K Number
K212198
Device Name
Tyvek(R) Roll with CI for STERLINKTM Sterilizer
Manufacturer
Date Cleared
2021-10-22

(100 days)

Product Code
Regulation Number
880.6850
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Tyvek® Roll with CI for STERLINK™ Sterilizer, when used in CHAMBER mode, is intended to provide health care workers with an effective method to enclose devices intended for sterilization in the STERLINK™ sterilizer. The device is intended to allow sterilization of enclosed devices and also to maintain sterility of the enclosed devices until used up to 1 month post sterilization. The maximum load weight that can be placed in the Tyvek® roll is 3.97 pounds (1.8kg). The roll is printed with a chemical indicator bar which is a process indicator (ISO 11140-1:2005) that changes from red to blue (or lighter) when exposed to hydrogen peroxide vapor during processing in the STERLINK™ sterilizer. The Tyvek® Roll with CI for STERLINK™ Sterilizer is offered in the follow 1 type: • Sterilization roll, Flat
Device Description
Tyvek® Roll with CI for STERLINK™ Sterilizer is intended to contain medical devices to be terminally sterilized in the STERLINK™ sterilization system. The medical devices are inserted into the roll, sealed, and then sterilized in the STERLINK™ sterilization system. After completion of the sterilization process, the roll maintains sterility of the enclosed medical devices until the seal is opened. The device is intended to allow sterilization of enclosed devices and also to maintain sterility of the enclosed devices for up to 1 month post sterilization. The roll is printed with a chemical indicator bar that changes from red to blue (or lighter) when exposed to hydrogen peroxide vapor during processing in the STERLINK™ sterilizer. The Tyvek® Roll with CI for STERLINK™ Sterilizer is offered in one type as a Flat Sterilization roll. The sterilization roll is made from a Tyvek® sheet and a clear plastic film that are heat sealed together on opposite two sides. After being cut into a suitable length, the product to be sterilized is placed inside and the two open ends are heat sealed. The process indicator printed on the Tyvek® will exhibit a color change after the roll is exposed to hydrogen peroxide (H2O2).
More Information

Not Found

No
The device description and performance studies focus on the physical properties of the sterilization roll and the chemical indicator, with no mention of AI or ML technology.

No
The device is a sterilization roll used to enclose other medical devices for sterilization and maintain their sterility, not to treat or diagnose patients itself.

No

This device is a Tyvek® roll intended for packaging medical devices for sterilization and maintaining their sterility, not for diagnosing medical conditions. The chemical indicator simply confirms exposure to hydrogen peroxide during sterilization, which is a process indicator, not a diagnostic one.

No

The device is a physical product (a sterilization roll made of Tyvek and plastic film) with a chemical indicator, not a software program.

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

Here's why:

  • Intended Use: The intended use is to enclose medical devices for sterilization and maintain their sterility. This is a function related to the processing and storage of medical devices, not the diagnosis of diseases or conditions using samples from the human body.
  • Device Description: The description focuses on the physical properties of the roll (materials, sealing) and its function in containing and protecting sterilized devices. It also mentions a chemical indicator for monitoring the sterilization process. None of these aspects relate to in vitro diagnostics.
  • Lack of IVD Characteristics: The text does not mention any of the typical characteristics of an IVD, such as:
    • Analyzing biological samples (blood, urine, tissue, etc.)
    • Detecting or measuring substances in biological samples
    • Providing information for diagnosis, monitoring, or treatment decisions based on sample analysis.

The device is clearly intended for use in the sterilization process of medical devices, which falls under the category of medical device accessories or sterilization packaging, not in vitro diagnostics.

N/A

Intended Use / Indications for Use

Tyvek® Roll with CI for STERLINK™ Sterilizer, when used in CHAMBER mode, is intended to provide health care workers with an effective method to enclose devices intended for sterilization in the STERLINK™ sterilizer. The device is intended to allow sterilization of enclosed devices and also to maintain sterility of the enclosed devices until used up to 1 month post sterilization.

The maximum load weight that can be placed in the Tyvek® roll is 3.97 pounds (1.8kg).

The roll is printed with a chemical indicator bar which is a process indicator (ISO 11140-1:2005) that changes from red to blue (or lighter) when exposed to hydrogen peroxide vapor during processing in the STERLINK™ sterilizer.

The Tyvek® Roll with CI for STERLINK™ Sterilizer is offered in the follow 1 type: Sterilization roll, Flat

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

FRG, JOJ

Device Description

Tyvek® Roll with CI for STERLINK™ Sterilizer is intended to contain medical devices to be terminally sterilized in the STERLINK™ sterilization system. The medical devices are inserted into the roll, sealed, and then sterilized in the STERLINK™ sterilization system. After completion of the sterilization process, the roll maintains sterility of the enclosed medical devices until the seal is opened. The device is intended to allow sterilization of enclosed devices and also to maintain sterility of the enclosed devices for up to 1 month post sterilization.

The roll is printed with a chemical indicator bar that changes from red to blue (or lighter) when exposed to hydrogen peroxide vapor during processing in the STERLINK™ sterilizer.

The Tyvek® Roll with CI for STERLINK™ Sterilizer is offered in one type as a Flat Sterilization roll. The sterilization roll is made from a Tyvek® sheet and a clear plastic film that are heat sealed together on opposite two sides. After being cut into a suitable length, the product to be sterilized is placed inside and the two open ends are heat sealed. The process indicator printed on the Tyvek® will exhibit a color change after the roll is exposed to hydrogen peroxide (H2O2).

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

health care workers / 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)

The performance and safety test of subject device was evaluated using the STERLINK™ FPS-15s Plus system, operating in Chamber mode, following the standards listed in the table. Key results for all tests listed (Sterilant Penetration, Shelf-life, Tear resistance, Microbial Barrier Test, CI of sterilization roll validation, Toxicological Properties, Residual sterilant on Tyvek® validation, Material compatibility test) were "Pass".

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.

K180672

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.

Not Found

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

§ 880.6850 Sterilization wrap.

(a)
Identification. A sterilization wrap (pack, sterilization wrapper, bag, or accessories, is a device intended to be used to enclose another medical device that is to be sterilized by a health care provider. It is intended to allow sterilization of the enclosed medical device and also to maintain sterility of the enclosed device until used.(b)
Classification. Class II (performance standards).

0

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

October 22, 2021

Consultant CardioMed Device Consultants LLC 1783 Forest Drive, Suite 254 Annapolis, Maryland 21401

Re: K212198

Trade/Device Name: Tyvek® Roll with CI for STERLINK™ Sterilizer Regulation Number: 21 CFR 880.6850 Regulation Name: Sterilization Wrap Regulatory Class: Class II Product Code: FRG, JOJ Dated: September 20, 2021 Received: September 21, 2021

Dear Candace Cederman:

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 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

1

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 Quality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K212198

Device Name Tyvek® Roll with CI for STERLINK™ Sterilizer

Indications for Use (Describe)

Tyvek® Roll with CI for STERLINK™ Sterilizer, when used in CHAMBER mode, is intended to provide health care workers with an effective method to enclose devices intended for sterilization in the STERLINK™ sterilizer. The device is intended to allow sterilization of enclosed devices and also to maintain sterility of the enclosed devices until used up to 1 month post sterilization.

The maximum load weight that can be placed in the Tyvek® roll is 3.97 pounds (1.8kg).

The roll is printed with a chemical indicator bar which is a process indicator (ISO 11140-1:2005) that changes from red to blue (or lighter) when exposed to hydrogen peroxide vapor during processing in the STERLINK™ sterilizer.

The Tyvek® Roll with CI for STERLINK™ Sterilizer is offered in the follow 1 type: · Sterilization roll, Flat

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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

3

1. General Information

| Applicant/Submitter: | Plasmapp Co., Ltd.
BVC-111, 125, Gwahak-ro,
Yuseong-gu, Daejeon, 34141,
Rep. of Korea (South Korea)
Tel: +82 (0)42 716 2115 |
|----------------------|-----------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | Candace Cederman |
| Address: | CardioMed Device Consultants LLC
1783 Forest Drive
Suite 254
Annapolis, MD 21401
Tel: +1 410 674 2060 |
| Preparation Date: | October 12, 2021 |

2. Device Name and Code

Device Trade Name:Tyvek® Roll with CI for STERLINK™ Sterilizer
Common Name:Tyvek® Roll for VH2O2 Sterilizer
Classification Name:1) Sterilization Wrap
  1. Sterilization Process Indicator |
    | Product Code: | 1) FRG
  2. JOJ |
    | Regulation Number: | 1) 21 CFR 880.6850
  3. 21 CFR 880.2800 |
    | Classification: | Class II |
    | Review Panel: | General Hospital |

4

3. Indications / Intended Use

Tyvek® Roll with CI for STERLINK™ Sterilizer, when used in CHAMBER mode, is intended to provide health care workers with an effective method to enclose devices intended for sterilization in the STERLINK™ sterilizer. The device is intended to allow sterilization of enclosed devices and also to maintain sterility of the enclosed devices until used up to 1 month post sterilization.

The maximum load weight that can be placed in the Tyvek® roll is 3.97 pounds (1.8kg).

The roll is printed with a chemical indicator bar which is a process indicator (ISO 11140-1:2005) that changes from red to blue (or lighter) when exposed to hydrogen peroxide vapor during processing in the STERLINK™ sterilizer.

The Tyvek® Roll with CI for STERLINK™ Sterilizer is offered in the follow 1 type:

  • . Sterilization roll, Flat

4. Device Description

Tyvek® Roll with CI for STERLINK™ Sterilizer is intended to contain medical devices to be terminally sterilized in the STERLINK™ sterilization system. The medical devices are inserted into the roll, sealed, and then sterilized in the STERLINK™ sterilization system. After completion of the sterilization process, the roll maintains sterility of the enclosed medical devices until the seal is opened. The device is intended to allow sterilization of enclosed devices and also to maintain sterility of the enclosed devices for up to 1 month post sterilization.

The roll is printed with a chemical indicator bar that changes from red to blue (or lighter) when exposed to hydrogen peroxide vapor during processing in the STERLINK™ sterilizer.

The Tyvek® Roll with CI for STERLINK™ Sterilizer is offered in one type as a Flat Sterilization roll. The sterilization roll is made from a Tyvek® sheet and a clear plastic film that are heat sealed together on opposite two sides. After being cut into a suitable length, the product to be sterilized is placed inside and the two open ends are heat sealed. The process indicator printed on the Tyvek® will exhibit a color change after the roll is exposed to hydrogen peroxide (H2O2).

5. Technical Characteristics in Comparison to Predicate Devices

The proposed subject device uses identical technology as the cited predicate devices and has the same intended uses. Based upon the overall performance characteristics for Tyvek® Roll with CI for STERLINK™ Sterilizer, Plasmapp Co., Ltd. believes there are no significant differences in

5

usage of its underlying technological principles between Tyvek® Roll with CI for STERLINK™ Sterilizer and the predicate device.

A summary of the technical characteristics of the subject device and predicate device can be found in the table below.

Subject DevicePredicate Device
510(k) SponsorPlasmapp Co., Ltd.Sigma Medical Supplies Corp.
ManufacturerSigma Medical Supplies Corp.Same
Device NameTyvek® Roll with CI for STERLINK™ SterilizerSterilization Pouch/Roll Made with Tyvek®
510(k) NumberK212198K180672
Device Classification Name1) Sterilization Wrap
  1. Sterilization Process Indicator | Same |
    | Classification Product Code | 1) FRG
  2. JOJ | Same |
    | Regulation Number | 1) 21 CFR 880.6850
  3. 21 CFR 880.2800 | Same |
    | Intended Use | Tyvek® Roll with CI for STERLINK™ Sterilizer, when used in CHAMBER mode, is intended to provide health care workers with an effective method to enclose devices intended for sterilization in the STERLINK™ sterilizer. The device is intended to allow sterilization of enclosed devices and also to maintain sterility of the enclosed devices until used up to 1 month post sterilization.

The maximum load weight that can be placed in the Tyvek® roll is 3.97lbs (1.8kg).

The roll is printed with a chemical indicator bar which is a process indicator (ISO 11140-1:2005) that changes from red to blue (or lighter) when exposed to hydrogen peroxide vapor during processing in the STERLINK™ sterilizer.

The Tyvek® Roll with CI for STERLINK™ Sterilizer is offered in the follow 1 type:
• Sterilization roll, Flat | Sterilization Pouch/Roll Made with Tyvek are intended to provide health care workers with an effective method to enclose devices intended for sterilization in the STERRAD® 100S Sterilizer. The device is intended to allow sterilization of enclosed devices and also to maintain sterility of the enclosed devices until used up to 3 years post sterilization.

The pouches and rolls are printed with a chemical indicator bar which is a process indicator (ISO 11140-1:2005) that changes from red to blue (or lighter) when exposed to hydrogen peroxide vapor during processing in the STERRAD® 100S Sterilizer.

The Sterilization Pouch/Roll Made with Tyvek® is offered in the follow 5 types:
• Self-sealing sterilization pouches
• Sterilization pouches, Flat
• Sterilization pouches, Gusseted
• Sterilization rolls, Flat
• Sterilization rolls, Gusseted |
| Pouch Types | The subject device includes a subset of the predicate device types:
Sterilization roll, Flat | Self-sealing sterilization pouches
Sterilization pouches, Flat
Sterilization pouches, Gusseted
Sterilization rolls, Flat
Sterilization rolls, Gusseted |

Summary of Subject and Predicate Device Technical Characteristics

6

Subject DevicePredicate Device
Sterilization Pouches, Flat
ModelDimensions
TYFP07520075 mm × 200 mm
TYFP07530075 mm × 300 mm
TYFP100200100 mm × 200 mm
TYFP100300100 mm × 300 mm
TYFP150255150 mm × 255 mm
TYFP150300150 mm × 300 mm
TYFP190330190 mm × 330 mm
TYFP200400200 mm × 400 mm
TYFP250450250 mm × 450 mm
TYFP300500300 mm × 500 mm
Sterilization Rolls, Flat
ModelDimensions
TYFR05007050 mm × 70 M
TYFR022f50.8 mm × 61 M
TYFR07507075 mm × 70 M
TYFR100070100 mm × 70 M
TYFR042f101.6 mm × 61 M
Device models
(Configurations
/Dimensions)TYFR150070150 mm × 70 M
Sterilization Roll, FlatTYFR062f152.4 mm × 61 M
ModelDimensionsTYFR200070200 mm × 70 M
FR400100400 mm × 100 MTYFR082f203.2 mm × 61 M
TYFR250070250 mm × 70 M
TYFR102f254 mm × 61 M
TYFR300070300 mm × 70 M
TYFR350070350 mm × 70 M
TYFR400070400 mm × 70 M
TYFR450070450 mm × 70 M
TYFR500070500 mm × 70 M
TYFR05010050 mm × 100 M
TYFR07510075 mm × 100 M
TYFR100100100 mm × 100 M
TYFR150100150 mm × 100 M
TYFR200100200 mm × 100 M
TYFR250100250 mm × 100 M
TYFR300100300 mm × 100 M
TYFR350100350 mm × 100 M
TYFR400100400 mm × 100 M
TYFR450100450 mm × 100 M
TYFR500100500 mm × 100 M
TYFR05020050 mm × 200 M
TYFR07520075 mm × 200 M
TYFR100200100 mm × 200 M
TYFR150200150 mm × 200 M
TYFR200200200 mm × 200 M
TYFR250200250 mm × 200 M
TYFR300200300 mm × 200 M
TYFR350200350 mm × 200 M
TYFR400200400 mm × 200 M

7

Subject DevicePredicate Device
Material CompositionTyvek®, PET, PE, Water, CH3COOH,
Alcohol, n-Heptane adhesive, Hydrogen
peroxide vapor Process Indicator Print InkSame
Sterilization CycleSTERLINK™ FPS-15s Plus - Chamber mode
(overall cycle: 36 minutes)STERRAD® 100S sterilization cycles:
54-minute Short cycle for most surgical instruments 72-minute Long cycle for flexible endoscopes and instruments with
longer lumen
Design FeatureSterilization roll, Flat: This roll is made
from a Tyvek® and plastic film that are heat
sealed on opposite two sides. It will be cut
into the suitable length and the opened sides
will be heat-sealed. The indicators printed on
the Tyvek® are the same with the self-sealing
sterilization roll.Same
Chemical Indicator
Device DesignThe color of the Chemical Indicator changes
from red to blue (or lighter) when exposed to
hydrogen peroxide.Same

6. Summary of Non-Clinical Testing

The Tyvek® Roll with CI for STERLINK™ Sterilizer has the identical intended use and indication for use as the predicate devices. Testing of the roll material was previously conducted on the predicate K180672. The identical materials are used in the Tyvek® Roll with CI for STERLINK™ Sterilizer. The size of the subject device is within the range of sizes available for the predicate device.

The performance and safety test of subject device was evaluated using the STERLINK™ FPS-15s Plus system, operating in Chamber mode, following the standards listed in the table below.

Performance TestingStandardResult
Sterilant
PenetrationSterilization efficacy testISO 14937Pass
CI of sterilization roll validationANSI/AAMI/ISO 11140-1Pass
Shelf-lifeInternal pressurization testASTM F1980-16
ASTM F1140/F1140M-13Pass
Visual inspection testASTM F1980-16
ASTM F1886/F1886M-16Pass
Dye penetration testASTM F1980-16
ASTM F1929-15Pass
Tensile strength of Tyvek®ASTM F1980-16
ASTM D5035-11Pass
Tensile strength of plastic filmASTM F1980-16
ASTM D882Pass
Seal strengthASTM F1980-16
ASTM F88Pass

8

Tyvek® Roll with CI for STERLINK™ Sterilize
510(k) Summary - K212198
Performance TestingStandardResult
Tear resistanceASTM F1980-16
ASTM D1922-20Pass
Microbial Barrier TestASTM F1980-16
DIN 58953-6Pass
CI of sterilization roll validationANSI/AAMI/ISO 11140-1Pass
Toxicological Properties
(Biocompatibility Tests)ISO 10993-5Pass - Test article is non-
cytotoxic after the sterilization.
Residual sterilant on Tyvek® validationInternal test standardPass
Material compatibility testASTM D638
ASTM E8/E8M-ae1
ASTM D790
ASTM E290-14
ASTM D256
ASTM E23-18
ASTM E1164
ASTM E313
ASTM D3985
ASTM F1249
Internal test standardPass

7. Conclusions

The conclusions drawn from the non-clinical tests demonstrates that the subject device in 510(k) submission K212198, Tyvek® Roll with CI for STERLINK™ Sterilizer, is as safe, as effective, and performs as well or better than the legally marketed predicate device cleared under K180672.