K Number
K210342
Device Name
BioShield- ERCP Biopsy Valve, BioShield Irrigator - Extension Tubing, BioShield Irrigating Adaptor
Manufacturer
Date Cleared
2021-09-03

(210 days)

Product Code
Regulation Number
876.1500
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The single-use BioShield biopsy valve is used to cover the biopsy/suction channel of gastrointestinal endoscopes. It provides access for endoscopic device passage and exchange, helps maintain insufflation, minimizes leakage of biomaterial from the biopsy port throughout the endoscopic procedure and provides access for irrigation. The BioShield Irrigator - extension tubing is intended to provide irrigation fluids, such as sterile water, during gastrointestinal endoscopic procedures when used in conjunction with the BioShield Irrigator. The BioShield Irrigating Adaptor is intended to be used with the BioShield Biopsy Valve to provide access for irrigation.
Device Description
The BioShield biopsy valve is a single-use disposable cap that is used to cover the biopsy/suction channel of endoscopes during endoscopic procedures and other procedures. It provides access to the endoscope's working channel, minimizes leakage of biomaterial and other fluids during insufflation and instrument exchange and allows for irrigation. The device consists of a valve body and a cap. The device is made from thermoplastic elastomer. There are a total of 10 versions of the BioShield biopsy valve. All 10 versions of the BioShield Biopsy valve are subject to the major change of removing the skirt that aided in maintaining insufflation in the predicate device and two of these 10 versions have had an irrigation line added. Seven versions of the biopsy valve that are compatible with Olympus and Fujinon endoscopes and three versions of the valve that are compatible with Pentax endoscopes. Also, of these 10 versions, there are two versions that have an irrigation line to provide another option to the user to irrigate. All valves, with the exception of one version, are supplied non-sterile. There are two accessories provided with the BioShield biopsy valve. These devices were not previously cleared under the 510(k) process. Their product code is OCX. They are the BioShield Irrigator and the BioShield Irrigator Extension Tubing. The BioShield Irrigator consists of a luer connection attached to a stainless-steel tip. The Bioshield Irrigator is used for intraprocedural gastrointestinal endoscopic irrigation when attached to a luer-lock or slip-tip syringe directly through the BioShield biopsy valve. The BioShield Irrigator Extension Tubing is a 180 cm long piece of irrigation tubing that has connectors on both ends. The tubing can be connected to a BioShield Irrigator biopsy valve on one end and to an irrigation system (irrigation tubing connected to an irrigation source used with an auxiliary water pump) on the other end in order to provide hands-free foot pedal irrigation control. Both of these irrigation accessories are provided non-sterile.
More Information

No
The device description and intended use focus on mechanical components and fluid management during endoscopic procedures, with no mention of AI or ML capabilities.

No.
The device components are used to cover an endoscope channel, provide access for device passage, maintain insufflation, minimize leakage, and provide irrigation during endoscopic procedures, rather than directly treating a condition or disease.

No

The device is described as a biopsy valve and accessories for endoscopes, used for access, insufflation, leakage minimization, and irrigation during gastrointestinal procedures. Its function is descriptive and procedural assistance, not diagnostic analysis or information gathering.

No

The device description clearly outlines physical components made of thermoplastic elastomer and stainless steel, and the performance studies focus on physical properties like retention force and leakage. There is no mention of software as a component or function.

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

Here's why:

  • Intended Use: The intended use clearly describes the device's function as an accessory for gastrointestinal endoscopes, facilitating access, maintaining insufflation, minimizing leakage, and providing irrigation during endoscopic procedures. This is a procedural aid, not a device used to examine specimens derived from the human body to provide information for diagnostic purposes.
  • Device Description: The description reinforces the device's role as a physical component used during an endoscopic procedure. It covers the biopsy/suction channel and provides access for instruments and irrigation.
  • Lack of Diagnostic Function: There is no mention of the device being used to analyze biological samples, detect markers, or provide any information for diagnosis. Its function is purely mechanical and procedural.
  • Performance Studies: The performance studies focus on physical characteristics and functionality (retention force, leakage, device exchange, backflow, irrigation flow rate), not on diagnostic accuracy or analytical performance related to biological samples.

IVD devices are specifically designed to perform tests on samples taken from the human body (like blood, urine, tissue) to provide information for diagnosis, monitoring, or screening. This device does not fit that description.

N/A

Intended Use / Indications for Use

The single-use BioShield biopsy valve is used to cover the biopsy/suction channel of gastrointestinal endoscopes. It provides access for endoscopic device passage and exchange, helps maintain insufflation, minimizes leakage of biomaterial from the biopsy port throughout the endoscopic procedure and provides access for irrigation.

The BioShield Irrigator - extension tubing is intended to provide irrigation fluids, such as sterile water, during gastrointestinal endoscopic procedures when used in conjunction with the BioShield Irrieator.

The BioShield Irrigating Adaptor is intended to be used with the BioShield Biopsy Valve to provide access for irrigation.

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

ODC, OCX

Device Description

The BioShield biopsy valve is a single-use disposable cap that is used to cover the biopsy/suction channel of endoscopes during endoscopic procedures and other procedures. It provides access to the endoscope's working channel, minimizes leakage of biomaterial and other fluids during insufflation and instrument exchange and allows for irrigation. The device consists of a valve body and a cap. The device is made from thermoplastic elastomer. There are a total of 10 versions of the BioShield biopsy valve. All 10 versions of the BioShield Biopsy valve are subject to the major change of removing the skirt that aided in maintaining insufflation in the predicate device and two of these 10 versions have had an irrigation line added. Seven versions of the biopsy valve that are compatible with Olympus and Fujinon endoscopes and three versions of the valve that are compatible with Pentax endoscopes. Also, of these 10 versions, there are two versions that have an irrigation line to provide another option to the user to irrigate. All valves, with the exception of one version, are supplied non-sterile.

There are two accessories provided with the BioShield biopsy valve. These devices were not previously cleared under the 510(k) process. Their product code is OCX. They are the BioShield Irrigator and the BioShield Irrigator Extension Tubing. The BioShield Irrigator consists of a luer connection attached to a stainless-steel tip. The Bioshield Irrigator is used for intraprocedural gastrointestinal endoscopic irrigation when attached to a luer-lock or slip-tip syringe directly through the BioShield biopsy valve. The BioShield Irrigator Extension Tubing is a 180 cm long piece of irrigation tubing that has connectors on both ends. The tubing can be connected to a BioShield Irrigator biopsy valve on one end and to an irrigation system (irrigation tubing connected to an irrigation source used with an auxiliary water pump) on the other end in order to provide hands-free foot pedal irrigation control. Both of these irrigation accessories are provided non-sterile.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

gastrointestinal

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)

Non-clinical performance testing was conducted.
Study type: Retention Force Testing, Leakage Testing, Device Exchange Testing, Backflow testing (through check valve attached to irrigation line), Irrigation Testing using the BioShield Irrigating Adaptor, Irrigation Testing Using the Irrigation Extension Tubing (Flow Rate Testing).
Key results: All tests passed their acceptance criteria.

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

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K070420, K103239, K142068

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

K210981

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 876.1500 Endoscope and accessories.

(a)
Identification. An endoscope and accessories is a device used to provide access, illumination, and allow observation or manipulation of body cavities, hollow organs, and canals. The device consists of various rigid or flexible instruments that are inserted into body spaces and may include an optical system for conveying an image to the user's eye and their accessories may assist in gaining access or increase the versatility and augment the capabilities of the devices. Examples of devices that are within this generic type of device include cleaning accessories for endoscopes, photographic accessories for endoscopes, nonpowered anoscopes, binolcular attachments for endoscopes, pocket battery boxes, flexible or rigid choledochoscopes, colonoscopes, diagnostic cystoscopes, cystourethroscopes, enteroscopes, esophagogastroduodenoscopes, rigid esophagoscopes, fiberoptic illuminators for endoscopes, incandescent endoscope lamps, biliary pancreatoscopes, proctoscopes, resectoscopes, nephroscopes, sigmoidoscopes, ureteroscopes, urethroscopes, endomagnetic retrievers, cytology brushes for endoscopes, and lubricating jelly for transurethral surgical instruments. This section does not apply to endoscopes that have specialized uses in other medical specialty areas and that are covered by classification regulations in other parts of the device classification regulations.(b)
Classification —(1)Class II (special controls). The device, when it is an endoscope disinfectant basin, which consists solely of a container that holds disinfectant and endoscopes and accessories; an endoscopic magnetic retriever intended for single use; sterile scissors for cystoscope intended for single use; a disposable, non-powered endoscopic grasping/cutting instrument intended for single use; a diagnostic incandescent light source; a fiberoptic photographic light source; a routine fiberoptic light source; an endoscopic sponge carrier; a xenon arc endoscope light source; an endoscope transformer; an LED light source; or a gastroenterology-urology endoscopic guidewire, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.(2) Class I for the photographic accessories for endoscope, miscellaneous bulb adapter for endoscope, binocular attachment for endoscope, eyepiece attachment for prescription lens, teaching attachment, inflation bulb, measuring device for panendoscope, photographic equipment for physiologic function monitor, special lens instrument for endoscope, smoke removal tube, rechargeable battery box, pocket battery box, bite block for endoscope, and cleaning brush for endoscope. The devices subject to this paragraph (b)(2) are exempt from the premarket notification procedures in subpart E of part 807of this chapter, subject to the limitations in § 876.9.

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September 3, 2021

STERIS Corporation Carroll Martin Regulatory Affairs Director 5976 Heislev Rd Mentor, OH 44060

Re: K210342

Trade/Device Name: BioShield- ERCP Biopsy Valve, BioShield Irrigator -Extension Tubing, BioShield Irrigating Adaptor Regulation Number: 21 CFR 876.1500 Regulation Name: Endoscope and accessories Regulatory Class: Class II Product Code: ODC, OCX Dated: August 2, 2021 Received: August 4, 2021

Dear Carroll Martin:

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 control's 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

1

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,

Shanil P. Haugen, Ph.D. Assistant Director DHT3A: Division of Renal, Gastrointestinal, Obesity and Transplant Devices OHT3: Office of GastroRenal, ObGyn, General Hospital and Urology 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) K210342

Device Name BioShield Biopsy Valve BioShield Irrigator - Extension Tubing BioShield Irrigating Adaptor

Indications for Use (Describe)

The single-use BioShield biopsy valve is used to cover the biopsy/suction channel of gastrointestinal endoscopes. It provides access for endoscopic device passage and exchange, helps maintain insufflation, minimizes leakage of biomaterial from the biopsy port throughout the endoscopic procedure and provides access for irrigation.

The BioShield Irrigator - extension tubing is intended to provide irrigation fluids, such as sterile water, during gastrointestinal endoscopic procedures when used in conjunction with the BioShield Irrieator.

The BioShield Irrigating Adaptor is intended to be used with the BioShield Biopsy Valve to provide access for irrigation.

Type of Use (Select one or both, as applicable)X Prescription Use (Part 21 CFR 801 Subpart D)

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

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Image /page/3/Picture/0 description: The image shows the first page of a document, labeled "K210342 Page 1 of 8". The page features the STERIS logo in large, bold, sans-serif font. Below the company name is an image of several horizontal wavy lines in blue, resembling water.

510(k) Summary for the BioShield Biopsy Valve

STERIS Corporation 5960 Heisley Road Mentor, OH 44060

Contact:Carroll Martin
Regulatory Affairs Director
Tel: 440-358-6259
Email: Carroll_Martin@steris.com

March 15, 2021 Submission Date:

4

1. Device Name

Trade Name:BioShield Biopsy Valve
BioShield Irrigator – Extension Tubing
BioShield Irrigating Adaptor
Device Class:Class II
Regulation Name:Endoscope and Accessories
Common/usual Name:Biopsy Valve
Regulation Number:21 CFR 876.1500
Product Code:OCX, ODC

2. Predicate Device

BioShield - ERCP Biopsy Valve, K070420 Irrigation System, K103239 Medovations BullDog Biopsy Valve Irrigating Adaptor Accessory, K142068

3. Device Description

The BioShield biopsy valve is a single-use disposable cap that is used to cover the biopsy/suction channel of endoscopes during endoscopic procedures and other procedures. It provides access to the endoscope's working channel, minimizes leakage of biomaterial and other fluids during insufflation and instrument exchange and allows for irrigation. The device consists of a valve body and a cap. The device is made from thermoplastic elastomer. There are a total of 10 versions of the BioShield biopsy valve. All 10 versions of the BioShield Biopsy valve are subject to the major change of removing the skirt that aided in maintaining insufflation in the predicate device and two of these 10 versions have had an irrigation line added. Seven versions of the biopsy valve that are compatible with Olympus and Fujinon endoscopes and three versions of the valve that are compatible with Pentax endoscopes. Also, of these 10 versions, there are two versions that have an irrigation line to provide another option to the user to irrigate. All valves, with the exception of one version, are supplied non-sterile.

There are two accessories provided with the BioShield biopsy valve. These devices were not previously cleared under the 510(k) process. Their product code is OCX. They are the BioShield Irrigator and the BioShield Irrigator Extension Tubing. The BioShield Irrigator consists of a luer connection attached to a stainless-steel tip. The Bioshield Irrigator is used for intraprocedural gastrointestinal endoscopic irrigation when attached to a luer-lock or slip-tip syringe directly through the BioShield biopsy valve. The BioShield Irrigator Extension Tubing is a 180 cm long piece of irrigation tubing that has connectors on both ends. The tubing can be connected to a BioShield Irrigator biopsy valve on one end and to an irrigation system (irrigation tubing connected to an irrigation source used with an auxiliary water pump) on the other end in order to provide hands-free foot pedal irrigation control. Both of these irrigation accessories are provided non-sterile.

5

Product NamePart NumberSterility Status
BioShield ">– biopsy valve00711124Non-sterile
BioShield ">– biopsy valve00711125Non-sterile
BioShield ">– biopsy valve00711126Non-sterile
BioShield ">– biopsy valve00711127Non-sterile
BioShield ">– biopsy valve-sterile00711128Sterile
BioShield ">– biopsy valve00711129Non-sterile
BioShield Irrigating Adaptor00711131Non-sterile
BioShield ">– irrigator00711133Non-sterile
BioShield Irrigator ">– extension
tubing (180 cm)00711134Non-sterile
BioShield ">– biopsy valve00711135Non-sterile
BioShield ">– biopsy valve00711136Non-sterile
BioShield ">– irrigator00711137Non-sterile

BioShield Biopsy Valves and Accessories

Indications for Use 4.

The single-use BioShield biopsy valve is used to cover the opening to the biopsy/suction channel of gastrointestinal endoscopes. It provides access for endoscopic device passage and exchange, helps maintain insufflation, minimizes leakage of biomaterial from the biopsy port throughout the endoscopic procedure and provides access for irrigation.

The BioShield Irrigator - extension tubing is intended to provide irrigation via irrigation fluids, such as sterile water, during gastrointestinal endoscopic procedures when used in conjunction with the BioShield Irrigator.

The BioShield Biopsy Valve Irrigating Adaptor Accessory is intended to be used with the biopsy valve to provide access for irrigation.

ട്. Technological Characteristics Comparison Table

A comparison of technical characteristics between the proposed BioShield Biopsy Valve and its predicate can be found in Table 1. A comparison of technical characteristics between the proposed accessory, the BioShield Irrigation Extension Tubing and its predicate can be found in Table 2. A comparison of technical characteristics between the proposed accessory, the BioShield Irrigating Adaptor and its predicate can be found in Table 3.

6

| Features | BioShield - ERCP Biopsy
Valve
Predicate Device K070420 | BioShield Biopsy Device
(Proposed Device) | Comparison |
|----------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Intended Use | The single-use BioShield -
ERCP biopsy valve is used to
cover the opening to the
biopsy/suction channel of
Olympus and G5 and newer
Fujinon gastrointestinal
endoscopes. It provides access
for endoscopic device passage
and exchange, helps maintain
sufflation, minimizes leakage of
biomaterial from the biopsy port
throughout the endoscopic
procedure and provides access
for irrigation. | The single-use BioShield
biopsy valve is used to cover
the opening to the
biopsy/suction channel of
gastrointestinal endoscopes.
It provides access for
endoscopic device passage
and exchange, helps maintain
insufflation, minimizes
leakage of biomaterial from
the biopsy port throughout
the endoscopic procedure and
provides access for irrigation. | Similar. This change
does not impact how
the device is used. The
modified device has the
same fundamental
technology as the
predicate. The terms
"sufflation" and
"insufflation have the
same meaning. |
| Construction | Valve Body
Valve Body Insert
Valve Cap | Valve Body
Valve Cap
Irrigation Line | Similar. The valve
body insert helped the
valve maintain
insufflation and
mitigate leakage.
Testing has shown that
removal of the insert
did not affect these
features of the device.
The addition of the
irrigation line gives the
user another option to
irrigate through the
valve. |
| Sterile/Non-
sterile | Sterile and Non-sterile | Sterile and Non-sterile (only
the 00711128 valve is supplied
sterile) | Identical |
| Sterilization
Method | Ethylene Oxide | Ethylene Oxide | Identical |
| Sterilization
Assurance Level | 10-6 | 10-6 | Identical |
| Usage | Single use | Single use | Identical |
| Materials (by
component) | Valve Body and valve cap
Thermoplastic elastomer | Valve Body and valve cap:
Thermoplastic elastomer
Irrigation Line: Polyvinyl
chloride
Check valve
Housing - Polycarbonate
Diaphragm: Silicone
Irrigation line: Polyvinyl
chloride | The same material for
the valve. Different
materials for the
components. Testing of
the components shows
no effect on safety or
effectiveness of the
proposed valves
themselves. |
| Target Population | Patients undergoing an
endoscopic procedure | Patients undergoing an
endoscopic procedure | Identical |

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| Energy

Used/DeliveredNoneNoneIdentical
Method of
ApplicationManualManualIdentical
Compatible
EndoscopesOlympus and G5 and newer
Fujinon gastrointestinal
endoscopesPentax, Olympus and G5 and
newer Fujinon
gastrointestinal endoscopesSimilar. The addition of
using the valve on
Pentax endoscopes is
similar to the predicate
in that the fundamental
technology and the use
of the valve on Pentax
endoscopes is identical
to the predicate.
Number of
Devices/Box2550, 100, 200 depending on
SKUSimilar. This change is
similar to the predicate
in that the packaging of
the device has not
changed, only the
number of devices in a
box.
Irrigation
AccessoriesNoneThe BioShield Irrigating
Adaptor consisting of a
polypropylene luer lock
connected to a stainless-steel
tip.
The BioShield Irrigation
Extension tubing consists of a
180cm piece of polyvinyl
chloride tubing with a female
connector made of
polycarbonate on one end and
a male connector made of
ABS plastic on the other endThis is different than
the predicate device in
that these accessories
were not offered for
use. But testing has
shown that use of these
accessories does not
impact the safety or
effectiveness of the
BioShield Biopsy
valves.

8

FeaturesUS Endoscopy'sBioShield Irrigator -Comparison
Irrigation System,
K103239extension tubing,
K210342
Intended UseThe Irrigation System
(tubing and accessories to
accommodate various
endoscopes and irrigation
pumps) is intended to
provide irrigation via
irrigation fluids, such as
sterile water, during
gastrointestinal endoscopic
procedures when used in
conjunction with an
irrigation pump or
electrosurgical unit.The BioShield Irrigator
  • extension tubing is
    intended to provide
    irrigation via irrigation
    fluids, such as sterile
    water, during
    gastrointestinal
    endoscopic procedures
    when used in
    conjunction with the
    BioShield Irrigator. | Similar. The BioShield
    Irrigator - extension
    tubing is not connected
    directly to an irrigation
    pump or electrosurgical
    unit but can be
    connected to irrigation
    tubing providing the
    same exact purpose of
    US Endoscopy's
    Irrigation System, that
    is to provide irrigation
    fluids to the endoscope.
    Whereas the intended
    use of the two devices
    is not exactly the same,
    the differences do not
    alter the intended
    therapeutic effect of the
    device. The
    fundamental technology
    of attaching to a water
    source and providing
    irrigation fluids to an
    endoscope are exactly
    the same. |
    | Construction | Irrigation Tubing Set:
    Consists of 110 in
    (279.4cm) irrigation tubing
    that has a connector on one
    end (to connect to the
    scope connector) and a
    vented bottle cap on the
    other end that goes into a
    water bottle.
    Scope Connector:
    Consists of two
    connectors, one on each
    end and a check valve in
    the middle. | BioShield Irrigator -
    extension tubing:
    Consists of a 70.9 in
    (180cm) piece of
    irrigation tubing with
    connectors on both ends
    that allow for connection
    to the BioShield Biopsy
    valve with the built-in
    irrigation line and to a
    water source. | Similar. Both devices
    have irrigation tubing as
    a component. This
    irrigation tubing serves
    the same purpose; to
    connect a water source
    to the endoscope for the
    purpose of providing
    irrigation fluids. The
    US Endoscopy
    Irrigation system has a
    scope connector with a
    check valve to protect
    against backflow. This
    check valve connects
    directly to the
    endoscope. The
    BioShield Irrigator -
    extension tubing does
    not have a check valve,
    it is connected to the |
    | | | | BioShield Biopsy valve
    with irrigation line that
    does have a check
    valve. Both devices
    connect to an irrigation
    source and to the
    endoscope. |
    | Materials of
    Construction | Irrigation tubing: PVC
    Cap: PVC
    Scope Connector:
    Polyetherimide | BioShield Irrigator –
    extension tubing: PVC
    Male connector: ABS
    plastic
    Female connector:
    polycarbonate | Similar. The irrigation
    tubing portion of both
    devices are made of
    PVC. |
    | Sterility | Sterile | Non-sterile | Different. The Pure Vu
    System, K210981 is a
    similar reference device
    that is provided in a
    non-sterile state. |

Table 2. BioShield Irrigator Extension Tubing Technological Characteristics Comparison Table

9

Table 3. BioShield Biopsy Valve Irrigating Adaptor Technological Characteristics Comparison Table

| Features | Medovations BullDog
Biopsy Valve Irrigating
Adaptor Accessory,
K142068 | BioShield Biopsy Valve
Irrigating Adaptor
Accessory, K210342 | Comparison |
|--------------|-----------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------|------------|
| Intended Use | The BullDog Biopsy Valve
Irrigating Adaptor
Accessory is intended to
be used with the biopsy
valve to provide access for
irrigation. | The BioShield Biopsy
Valve Irrigating Adaptor
Accessory is intended to
be used with the biopsy
valve to provide access
for irrigation. | Same |
| Construction | Hollow metal tube with
standard plastic luer lock
connector | Hollow metal tube with
standard plastic luer lock
connector | Same |

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Summarv of Non-Clinical Performance Testing 6.

TestingAcceptance CriteriaResults
Retention Force
TestingThe retention force of the BioShield
Biopsy valves must be equal to or greater
than the predicate device as documented in
K070420 (3.2 lbs.).Pass
Leakage TestingThe BioShield biopsy valves must not
spray or experience geyser type leaks
while the endoscope is pressurizedPass
Device Exchange
TestingThe BioShield Biopsy valves should allow
device passage and should not become
detached during instrument usage and
exchange.Pass
Backflow testing
(through check valve
attached to irrigation
line)The BioShield Biopsy Valve Irrigator
Olympus/Fuji and Pentax must not leak
through the check valve located on the
irrigation line while the endoscope is
pressurized.Pass
Irrigation Testing
using the BioShield
Irrigating AdaptorDuring irrigation, the biopsy valve should
not experience spraying geyser type leaks.Pass
Irrigation Testing
Using the Irrigation
Extension Tubing
(Flow Rate Testing)The average amount of water displaced
when using the BioShield Irrigation
Extension tubing must be equal to ± 15%
of the average amount of water displaced
when the BioShield Irrigation tubing was
not used. Also, water flow should not
occur when the pinch clamp is closed.Pass

Non-clinical testing consisted of the following:

7. Conclusion

Based on the intended use, technological characteristics and non-clinical performance data (bench and simulated use testing), the subject device has shown to be substantially equivalent to the predicate and having met the acceptance criteria based on its indications for use.