K Number
K203415
Date Cleared
2021-05-20

(182 days)

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

The Surgical Isolation Gown is intended to protect patients and health care personnel from the transfer of microorganisms, body fluids and particulate material. Not intended for use in the operating room. In addition, the Surgical Isolation Gown meets the requirements of an AAMI Level 3 barrier protection for an isolation gown per ANSI/AAMI PB70:2012 Liquid Barrier Performance and Classification of Protective Apparel Drapes Intended for Use in Health Care Facilities (ANSI/AAMI PB70). The Surgical Isolation Gown is a single use, disposable medical device provided non-sterile.

Device Description

The proposed Surgical Isolation Gown is constructed of Polypropylene SMS non-woven material with the color in blue. The melt-blown nonwovens are made of polypropylene. The Surgical isolation gown is different in size. The size of surgical isolation gown is divided into seven groups: S(160), M(165), L(170), XL(175), XXL(180), 3XL(185), 4XL(190).

The Surgical Isolation Gown is a single use, disposable medical device provided non-sterile.

The device description of the Surgical Isolation Gown is in accordance with the Guidance on Premarket Notification [510(k)] Submissions for Surgical Gowns and Surgical Drapes, issued on August 1, 1993 and ANSI/AAMI PB70:2012 Liquid Barrier Performance and Classification of Protective Apparel and Drapes Intended for Use in Health Care Facilities.

AI/ML Overview

The provided text describes the regulatory clearance for a medical device, a Surgical Isolation Gown, and details the non-clinical tests performed to demonstrate its substantial equivalence to a predicate device. This document is a 510(k) summary, not a study describing the development of an AI algorithm or its performance in a clinical setting. Therefore, many of the requested categories are not applicable.

Here's an analysis based on the provided text, focusing on the acceptance criteria and the "study" (non-clinical testing) that proves the device meets them:

1. A table of acceptance criteria and the reported device performance

The acceptance criteria for the Surgical Isolation Gown are primarily based on established industry standards and regulatory guidance for barrier performance, physical properties, flammability, and biocompatibility. The reported device performance is compared against these standards.

Table of Acceptance Criteria and Device Performance

Test/CharacteristicAcceptance Criteria (Standard)Reported Device Performance (Proposed Device K203415)Equivalence to Predicate (K190306)
Barrier Performance (AAMI PB70:2012)AAMI Level 3 barrier protectionMeets AAMI Level 3 requirementsSame
Water Resistance (AATCC 42-2017)Meets requirements for Level 3 per AAMI PB70:2012Met Level 3 requirementsNot explicitly compared in table, but overall meets AAMI L3.
Water Resistance (AATCC 127-2018)Meets requirements for Level 3 per AAMI PB70:2012Met Level 3 requirementsNot explicitly compared in table, but overall meets AAMI L3.
Basic Weight (ASTM D3776/D3776M-09)No explicit acceptance criterion given, but compared to predicate.60.7 g/m² (1.79 oz/yd²)Similar (Predicate: 39.97 ± 1.61 g/m²)
Flammability (16 CFR Part 1610.7)Class 1 FlammabilityClass 1Same
Breaking Strength (MD) (ASTM D5034-09)No explicit acceptance criterion given, but compared to predicate.Mean: 175.5 NSimilar (Predicate: 18.17 ± 0.31 lbf)
Breaking Strength (CD) (ASTM D5034-09)No explicit acceptance criterion given, but compared to predicate.Mean: 118.0 NSimilar (Predicate: 11.78 ± 0.33 lbf)
Tearing Strength (MD) (ASTM D5587-2015)No explicit acceptance criterion given, but compared to predicate.Mean: 63.5 NSimilar (Predicate: 11.01 ± 0.64 lbf)
Tearing Strength (CD) (ASTM D5587-2015)No explicit acceptance criterion given, but compared to predicate.Mean: 34.5 NSimilar (Predicate: 5.30 ± 0.35 lbf)
Linting (ISO 9073-10:2004)No explicit acceptance criterion given, but compared to predicate.Particulate size range (μm): 3 to 25; Coefficient of linting log10 Min:2.2, Max:2.8, Mean: 2.5 (Face A); Min:2.5, Max:2.9, Mean:2.74 (Face B)Similar (Predicate values also provided)
Cytotoxicity (ISO 10993-5:2009)Non-CytotoxicNon-CytotoxicSame
Irritation (ISO 10993-10:2010)Non-Irritating and Non-SensitizingNon-IrritatingSame
Sensitization (ISO 10993-10:2010)Non-Irritating and Non-SensitizingNon-SensitizingSame

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

The document does not specify the exact sample sizes (number of gowns or material samples) used for each non-clinical test. The tests were performed according to recognized ASTM, AATCC, ISO standards, and FDA guidances. The data provenance is described as non-clinical tests performed on the proposed device, manufactured by YANBIAN PACIFIC TEXTILE CO., LTD in China. These would be prospective tests specifically conducted for this submission.

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 question is not applicable. The device is a surgical isolation gown, not an AI or diagnostic device that requires expert ground truth establishment in the traditional sense of medical image analysis or clinical diagnosis. The "ground truth" for this device's performance is derived from standardized physical, chemical, and biological testing methods as defined by the mentioned international standards.

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

Not applicable. Adjudication methods like 2+1 or 3+1 are used in studies where human readers provide interpretations (e.g., radiological reads) and disagreement needs to be resolved. This is a physical device subject to standard laboratory testing.

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 not an AI-assisted diagnostic or interpretative device.

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

Not applicable. This is not an AI algorithm. The performance described is for a physical product, the Surgical Isolation Gown, in a standalone testing environment (laboratory tests).

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

The "ground truth" for the device's performance is based on the objective measurements and pass/fail criteria defined within the specified international standards (e.g., AAMI PB70:2012 for barrier performance, ISO 10993 for biocompatibility, ASTM for physical properties).

8. The sample size for the training set

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

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

Not applicable. As above, there is no training set mentioned or required for this type of device submission.

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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.

Yanbian Pacific Textile Co., LTD % Rafi Wong Manager Pacific Fortune Management Inc. 2350 Mission College BLVD, STE 475 Santa Clara, California 95054

Re: K203415

Trade/Device Name: Surgical Isolation Gown Regulation Number: 21 CFR 878.4040 Regulation Name: Surgical Apparel Regulatory Class: Class II Product Code: FYC, Dated: April 13, 2021 Received: April 19, 2021

Dear Rafi Wong:

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); 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 Ryan Ortega 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)

K203415

Device Name

Surgical Isolation Gown

Indications for Use (Describe)

The Surgical Isolation Gown is intended to protect patients and health care personnel from the transfer of microorganisms, body fluids and particulate material. Not intended for use in the operating room. In addition, the Surgical Isolation Gown meets the requirements of an AAMI Level 3 barrier protection for an isolation gown per ANSU AAMI PB70:2012 Liquid Barrier Performance and Classification of Protective Apparel Drapes Intended for Use in Health Care Facilities (ANSI/AAMI PB70). The Surgical Isolation Gown is a single use, disposable medical device provided non-sterile.

Type of Use (Select one or both, as applicable)
-------------------------------------------------
☐ Research Use (Part 21 CFR 601 Subpart D)
☑ Source Tissue Controlled (21 CFR 601 Subpart C)

| | Prescription Use (Part 21 CFR 801 Subpart D)

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

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4. Indications for Use Statement

The Surgical Isolation Gown is intended to protect health care patients and health care personnel from the transfer of microorganisms, body fluids and particulate material. Not intended for use in the operating room. In addition, the Surgical Isolation Gown meets the requirements of an AAMI Level 3 barrier protection for an isolation gown per ANSI/AAMI PB70:2012 Liquid Barrier Performance and Classification of Protective Apparel Drapes Intended for Use in Health Care Facilities (ANSI/AAMI PB70). The Surgical Isolation Gown is a single use, disposable medical device provided non-sterile.

The Surgical Isolation Gown is considered under the product code, FYC, under the classification of a surgical isolation gown per the new Guidance for Industry and FDA Staff - Premarket Notification Requirements Concerning Gowns Intended for Use in Healthcare Settings issued by the FDA on December 9, 2015 because this isolation gown has a moderate barrier protection.

The Surgical Isolation Gowns are non-sterile and provided in ONE product model in seven sizes to meet the needs of healthcare patients and health care personnel, Refer to Table 1 below. The medical device will be available in one model in S(160), M(165), L(170), XL(175), XXL(180), 3XL(185), 4XL(190) sizes.

The proposed Surgical Isolation Gown is constructed of Polypropylene SMS non-woven material with the color in blue. The Surgical Isolation Gowns consist of a one critical zone throughout the entire gown including seams but excluding cuffs, hems, and bindings. The product has been tested for barrier performance per ANSI/AAMI PB70:2012. Testing was performed according to the Guidance on Premarket Notification [510(k)] Submissions for Surgical Gowns and Surgical Drapes, issued on August 1, 1993 and ANSI/AAMI PB70:2012 Liquid Barrier Performance and Classification of Protective Apparel and Drapes Intended for Use in Health Care Facilities. All results of testing met AATCC-42/AATCC-127, and meets AAMI PB70:2012 Level 3 requirements.

ProductNameModelNumberSterilityColorDimensionsSize
SurgicalIsolationGownNon-sterileBlue105cm×125cmS(160)
110cm×130cmM(165)
12265115cm×135cmL(170)
120cm×140cmXL(175)
125cm×145cmXXL(180)
130cm×150cm3XL(185)
135cm×155cm4XL(190)

Table 1 Specifications and dimensions of proposed device

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510K SUMMARY

K203415

Date of Summary Prepared:

May 20, 2021

Submitter Information 1.

Submitter Contact:YANBIAN PACIFIC TEXTILE CO., LTDLongjing industry concentration area, Longjing cityJilin, China, 133400
Submitter Contact Person:
Name:Juan Zhuang
Phone Number:(+86) 138-6397-7758
Email:zhuangjuan777@126.com
Designated Submission Correspondent:
Name:Rafi Wong
Phone Number:+1 (408) 646-6537
Email:rafi.wong@pfmfinance.com

2. Device Name: Surgical Isolation Gown

3. Regulatory Information

Classification Name:Surgical Isolation Gown
Common Name:Surgical Apparel
Classification:Class II
Product Code:FYC
Regulation Number:21 CFR 878.4040

4. Predicate Device

510K Number:K190306 - AMD Medicom Inc.
Device Name:AMD Ritmed AssureWear™ VersaGown
Cleared date:January 17, 2020

5. Intended Use/Indications for Use

The Surgical Isolation Gown is intended to protect patients and health care personnel from the transfer of microorganisms, body fluids and particulate material. Not intended for use in the operating room. In addition, the Surgical Isolation Gown meets the requirements of an AAMI Level 3 barrier protection for an isolation gown per ANSI/AAMI PB70:2012 Liquid Barrier Performance and Classification of Protective Apparel Drapes Intended for Use in Health Care Facilities (ANSI/AAMI PB70). The Surgical Isolation Gown is a single use, disposable medical device provided non-sterile.

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6. Device Description

The proposed Surgical Isolation Gown is constructed of Polypropylene SMS non-woven material with the color in blue. The melt-blown nonwovens are made of polypropylene. The Surgical isolation gown is different in size. The size of surgical isolation gown is divided into seven groups: S(160), M(165), L(170), XL(175), XXL(180), 3XL(185), 4XL(190).

The Surgical Isolation Gown is a single use, disposable medical device provided non-sterile.

The device description of the Surgical Isolation Gown is in accordance with the Guidance on Premarket Notification [510(k)] Submissions for Surgical Gowns and Surgical Drapes, issued on August 1, 1993 and ANSI/AAMI PB70:2012 Liquid Barrier Performance and Classification of Protective Apparel and Drapes Intended for Use in Health Care Facilities.

7. Summary of Comparison and Technological Characteristics

ItemsProposed DeviceK203415Predicate DeviceK190360Result
ProductCommon NameSurgical Isolation GownAMD Ritmed AssureWear™VersaGownDifference
ManufacturerYANBIAN PACIFIC TEXTILE CO.,LTDAMD Medicom Inc.-
510K NumberK203415K190306-
Product CodeFYCFYCSame
ClassificationClass II (21 CFR 878.4040)Class II (21 CFR 878.4040)Same
IntendedUse/Indicationfor UseThe Surgical Isolation Gown is intended toprotect patients and health care personnelfrom the transfer of microorganisms, bodyfluids and particulate material. Not intendedfor use in the operating room. In addition,the Surgical Isolation Gown meets therequirements of an AAMI Level 3 barrierprotection for an isolation gown perANSI/AAMI PB70:2012 Liquid BarrierPerformance and Classification of ProtectiveApparel Drapes Intended for Use in HealthCare Facilities (ANSI/AAMI PB70). TheSurgical Isolation Gown is a single use,disposable medical device provided non-sterile.AMD Ritmed AssureWear™ VersaGown isintended to be worn by healthcare personnelto protect health care patients and healthcare personnel from the transfer ofmicroorganisms, body fluids and particulatematerial. AssureWear™ VersaGown meets therequirements of an AAMI Level 3 barrierprotection for an isolation gown perANSI/AAMI PB70:2012 Liquid BarrierPerformance Classification of ProtectiveApparel Drapes Intended for Use in HealthCare Facilities (ANSI/AAMI PB70). AMDRitmed AssureWear™ VersaGown is a singleuse, non-sterile disposable medical deviceand not intended for use in operating rooms.Similar
MaterialsSMS PP + PE non-woven fabric materialPP SMS non-woven + PESame
ColorBlueBlueSame
DesignTape Neck Closure Belt TieElastic CuffsThumb loop Elastic cuffs Extended cuff(Thumb loop) Flexneck™ Tie (neck) Straightsleeve Inclined sleeve Blue belt tieReinforced seamsSimilar for alldesignsexcept forthe Flexneckpatenteddesign
OTC UseYesYesSame
Single UseYesYesSame
SterileNoNoSame
Level of barrierprotectionAAMI PB70Level 3Level 3Same
Physical and mechanical performance
Basic weightASTM D377660.7 g/m2 (1.79 oz/yd2) Seam betweenareas C&D: <0.1g39.97 ± 1.61 g/m2(1.17 oz/yd2 ± 0.05)Similar
Flammability16 CFR Part1610.7Class 1Class 1Same
Breakingstrength (MD)ASTM D5034Mean: 175.5 N18.17 ± 0.31 lbfSimilar
Breakingstrength (CD)ASTM D5034Mean: 118.0 N11.78 ± 0.33 lbfSimilar
Tearingstrength (MD)ASTM D5733-1999Mean: 63.5 N11.01 ± 0.64 lbf (ASTM D5587)Similar
Tearingstrength (CD)ASTM D5733-1999Mean: 34.5 N5.30 ± 0.35 lbf (ASTM D5587)Similar
Linting (ISO9073-10)Particulate size range(μm): 3 to 25A: Face: Measured value Coefficient oflingting log10 Min:2.2, Max:2.8,Mean: 2.5;Particulate size range(μm): 1 to 25Outside: Total linting >0.3:2.07;>0.5:1.97Index for Particulate Matter (IPM):1.50Similar
B: Face: Measured value Coefficient oflingting log10 Min:2.5, Max:2.9,Mean:2.74Inside: Totallinting >0.3:2.16;>0.5:2.00Index for Particulate Matter (IPM):1.35
Biocompatibility
CytotoxicityISO 10993-5:2009Non-CytotoxicNon-CytotoxicSame
Irritation ISO10993-10: 2010Non-SensitizingNon-SensitizingSame
SensitizationISO 10993-10: 2010Non-IrritatingNon-IrritatingSame

Table I - General Comparison

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*The difference in the materials and colors does not raise additional questions for safety and effectiveness. Performance testing including biocompatibility evaluation has been performed on the final finished device which includes all construction materials and color additives.

8. Summary of Non-clinical Tests Performed on the Proposed Device

The proposed device was tested and conformed to the following standards and the requirements stated in the Guidance for Industry and FDA Staff: Guidance on Premarket Notification [510(k)] Submissions for Surgical Gowns and Surgical Drapes on August, 1993 STANDARDS:

AAMI PB70:2012, Liquid Barrier Performance Classification of Protective Apparel and 0 Drapes Intended for Use in Health Care Facilities.

o ASTM D3776/D3776M-09 (2013), Test Methods for Mass Per Unit Area (Weight) of Woven Fabric.

ASTM D5034-09(2013), Standard Test Method for Breaking Strength and Elongation of ● Textile Fabrics (Grab Test).

ASTM D5587-2015, Standard Test Method for Tearing Strength of Fabrics by Trapezoid ● Procedure.

  • o (CPSC), Part 1610, Standard For The Flammability Of Clothing Textiles.
  • AATCC 42-2017, Water Resistance: Impact Penetration Test.
  • AATCC 127-2018, Water Resistance: Hydrostatic Pressure Test. ●
  • o ISO 10993- 1: 2009/(R)2013, Biological Evaluation of Medical Devices- Part 1: Evaluation and testing within a risk management process.

o ISO 10993-5: 2009 Biological Evaluation Of Medical Devices – Part 5: Tests For In Vitro Cytotoxicity.

ISO 10993-10: 2010 Biological Evaluation Of Medical Devices – Part 10: Tests For o Irritation And Skin Sensitization.

o ISO 9073-10:2004, Textiles-Test methods for nonwovens-Part 10: Lint and other particles generation in the dry state.

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Clinical Test 9.

There is no clinical study included in this submission.

10. Conclusion

The conclusions drawn from the non-clinical tests demonstrate that the proposed device Surgical Isolation Gown is as safe, as effective, and performs as well as or better than the predicate device, the AMD Ritmed AssureWear™ VersaGown (K190306) manufactured by AMD Medicom Inc.

§ 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.