K Number
K211827
Date Cleared
2021-09-23

(101 days)

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

The Level 3 Fluid Resistant Procedure/Surgical Mask (model:15604F, 1570F) 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 a single use, disposable device(s), provided non-sterile.

Device Description

The proposed device (model: 15604F) is blue color, and Flat Pleated type mask, utilizing Ear Loops way for wearing, and it has Nose clips design for fitting the face mask around the nose.

The proposed device (model: 15704F) is blue color, and Flat Pleated type mask, utilizing tie-on way for wearing, and it has Nose clips design for fitting the face mask around the nose.

The proposed devices are manufactured with three layers, the inner and outer layers are made of Non-woven Fabric(polypropylene), and the middle layer is made of Melton brown Fabric (Polypropylene). The 15604F model of proposed device, ear loops, is held in place over the users' mouth and nose by two elastic ear loops welded to the face mask. The elastic ear loops are made of polyurethane. The nose piece contained in the proposed device(s) is in the layers of face mask to allow the user to fit the face mask around their nose, which is made of Polypropylene coating iron. The 15704F model of proposed device, tie-on, is held in place over the users' mouth and nose by two tie-on bands welded to the face mask. The tie-on bands are made of non-woven Fabric (Polypropylene). The nose piece contained in the proposed device(s) is in the layers of face mask to allow the user to fit the face mask around their nose, which is made of Polypropylene coating iron.

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

AI/ML Overview

The provided text describes the acceptance criteria and performance data for a Level 3 Fluid Resistant Procedure/Surgical Mask (models 15604F, 1570F). This document is a 510(k) summary, which focuses on demonstrating substantial equivalence to a predicate device through non-clinical testing.

Here's the breakdown of the information requested:

1. Table of Acceptance Criteria and Reported Device Performance

Test MethodPurposeAcceptance CriteriaResult 1 (Model: 15604F)Result 2 (Model: 15704F)
Fluid Resistance Performance (ASTM F1862)Assess the performance of a mask to resistance to a synthetic blood preparation targeted toward the mask at a set pressure29 out of 32 pass at 160 mmHgPASS (32 out of 32 pass at 160 mmH2O for 3 non-consecutive lots)PASS (32 out of 32 pass at 160 mmH2O for 3 non-consecutive lots)
Particulate Filtration Efficiency (ASTM F2299)Assess the performance of a mask to penetration by sub-micron polystyrene latex particles of 0.1 micron≥ 98%PASS (Lot1: 99.4%, Lot2: 99.5%, Lot3: 99.4% for 3 non-consecutive lots)PASS (Lot1: 99.74%, Lot2: 99.85%, Lot3: 99.85% for 3 non-consecutive lots)
Bacterial Filtration Efficiency (ASTM F2101)Assess the performance of a mask to penetration by a prepared solution with known concentration of an indicator bacterial organism≥ 98%PASS (Lot1: 99.4%, Lot2: 99.4%, Lot3: 99.4% for 3 non-consecutive lots)PASS (Lot1: 99.7%, Lot2: 99.8%, Lot3: 99.7% for 3 non-consecutive lots)
Differential Pressure (Delta P) (EN 14683 Annex C)Assess the performance of a mask for resistance to air movement through the materials of the face of the mask< 6.0 mmH2O/cm²PASS (Lot1: 4.57 mmH2O/cm², Lot2: 4.72 mmH2O/cm², Lot3: 4.72 mmH2O/cm² for 3 non-consecutive lots)PASS (Lot1: 4.60 mmH2O/cm², Lot2: 4.70 mmH2O/cm², Lot3: 4.70 mmH2O/cm² for 3 non-consecutive lots)
Flammability (16 CFR 1610)Assess the resistance of a mask to ignitionClass 1PASS (Class 1 for 3 non-consecutive lots)PASS (Class 1 for 3 non-consecutive lots)
CytotoxicityAssess the potential risk of Cytotoxicity of mask materialNon-CytotoxicPASS (Under the conditions of the study, the device is non-cytotoxic.)PASS (Under the conditions of the study, the device is non-cytotoxic.)
IrritationAssess the potential risk of Irritation of mask materialNon-IrritatingPASS (Under the conditions of the study, the device is non-irritating.)PASS (Under the conditions of the study, the device is non-irritating.)
SensitizationAssess the potential risk of Sensitization of mask materialNon-SensitizingPASS (Under the conditions of the study, the device is non-sensitizing.)PASS (Under the conditions of the study, the device is non-sensitizing.)

2. Sample size used for the test set and the data provenance

  • Sample Size:
    • For Fluid Resistance, Particulate Filtration Efficiency, Bacterial Filtration Efficiency, Differential Pressure, and Flammability tests, a sample size of 32 per lot was used, across 3 non-consecutive lots.
    • For Biocompatibility tests (Cytotoxicity, Irritation, Sensitization), the sample size is not explicitly stated as a number but the results indicate "Under the conditions of the study."
  • Data Provenance: The tests were conducted to verify that the proposed device met design specifications and was similar to the predicate device. The document does not specify the country of origin of the test data or explicitly state whether the studies were retrospective or prospective, but these are standard laboratory tests conducted to evaluate product performance. Given the context of a 510(k) submission, these are typically prospective tests conducted on manufactured samples.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

This information is not applicable to this type of device and study. The "ground truth" for the performance of a surgical mask is established by validated standardized testing methods (e.g., ASTM, EN, ISO standards), not by expert consensus in a medical imaging or diagnostic sense. The results are quantitative measurements against predefined criteria.

4. Adjudication method for the test set

This information is not applicable. As these are objective, quantitative laboratory tests based on recognized standards, an adjudication method for reconciling expert opinions is not relevant. The results are measured values compared against specific acceptance criteria.

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

No, an MRMC comparative effectiveness study was not done. This type of study is relevant for diagnostic devices (e.g., AI for medical imaging) where human interpretation is involved. For a surgical mask, the performance is evaluated through physical and biological laboratory tests, not human interpretation of cases.

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

Not Applicable. This device is a physical medical product (a surgical mask), not an algorithm or AI system. Therefore, the concept of "standalone algorithm performance" does not apply.

7. The type of ground truth used

The "ground truth" for the device's performance is established by objective measurements against established industry standards and regulatory requirements. These include:

  • ASTM F1862 (Fluid Resistance)
  • ASTM F2299 (Particulate Filtration Efficiency)
  • ASTM F2101 (Bacterial Filtration Efficiency)
  • EN 14683 Annex C (Differential Pressure)
  • 16 CFR 1610 (Flammability)
  • ISO 10993 (Biocompatibility - Cytotoxicity, Irritation, Sensitization)

8. The sample size for the training set

Not Applicable. This is not a machine learning or AI device that requires a training set. The device is a physical product subject to standardized performance testing.

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

Not Applicable. As there is no training set for this type of device, the concept of establishing ground truth for a training set does not apply.

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Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, with the letters "FDA" in a blue square. Next to that is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

September 23, 2021

Zhejiang Lanhine Medical Products LTD % Ivy Wang Consultant Shanghai Sungo Management Consulting Company Limited 14th Floor, 1500# Central Avenue Shanghai, Shanghai 200122 China

Re: K211827

Trade/Device Name: Level 3 Fluid Resistant Procedure/Surgical Mask (model:15604F, 1570F) Regulation Number: 21 CFR 878.4040 Regulation Name: Surgical Apparel Regulatory Class: Class II Product Code: FXX Dated: August 18, 2021 Received: August 23, 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.

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

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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,

Clarence W. Murray, III, PhD Assistant Director DHT4B: Division of Infection Control and Plastic Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K211827

Device Name

Level 3 Fluid Resistant Procedure/Surgical Mask (model:15604F, 1570F)

Indications for Use (Describe)

The Level 3 Fluid Resistant Procedure/Surgical Mask (model:15604F, 1570F) 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 a single use, disposable device(s), provided non-sterile.

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

Research that is Part of CER-221a, Category B
Service-Type Construction (40 CFR 280, Subpart C)

__ Prescription Use (Part 21 CFR 801 Subpart D)

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

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510(K) Summary K211827

A. Applicant:

Name: Zhejiang Lanhine Medical Products LTD.

Address: 1989 Cidong Road, Cidongbinhai District, 315300 Cixi City, Zhejiang Province, China Contact Person: Jerry Gu Tel: +86 0574-63970705 Mail: Jf.gu(@lanhine.com

Submission Correspondent: Primary contact: Ivy Wang Shanghai SUNGO Management Consulting Co., Ltd. 14th floor, 1500# Century Ave., Shanghai 200122, China Tel: +86-21-58817802 Email: haiyu.wang@sungoglobal.com Secondary contact: Mr. Raymond Luo 14th floor, 1500# Century Ave., Shanghai 200122, China Tel: +86-21-68828050

Email: fda.sungo@@gmail.com

B. Device:

Trade Name: Level 3 Fluid Resistant Procedure/Surgical Mask Common Name: Surgical Face Mask Model(s): 15604F, 15704F

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

C. Predicate device:

510KDevice nameASTM F2100 levelManufacturer
K200923Single-use Surgical MasksLevel 3BYD Precision Manufacturer Co. Ltd

D. Indications for use of the device:

The Level 3 Fluid Resistant Procedure/Surgical Masks (model: 15604F) 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 a single use, disposable device(s), provided non-sterile.

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Zhejiang Lanhine Medical Products LTD 1989 Cidong Road, Cidongbinhai District, 315300 Cixi City, Zhejiang Province, China

E. Device Description:

The proposed device (model: 15604F) is blue color, and Flat Pleated type mask, utilizing Ear Loops way for wearing, and it has Nose clips design for fitting the face mask around the nose.

The proposed device (model: 15704F) is blue color, and Flat Pleated type mask, utilizing tie-on way for wearing, and it has Nose clips design for fitting the face mask around the nose.

The proposed devices are manufactured with three layers, the inner and outer layers are made of Non-woven Fabric(polypropylene), and the middle layer is made of Melton brown Fabric (Polypropylene). The 15604F model of proposed device, ear loops, is held in place over the users' mouth and nose by two elastic ear loops welded to the face mask. The elastic ear loops are made of polyurethane. The nose piece contained in the proposed device(s) is in the layers of face mask to allow the user to fit the face mask around their nose, which is made of Polypropylene coating iron. The 15704F model of proposed device, tie-on, is held in place over the users' mouth and nose by two tie-on bands welded to the face mask. The tie-on bands are made of non-woven Fabric (Polypropylene). The nose piece contained in the proposed device(s) is in the layers of face mask to allow the user to fit the face mask around their nose, which is made of Polypropylene coating iron.

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

DeviceProposed DevicePredicate Device 1Comparison
ManufacturerZhejiang Lanhine MedicalProducts LTD.BYD PrecisionManufacturer Co. Ltd-
510K numberK211827K200923-
ClassificationClass II Device, FXX (21CFR878.4040)Class II Device, FXX (21CFR878.4040)Same
Indications for useThe Level 3 FluidResistantProcedure/Surgical Mask(model: 15604F, 15704F)are intended to be worn toprotect both the patient andhealthcare personnel fromtransfer of microorganisms,body fluids and particulatematerial. These face masksare intended for use ininfection control practicesto reduce the potentialexposure to blood and bodyfluids.This a single use,The Single-use SurgicalMasks (Model: FE2311)are intended to be worn toprotect both the patient andhealthcare personnel fromtransfer ofmicroorganisms, bodyfluids and particulatematerial. These face masksare intended for use ininfection control practicesto reduce the potentialexposure to blood andbody fluids.This is a single use,disposable device(s),Similar

F. Comparison with predicate device/

Table 1 General Comparison

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disposable device(s),provided non-sterile.provided non-sterile.
Ear loop modeland tie-on modelEar Loops, Tie-On, FlatPleated, 3 layersEar Loops, Flat Pleated, 3layersAnalysis
MaterialOuterlayerNon-woven Fabric(Polypropylene)Spun-bond polypropyleneSame
MiddlelayerMelton brown Fabric(Polypropylene)Melt blownpolypropylene filterSame
InnerlayerNon-woven Fabric(Polypropylene)Spun-bond polypropyleneSame
Nose clipPolypropylenecoatingironMalleable aluminum wireAnalysis
Tie-onbandsNon-woven Fabric(Polypropylene)/--
Ear loopsPolyurethanePolyesterAnalysis
ColorBlueBlueSame
Dimension17.5 cm +/- 0.5 cm17.5 cm +/- 0.4 cmAnalysis
Dimension9.5 cm +/- 0.5 cm9.5 cm +/- 0.4 cmAnalysis
OTC useYesYesSame
SterilityNon-SterileNon-SterileSame
UseSingle Use, DisposableSingle Use, DisposableSame
ASTM F2100 levelLevel 3Level 3Same
BiocompatibilityISO10993ISO10993Same

G. Non-Clinical Test Conclusion

Non-clinical tests were conducted to verify that the proposed device met all design specifications as was similar 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:

  • A 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

  • A ASTM F1862, Standard Test Method for Resistance of Medical Face Masks To Penetration by Synthetic Blood (Horizontal Projection of Fixed Volume At AKnown Velocity);
  • EN 14683, Medical Face Masks-Requirements and Test Methods;

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

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  • A ASTM F2299, Stand test method for determining the initial efficiency of materials used in medical face masks to penetration by particulates using latex spheres;
  • 16 CFR 1610, Standard for the Flammability of clothing textiles;

Table 2 - Performance Testing

Test MethodPurposeAcceptanceCriteriaResult 1Proposed device(model:15604F)Result 2Proposed device(model:15704F)
FluidResistancePerformanceASTM F1862Assess the performanceof a mask to resistance toa synthetic bloodpreparation targetedtoward the mask at a setpressure29 out of 32 passat 160 mmHgPASS3 non-consecutive lotstested, using a samplesize of 32/lot.32 out of 32 pass at 160mmH2OPASS3 non-consecutive lotstested, using a samplesize of 32/lot.32 out of 32 pass at 160mmH2O
ParticulateFiltrationEfficiency ASTMF2299Assess the performance ofa mask to penetration bysub-micron polystyrenelatex particles of 0.1 micron≥ 98%PASS3 non-consecutive lotstested, using a samplesize of 32/lot.Lot1: 99.4%Lot2: 99.5%Lot3: 99.4%PASS3 non-consecutive lotstested, using a samplesize of 32/lot.Lot1: 99.74%Lot2: 99.85%Lot3: 99.85%
BacterialFiltrationEfficiencyASTM F2101Assess the performance ofa mask to penetration by aprepared solution withknown concentration ofan indicator bacterialorganism≥ 98%PASS3 non-consecutive lotstested, using a samplesize of 32/lot.Lot1: 99.4%Lot2: 99.4%Lot3: 99.4%PASS3 non-consecutive lotstested, using a samplesize of 32/lot.Lot1: 99.7%Lot2: 99.8%Lot3: 99.7%
DifferentialPressure (DeltaP) EN 14683Annex CAssess the performance ofa mask for resistance toair movement through thematerials of the face ofthe mask< 6.0mmH2O/cm²PASS3 non-consecutive lotstested, using a samplesize of 32/lot.Lot1: 4.57 mmH2O/cm²Lot2: 4.72 mmH2O/cm²Lot3: 4.72 mmH2O/cm²PASS3 non-consecutive lotstested, using a samplesize of 32/lot.Lot1: 4.60 mmH2O/cm²Lot2: 4.70 mmH2O/cm²Lot3: 4.70 mmH2O/cm²
Flammability 16CFR 1610Assess the resistance of amask to ignitionClass 1PASS3 non-consecutive lotstested, using a samplesize of 32/lot.Class 1PASS3 non-consecutive lotstested, using a samplesize of 32/lot.Class 1

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Table 3 Biocompatibility Testing
ItemPurposeAcceptance CriteriaResult
CytotoxicityAssess the potential risk ofCytotoxicity of mask materialNon-CytotoxicPASSUnder the conditions of the study,the device is non-cytotoxic.
IrritationAssess the potential risk ofIrritation of mask materialNon-IrritatingPASSUnder the conditions of the study, thedevice is non-irritating.
SensitizationAssess the potential risk ofSensitization of mask materialNon-SensitizingPASSUnder the conditions of the study, thedevice is non-sensitizing

H. Clinical Test Conclusion

No clinical study is included in this submission.

I. Conclusion

The conclusion drawn from the nonclinical tests demonstrates that the subject device in 510(K) submission K211827, the Level 3 Fluid Resistant Procedure/Surgical Mask(model:15604F, 1570F) is as safe, as effective, and performs as well as or better than the legally marketed predicate device cleared under K200923.

§ 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.