Surgical Masks (68-8536-B (Blue, tie-on, level 1) & 68-8538-B (Blue, tie-on, level 3) are single use, threelayer, flat-folded masks with Ties, and nose wire. The Surgical Masks are manufactured with three layers, the inner and outer layers are made of spun- bond polypropylene, and the middle layer is made of meltblown polypropylene filter. The ties welded are used to keep the mouth and the nose. The tie is made of spunbond polypropylene. The nose wire is to allow the user to fit the facemask around their nose, which is made of polyethylene wire. The surgical masks will be provided in Blue. The procedure masks are sold non-sterile and are intended to be single use, disposable device.

AI/ML Overview

The provided document is a 510(k) Premarket Notification for a Procedure Mask/Surgical Mask. It describes the device's technical specifications and performance testing. However, it is important to note that this document is for a medical device (a mask) and not a software or AI-based device. Therefore, many of the requested elements for describing an AI study, such as sample size for test sets, data provenance, number of experts for ground truth, adjudication methods, MRMC studies, or training set details, are not applicable in this context.

The document focuses on demonstrating that the proposed device is substantially equivalent to a legally marketed predicate device by meeting certain performance criteria.

Here's the information derived from the document that is applicable to your request, formatted as closely as possible:

1. Table of Acceptance Criteria and Reported Device Performance

The device was tested against the ASTM F2100 requirements for Level 1 and Level 3 masks.

Acceptance Criteria and Device Performance for Level 1 Masks:

ItemAcceptance Criteria (Level 1)Proposed Device (Model 68-8506-G) PerformanceProposed Device (Model 68-8536-B) PerformanceResult
Fluid Resistance$\ge$ 29 out of 32 pass at 80 mmHg32 out of 32 passed at 80 mmHg, 3 lots32 out of 32 passed at 80 mmHg, 3 lotsPASS
Particulate Filtration Efficiency$\ge$ 95%97.4%, 97.5%, 97.5%97.2%, 97.1%, 97.1%PASS
Bacterial Filtration Efficiency$\ge$ 95%99.9% 3 lots99.9% 3 lotsPASS
Differential Pressure< 5.0 mmH₂O/cm²2.9, 2.8, 2.7 mmH₂O/cm²3.7, 3.4, 3.7 mmH₂O/cm²PASS
FlammabilityClass 1Class 1Class 1PASS

Acceptance Criteria and Device Performance for Level 3 Masks:

ItemAcceptance Criteria (Level 3)Proposed Device (Model 68-8508-G) PerformanceProposed Device (Model 68-8538-B) PerformanceResult
Fluid Resistance$\ge$ 29 out of 32 pass at 160 mmHg32 out of 32 passed at 160 mmHg, 3 lots32 out of 32 passed at 160 mmHg, 3 lotsPASS
Particulate Filtration Efficiency$\ge$ 98%98.2%, 98.4%, 98.4%98.4%, 98.4%, 98.3%PASS
Bacterial Filtration Efficiency$\ge$ 98%99.9%, 3 lots99.9%, 3 lotsPASS
Differential Pressure< 6.0 mmH₂O/cm²3.4, 3.0, 3.0 mmH₂O/cm²4.1, 3.4, 3.4 mmH₂O/cm²PASS
FlammabilityClass 1Class 1Class 1PASS

2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

  • Sample Size for Test Set:
    • Fluid Resistance (ASTM F1862): 32 samples per lot, across 3 lots for both Level 1 and Level 3 masks. (e.g., "32 out of 32 passed at 80 mmHg, 3 lots")
    • Particulate Filtration Efficiency (ASTM F2299): Not explicitly stated how many individual samples were tested, but results are reported as percentages for "3 lots."
    • Bacterial Filtration Efficiency (ASTM F2101): Not explicitly stated how many individual samples were tested, but results are reported as percentages for "3 lots."
    • Differential Pressure (EN 14683): Not explicitly stated how many individual samples were tested per lot, but results are reported with three values for each model (e.g., "2.9, 2.8, 2.7 mmH₂O/cm²"), likely representing different samples or averages across lots.
    • Flammability (16 CFR 1610): Not explicitly stated.
  • Data Provenance: The document implies that the tests were conducted by the manufacturer or a third-party lab on samples of their manufactured masks. The manufacturer is KENPAX INTERNATIONAL LIMITED, located in Hong Kong, China. The testing therefore likely occurred in China or at a contract lab. The data is prospective in the sense that these tests were performed on new device samples to demonstrate compliance.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

This type of information is not applicable. The "ground truth" for medical masks is established by validated standardized test methods (e.g., ASTM standards) and not by expert clinical consensus. The performance is measured objectively using specified laboratory procedures.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

Not applicable, as this is objective performance testing against a standard, not classification based on expert opinions.

5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

Not applicable. This is for a physical medical device (mask), not an AI system.

6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

Not applicable. This is for a physical medical device (mask), not an AI system. The tests are for the physical properties of the mask.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

The "ground truth" is based on established engineering and materials science standards for mask performance (e.g., flow rates, particle sizes, microbial viability, fluid pressure) as defined by organizations like ASTM and EN. For example, the ground truth for Bacterial Filtration Efficiency (BFE) is derived from the established protocol of the ASTM F2101 standard, which dictates the aerosolization of Staphylococcus aureus and measurement of filtration effectiveness.

8. The sample size for the training set

Not applicable. This is a physical device, not an AI model that requires a training set.

9. How the ground truth for the training set was established

Not applicable. As above, no AI model or training set is involved.

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May 20, 2021

Kenpax International Limited % Ivy Wang Technical Manager Shanghai Sungo Management Consulting Company Limited 14th Floor, 1500# Central Avenue Shanghai, Shanghai 200122 China

Re: K202899

Trade/Device Name: Procedure Mask/Surgical Mask (Ear loops and 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 Ivy 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.

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Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 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 Clarence W. Murray III, Ph.D. 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

Enclosure

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Indications for Use

510(k) Number (if known) K202899

Device Name Procedure Mask/ Surgical Mask Ear loops and Tie-on

Indications for Use (Describe)

The Procedure Masks / Surgical Masks are intended to be worn to protect both the patient and healtheare 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)

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KENPAX INTERNATIONAL LIMITED Flat 5, 5/F, Wing On Plaza, 62 Mody Road, Tsim Sha Tsui, Kowloon, Hong Kong, China

510(K) Summary K202899

Date of summary prepared: 2021-05-20

A. Applicant:

KENPAX INTERNATIONAL LIMITED Address: Flat 5, 5/F, Wing On Plaza, 62 Mody Road, Tsim Sha Tsui, Kowloon, Hong Kong, China

Submission Correspondent: Primary contact: Ms. Ivy Wang Shanghai SUNGO Management Consulting Co., Ltd. Room 1401, Dongfang Building, 1500# Century Ave., Shanghai 200122, China Tel: +86-21-58817802 Email: haiyu.wang@sungoglobal.com Secondary contact: Mr. Raymond Luo Room 1401, Dongfang Building, 1500# Century Ave., Shanghai 200122, China Tel: +86-21-68828050 Email: fda.sungo@gmail.com

US agent: Solomon Chen 17947 PASEO DEL SOL Chino Hills, CA, US 91709 Phone: 909 4387898 Ext Email: Solomon@Aplusgroup.Net

B. Device:

Trade Name: Procedure mask/ Surgical Mask Common Name: SURGICAL MASK Model: ear loops & Tie-on

Regulatory Information Classification Name: Surgical Face Mask Classification: Class II Product code: FXX Regulation Number: 878.4040 Review Panel: Surgical Apparel

C. Predicate device:

K133070 Surgical Face Mask, Ear Loops, Model 101B, 101G, 136B, 136G, 137B, 137G Surgical Face Mask, Tie-on, Model 145B, 145G, 143B, 138G, 138G, 142B, 142G, 151B, 151G BH Medical Products Co., Ltd.

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KENPAX INTERNATIONAL LIMITED Flat 5, 5/F, Wing On Plaza, 62 Mody Road, Tsim Sha Tsui, Kowloon, Hong Kong, China

D. Indications for use of the device:

The Procedure Masks/ 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.

E. Device Description:

The Procedure Masks (68-8506-G (Green, ear loop, level 1) & 68-8508-G (Green, ear loop, level 3) are single use, three-layer, flat-folded masks with ear loops, and nose wire. The Procedure Masks are manufactured with three layers, the inner and outer layers are made of spun- bond polypropylene, and the middle layer is made of meltblown polypropylene filter.

The ear loops welded are used to keep the mask close to the nose. The elastic ear loops are not made with natural rubber latex. The nose wire is to allow the user to fit the facemask around their nose, which is made of polyethylene wire. The procedure masks will be provided in green.

The Surgical Masks (68-8536-B (Blue, tie-on, level 1) & 68-8538-B (Blue, tie-on, level 3) are single use, threelayer, flat-folded masks with Ties, and nose wire. The Surgical Masks are manufactured with three layers, the inner and outer layers are made of spun- bond polypropylene, and the middle layer is made of meltblown polypropylene filter.

The ties welded are used to keep the mouth and the nose. The tie is made of spunbond polypropylene. The nose wire is to allow the user to fit the facemask around their nose, which is made of polyethylene wire. The surgical masks will be provided in Blue.

The procedure masks are sold non-sterile and are intended to be single use, disposable device. The difference

Product ModelFeatureLayers (components)Nose WireEarloopColorant
68-8506-GASTM Level 1GreenEarloopOuter: 22gsm SPPPolyethyleneCoated Steel WirePolyesterGreenmasterbatchPCG861
Middle: 22gsm MB
Inner: 22gsm SPP
68-8508-GASTM Level 3GreenEarloopOuter: 25gsm SPPPolyethyleneCoated Steel WirePolyesterGreenmasterbatchPCG861
Middle: 25gsm MB
Inner: 25gsm SPP
68-8536-BASTM Level 1BlueTie-onOuter: 22gsmSPPPolyethyleneCoated Steel Wire40gsm SPPBluemasterbatchPCB1628
Middle: 22gsmMB
Inner: 22gsmSPP
68-8538-BASTM Level 3BlueTie-onOuter: 25gsmSPPPolyethyleneCoated Steel Wire40gsm SPPBluemasterbatchPCB1628
Middle: 25gsmMB
Inner: 25gsmSPP

Detailed information of the four models please see below table.

F. Comparison with predicate device

The procedure masks/surgical masks are essentially the same as or similar to the predicate device in terms of the intended use, design and construction, performance characteristics.

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Table 1 General Comparison
DeviceProposed DevicePredicate DeviceResult
510K #K202899K133070
ManufacturerKENPAX INTERNATIONAL LIMITEDBH Medical Products Co., Ltd.
ModelNameProcedure Mask/ Surgical MaskEar loops & tie-onSurgical Face Mask, Ear Loops, Model101B, 101G, 136B, 136G, 137B, 137GSurgical Face Mask, Tie-on, Model 145B,145G, 143B, 143G, 138B, 138G, 142B,142G, 151B, 151GSimilar
ClassificationClass II Device, FXX (21 CFR878.4040)Class II Device, FXX (21 CFR878.4040)Same
Intend Use/Indicationsfor UseThe Procedure Masks/ Surgical Masksare intended to be worn to protectboth the patient and healthcarepersonnel from transfer ofmicroorganisms, body fluids, andparticulate material. These face masksare intended for use in infectioncontrol practices to reduce thepotential exposure to blood and bodyfluids. This is a single use, disposabledevice(s), provided non-sterile.The surgical face masks are intended tobe worn to protect both the patientand healthcare personnel from transferof microorganisms, body fluids andparticulate material. These face masksare intended for use in infectioncontrol practices to reduce thepotential exposure to blood and bodyfluids. This is a single use, disposabledevice(s), provided non-sterile.Same
Materials
Outer layerSpunbond PolypropyleneLevel 1: 22gsmLevel 3: 25gsmSpunbond PolypropyleneSame
Inner layerSpunbond PolypropyleneLevel 1: 22gsmLevel 3: 25gsmSpunbond PolypropyleneSame
Filter layerMelt-blown PolypropyleneLevel 1: 22gsmLevel 3: 25gsmMeltblown PolypropyleneSame
Nose wirePolyethylene Coated Steel WireAluminum WireDifferent
Ear loopsNylon, spandexPolyesterDifferent
Tie-onSpunbond PolypropyleneSpunbond PolypropyleneSame
DesignFeaturesEar Loops, Tie-onEar Loops, Tie-OnSame
Mask styleFlat PleatedFlat PleatedSame
ColorBlue, greenBlue, GreenSame
Dimension(Length)178±5mm3.5"+/-0.25"4.2"+/-0.25"Similar
Dimension(Width)95±5mm6.8"+/-0.25"Similar
OTC useYesYesSame
SterilityNon-SterileNon-SterileSame
UseSingle Use, DisposableSingle Use, DisposableSame
BiocompatibilityNon-cytotoxic, Non-sensitizing, non-irritatingNon-cytotoxic, Non-sensitizing, non-irritatingSame
Performance Testing (see Table 2)
ASTM levelLevel 1, Level 3Level 1, Level 2, Level 3Similar
FluidResistanceMeet ASTM F1862-17Meet ASTM F1862-07similar
ParticulateFiltrationEfficiencyMeet ASTM F2299-17Meet ASTM F2299-03Similar
BacterialFiltrationEfficiencyMeet ASTM F2101-19Meet ASTM F2101-07Similar
DifferentialPressureMeet EN 14683: 2019, Annex CMeet MIL-M36945CDifferent
FlammabilityMeet 16 CFR 1610Meet 16 CFR 1610Similar
BiocompatibilityNon-cytotoxic, Non-sensitizing, non-irritatingNon-cytotoxic, Non-sensitizing, non-irritatingSame

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KENPAX INTERNATIONAL LIMITERNATIONAL LIMITED

Flat 5, 5/F, Wing On Plaza, 62 Mody Road, Tsim Sha Tsui, Kowloon, Hong Kong, China

Table 2 Comparison of Performance testing

ItemProposed device (K202899)Predicate device (K133070)Acceptance criteria (Level 1)Result
Model 68-8506-GModel 68-8536-B
Fluid Resistance32 out of 32 passed at 80 mmHg, 3 lots32 out of 32 passed at 80 mmHg, 3 lotsMeet the ASTM F2100 Requirements for Level 1 Classification29 out of 32 pass at 80 mmHgPASS
Particulate Filtration Efficiency97.4%, 97.5%, 97.5%97.2%, 97.1%, 97.1%Meet the ASTM F2100 Requirements for Level 1 Classification≥95%PASS
Bacterial Filtration Efficiency99.9% 3 lots99.9% 3 lotsMeet the ASTM F2100 Requirements for Level 1 Classification≥95%PASS
Differential Pressure2.9, 2.8, 2.7 mmH₂O/cm²3.7, 3.4, 3.7 mmH₂O/cm²Meet the ASTM F2100 Requirements for Level 1 Classification<5.0PASS
FlammabilityClass 1Class 1Class 1Class 1PASS
ItemProposed device (K202899)Predicate device(K133070)Acceptance criteria(Level 3)Result
Model 68-8508-GModel 68-8538-B

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KENPAX INTERNATIONAL LIMITED Flat 5, 5/F, Wing On Plaza, 62 Mody Road, Tsim Sha Tsui, Kowloon, Hong Kong, China

FluidResistance32 out of 32 passedat 160 mmHg, 3 lots32 out of 32 passedat 160 mmHg, 3 lotsMeet the ASTM F2100Requirements forLevel 3 Classification29 out of 32 passat 160 mmHgPASS
ParticulateFiltrationEfficiency98.2%,98.4%98.4%98.4%,98.4%,98.3%Meet the ASTM F2100Requirements for Level3 Classification≥98%PASS
BacterialFiltrationEfficiency99.9%, 3 lots99.9%, 3 lotsMeet the ASTM F2100Requirements for Level3 Classification≥98%PASS
DifferentialPressure3.4, 3.0, 3.0mmH2O/cm²4.1, 3.4, 3.4mmH2O/cm²Meet the ASTM F2100Requirements for Level3 Classification<6.0PASS
FlammabilityClass 1Class 1Class 1Class 1PASS

G. Summary of Non-Clinical Test

Non-clinical tests were conducted to verify that the proposed device met all design specifications as was same to the predicate device. The test results demonstrated that the proposed device complies with 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:

  • ISO 10993-5: 2009 Biological Evaluation of Medical Devices -- Part 5: Tests For In Vitro Cytotoxicity

  • A ISO 10993-10: 2010 Biological Evaluation of Medical Devices - Part 10: Tests For Irritation And Skin Sensitization
  • ASTM F2100, Standard Specification for Performance of Materials Used In Medical Face Masks

  • ASTM F1862, Standard Test Method for Resistance of Medical Face Masks To Penetration by Synthetic Blood (Horizontal Projection of Fixed Volume At A Known Velocity);

  • A EN 14683, Medical Face Masks—Requirements and Test Methods;
  • ASTM F2101, Standard Test Method for Evaluating the Bacterial Filtration Efficiency (BFE) Of Medical Face Mask Materials, Using A Biological Aerosol of Staphylococcus Aureus;

  • ASTM F2299, Standard test method for determining the initial efficiency of materials used in medical face masks to penetration by particulates using latex spheres;

  • A 16 CFR 1610, Standard for the Flammability of clothing textiles;

H. Summary of Clinical Test

No clinical study is included in this submission.

l. Conclusion

The conclusions drawn from the nonclinical tests demonstrate that the subject device is as safe, as effective, and performs as well as or better than the legally marketed predicate device K133070.

§ 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.