K Number
K220250
Device Name
Sterile Powder Free Nitrile Examination Gloves (Blue), Tested for Use with Chemotherapy Drugs
Date Cleared
2022-05-11

(100 days)

Product Code
Regulation Number
880.6250
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Sterile Powder Free Nitrile Examination Gloves (Blue), Tested for Use with Chemotherapy Drugs is a disposable device intended for medical purposes that is worn on the examiner's hand or finger to prevent contamination between patient and examiner. In addition these gloves were tested for use with Chemotherapy drugs in accordance with ASTM D6978 standards.
Device Description
The subject device is Nitrile Examination Gloves Sterile with Chemotherapy drugs claims. The subject device is a patient examination glove made from nitrile latex compound, blue color, powder free and sterile (Per 21 CFR 880.6250, class I). The device is direct contact and not to be worn for more than 24 hours. The device meets all the specifications in ASTM D6319-19, Standard specification for Nitrile Examination Gloves. Additionally, the gloves have been tested for biocompatibility per 10993-10, 10993-11 and permeability to chemotherapy drugs per ASTM D6978-05(2019).
More Information

Not Found

No
The 510(k) summary describes a standard medical examination glove and its performance testing against established standards. There is no mention of AI or ML technology in the intended use, device description, or performance studies.

No.
The device is described as a disposable glove intended to prevent contamination between patient and examiner, and is used for medical purposes, not to treat or diagnose a disease or condition.

No

Explanation: This device is a pair of examination gloves, stated to prevent contamination between the patient and examiner. Its purpose is protective, not diagnostic.

No

The device is a physical product (nitrile examination gloves) and does not involve any software component.

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use is clearly stated as a "disposable device intended for medical purposes that is worn on the examiner's hand or finger to prevent contamination between patient and examiner." This describes a barrier device used for protection during physical examination or procedures.
  • Device Description: The description confirms it's a "patient examination glove made from nitrile latex compound."
  • Lack of IVD Characteristics: An IVD is a medical device used to perform tests on samples taken from the human body (like blood, urine, tissue) to provide information about a person's health. This device does not perform any such tests. It is a physical barrier.
  • Regulatory Classification: The device is classified as "Per 21 CFR 880.6250, class I," which is the classification for patient examination gloves. IVDs have different regulatory classifications.

While the gloves are tested for use with chemotherapy drugs, this is a performance characteristic related to their barrier function and safety when handling these substances, not an indication that they are used for diagnostic testing.

N/A

Intended Use / Indications for Use

Sterile Powder Free Nitrile Examination Gloves (Blue), Tested for Use with Chemotherapy Drugs as a disposable device intended for medical purposes that is worn on the examiner's hand or finger to prevent contamination between patient and examiner. In addition these gloves were tested for use with Chemotherapy drugs in accordance with ASTM D6978 standards.

Product codes

LZA, LZC

Device Description

The subject device is Nitrile Examination Gloves Sterile with Chemotherapy drugs claims. The subject device is a patient examination glove made from nitrile latex compound, blue color, powder free and sterile (Per 21 CFR 880.6250, class I). The device is direct contact and not to be worn for more than 24 hours. The device meets all the specifications in ASTM D6319-19, Standard specification for Nitrile Examination Gloves. Additionally, the gloves have been tested for biocompatibility per 10993-10, 10993-11 and permeability to chemotherapy drugs per ASTM D6978-05(2019).

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Hand or finger

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Examiner / Medical purposes

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

Non-clinical tests were performed to verify that the subject device will meet the acceptance criteria of the performance test shown below:

  1. ASTM D6319-19 (Dimensions): The purpose of the testing is to measure the dimensions of the subject device. Acceptance criteria for palm width by size: XS-70±10, S-80±10, M-95±10, L-110±10, XL-120±10, XXL-130±10. Result: Meets.
  2. ASTM D6319-19 (Physical Properties): The purpose of the testing is to measure the physical properties of the subject device. Acceptance criteria: Finger Thickness - Minimum 0.05mm, Palm Thickness - Minimum 0.05mm, Tensile Strength before aging - 14MPa, min, Ultimate Elongation before aging - 500%, min, Tensile Strength After Accelerated Aging - 14MPa, min, Ultimate Elongation After Accelerated Aging - 400%, min. Result: Meets.
  3. ASTM D6319-19 / ASTM D5151-19 (Freedom from holes): The purpose of the testing is to measure the freedom from holes of the subject device. Acceptance criteria: In accordance with ASTM D5151-19, following ASTM D6319-19, G-I, AQL 2.5. Result: Meets.
  4. ASTM D6124-06(2017) / ASTM D6319-19 (Residual powder): The purpose of the testing is to measure the residual powder on the subject device. Acceptance criteria: ≤2 mg per glove. Result: Meets.
  5. ISO 10993-10:2010 (Primary skin irritation test): The purpose of the testing is to measure the primary skin irritation test of the subject device. Acceptance criteria: Under the conditions of the study the device extracts were not an irritant. Result: Meets.
  6. ISO 10993-10:2010 (Dermal sensitization assay): The purpose of the testing is to measure the Dermal sensitization assay of the subject device. Acceptance criteria: Under the conditions of the study the device extracts were not a sensitizer. Result: Meets.
  7. ISO 10993-11:2017 (Acute Systemic Toxicity): The purpose of the testing is to measure the Acute Systemic Toxicity of the subject device. Acceptance criteria: Under the conditions of this study, there was no evidence of systemic toxicity for the device extracts. Result: Meets.
  8. ASTM D6978 standards (Chemotherapy Drug Permeation): Tested for breakthrough time (BDT) with various chemotherapy drugs.
    • Carmustine (BCNU) (3.3mg/ml): 54.3 minutes
    • Cyclophosphamide (20mg/ml): >240 minutes
    • Doxorubicin Hydrochloride (2 mg/ml): >240 minutes
    • Etoposide (20mg/ml): >240 minutes
    • Fluorouracil (50mg/ml): >240 minutes
    • Paclitaxel (6mg/ml): >240 minutes
    • Thiotepa (10mg/ml): 196.7 minutes
    • Methotrexate (25mg/ml): >240 minutes
    • Cisplatin (1mg/ml): >240 minutes
    • Vincristine Sulfate (1.0 mg/ml): >240 minutes
    • Cytarabine HCL (100mg/ml): >240 minutes
    • Mitoxantrone (2.0 mg/ml): >240 minutes
    • Mitomycin C (0.5 mg/ml): >240 minutes
    • Ifosfamide (50.0 mg/ml): >240 minutes
    • Dacarbazine (DTIC) (10.0 mg/ml): >240 minutes

Key Metrics

Not Found

Predicate Device(s)

K190725

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 880.6250 Non-powdered patient examination glove.

(a)
Identification. A non-powdered patient examination glove is a disposable device intended for medical purposes that is worn on the examiner's hand or finger to prevent contamination between patient and examiner. A non-powdered patient examination glove does not incorporate powder for purposes other than manufacturing. The final finished glove includes only residual powder from manufacturing.(b)
Classification. Class I (general controls). The device, when it is a finger cot, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 880.9.

0

Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: a symbol on the left and the FDA name on the right. The symbol on the left is a stylized image of a human figure, while the FDA name on the right is written in blue letters. The words "U.S. FOOD & DRUG ADMINISTRATION" are written in a clear, sans-serif font.

May 11, 2022

Grand Work Plastic Products Co., Ltd % Kathy Liu Project Manager Hongray USA Medical Products Inc. 3973 Schaefer Avenue Chino, California 91710

Re: K220250

Trade/Device Name: Sterile Powder Free Nitrile Examination Gloves (Blue), Tested for Use with Chemotherapy Drugs Regulation Number: 21 CFR 880.6250 Regulation Name: Non-Powdered Patient Examination Glove Regulatory Class: Class I, reserved Product Code: LZA, LZC Dated: February 12, 2022 Received: February 17, 2022

Dear Kathy Liu:

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.

1

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about 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.

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) K220250

Device Name

Sterile Powder Free Nitrile Examination Gloves (Blue), Tested for Use with Chemotherapy Drugs

Indications for Use (Describe)

Sterile Powder Free Nitrile Examination Gloves (Blue), Tested for Use with Chemotherapy Drugs is a disposable device intended for medical purposes that is worn on the examiner's hand or finger to prevent contamination between patient and examiner. In addition these gloves were tested for use with Chemotherapy drugs in accordance with ASTM D6978 standards.

Chemotherapy DrugMinimum BDT (Minutes)
Carmustine (BCNU) (3.3mg/ml)54.3
Cyclophosphamide (20mg/ml)>240
Doxorubicin Hydrochloride (2 mg/ml)>240
Etoposide (20mg/ml)>240
Fluorouracil (50mg/ml)>240
Paclitaxel (6mg/ml)>240
Thiotepa (10mg/ml)196.7
Methotrexate (25mg/ml)>240
Cisplatin (1mg/ml)>240
Vincristine Sulfate (1.0 mg/ml)>240
Cytarabine HCL (100mg/ml)>240
Mitoxantrone (2.0 mg/ml)>240
Mitomycin C (0.5 mg/ml)>240
Ifosfamide (50.0 mg/ml)>240
Dacarbazine (DTIC) (10.0 mg/ml)>240
Please note that the following drugs have low permeation times:
Carmustine (BCNU): 54.3 minutes, Thiotepa: 196.7 minutes

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

Prescription Use (Part 21 CFR 801 Subpart D)

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

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3

Donggao Industrial Zone, Zanhuang, Hebei, 050000, China

Product: Sterile Powder Free Nitrile Examination Gloves (Blue), Tested for Use with Chemotherapy Drugs

510(K) SUMMARY

This summary of 510(K) is being submitted in accordance with requirements of 21 CFR $807.92.

The assigned 510(K) number is: K220250

Date Prepared: January 20, 2022

  1. Owner's Identification:

Mrs. Wu Yuli Grand Work Plastic Products Co., Ltd. Donggao Industrial Zone, Zanhuang, Hebei, 050000, China Tel: 86-311-66179668

Contact: Ms. Kathy Liu, Project Manager Address: 3973 Schaefer Ave., Chino, CA 91710 Tel: 909-590-1611

2. Name of the Device:

Trade Name: Sterile Powder Free Nitrile Examination Gloves (Blue), Tested for Use with Chemotherapy Drugs Common Name: Exam Gloves Classification Name: Patient Examination Glove Classification Regulation: 880.6250 Classification Panel: 880 General Hospital and Personal Use Product Code: LZA and LZC Device Class: Class I

3. Predicate Device Information:

Riverstone Resources SDN BHD. Nitrile Examination Glove, Sterile Tested for use with Chemotherapy Drugs Claim, White (K190725)

4. Device Description:

The subject device is Nitrile Examination Gloves Sterile with Chemotherapy drugs claims. The subject device is a patient examination glove made from nitrile latex compound, blue color, powder free and sterile (Per 21 CFR 880.6250, class I). The device is direct contact and not to be worn for more than 24 hours. The device meets all the specifications in ASTM D6319-19, Standard specification for Nitrile Examination Gloves. Additionally, the gloves have been tested for biocompatibility per 10993-10, 10993-11 and permeability to chemotherapy drugs per ASTM D6978-05(2019).

5. Indications for Use:

A patient examination glove is disposable device intended for medical purpose that is worn on the examiner's hand or finger to prevent contamination between patient and examiner. In addition, these gloves were tested for use with chemotherapy drugs and provides protection against following chemotherapy drugs and the minimum breakthrough time are listed as follows.

Chemotherapy DrugMinimum BDT (Minutes)
Carmustine (BCNU) (3.3mg/ml)54.3
Cyclophosphamide (20mg/ml)>240
Doxorubicin Hydrochloride (2 mg/ml)>240
Etoposide (20mg/ml)>240
Fluorouracil (50mg/ml)>240
Paclitaxel (6mg/ml)>240

4

Donggao Industrial Zone, Zanhuang, Hebei, 050000, China

Product: Sterile Powder Free Nitrile Examination Gloves (Blue), Tested for Use with Chemotherapy Drugs

Thiotepa (10mg/ml)196.7
Methotrexate (25mg/ml)>240
Cisplatin (1mg/ml)>240
Vincristine Sulfate (1.0 mg/ml)>240
Cytarabine HCL (100mg/ml)>240
Mitoxantrone (2.0 mg/ml)>240
Mitomycin C (0.5 mg/ml)>240
Ifosfamide (50.0 mg/ml)>240
Dacarbazine (DTIC) (10.0 mg/ml)>240

Please note that the following drugs have low permeation times: Carmustine (BCNU): 54.3 minutes, Thiotepa: 196.7 minutes

6. Specification for Nitrile Gloves:

ItemsAcceptance CriteriaResults
LengthMinimum 230mmAll size ≥290
Palm WidthXS: 70±10mm76-78mm
S: 80±10mm86-88 mm
M:95±10mm96 -98mm
L:110±10mm106-108 mm
XL: 120±10mm116-118 mm
XXL: 130±10mm126-128 mm
ThicknessPalm: 0.05mm (min)0.09-0.11mm
Finger: 0.05mm (min)0.13-0.14mm
Tensile Strength, Before Aging14MPa, min15.8-20.8 MPa
Tensile Strength, After Accelerated Aging14MPa, min15.6-19.8 MPa
Ultimate Elongation, Before Aging500%, min500-560%
Ultimate Elongation, After Accelerated Aging400%, min400-500%
Freedom from holesG-I, AQL 2.5Meet and above AQL2.5
requirements
Powder-Content≤2 mg per glove≤ 2 mg, meet requirements

Gloves meet all the specification listed in ASTM D 6319-19.

7. Technological Characteristic Comparison:

CharacteristicsSubject DevicePredicate Device K190725Comparison
Trade NameSterile Powder Free Nitrile
Examination Gloves (Blue), Tested
for Use with Chemotherapy DrugsNitrile Examination Gloves
Sterile Tested for Use with
Chemotherapy Drugs claim, WhiteSimilar
Product CodeLZA and LZCLZA and LZCSame
Regulation Number21 CFR 880.625021 CFR 880.6250Same

5

Donggao Industrial Zone, Zanhuang, Hebei, 050000, China

Product: Sterile Powder Free Nitrile Examination Gloves (Blue), Tested for Use with Chemotherapy Drugs

ClassIISame
Indications for UseSubject device is a disposable device intended for medical purpose that is worn on the examiner's hand or finger to prevent contamination between patient and examiner. The device is for over-the-counter use.Predicate device is a disposable device intended for medical purpose that is worn on the examiner's hand or finger to prevent contamination between patient and examiner. The device is for over-the-counter use.Same
DescriptionSterile Examination glove made of
Nitrile and color Blue and tested
with chemotherapy DrugsSterile Examination glove made of
Nitrile and color White and tested with
chemotherapy DrugsSame
Design FeatureAmbidextrousAmbidextrousSame
Material useNitrile Synthetic LatexNitrile Synthetic LatexSame
ColorBlueWhiteDifferent
Sterility ISO 11737-2
EN ISO 11137-2SterilitySterilitySame
Single usedSingle usedSingle usedSame
Non Sterile or SterileSterileSterileSame
10993-10:2010 Skin
Irritation StudyUnder the conditions of the
study, not an irritantUnder the conditions of the study,
not an irritantSame
10993-10:2010
Maximization Sensitization
StudyUnder the conditions of the
study, not a sensitizerUnder the conditions of the study,
not a sensitizerSame
ISO 10993 Part 11
Acute Systemic Toxicity
TestUnder the conditions of this study,
there was no evidence of systemic
toxicity.Under the condition of this study,
Nitrile Examination glove, sterile
shows no adverse biological reactionSame

Dimensions and Performance Comparison Table:

| Technological
Characteristics | Subject Device | Predicate Device
K190725 | Comparison |
|--------------------------------------|----------------|-----------------------------|------------|
| Length | Minimum 230mm | Minimum 230mm | Same |
| Palm Width (size) (mm) | | | |
| XS | 70±10 | 70±10 | Same |
| S | 80±10 | 80±10 | Same |
| M | 95±10 | 95±10 | Same |
| L | 110±10 | 110±10 | Same |
| XL | 120±10 | 120±10 | Same |
| XXL | 130±10 | / | Different |
| Thickness(mm) | | | |
| Finger | Minimum 0.05 | Minimum 0.05 | Same |
| Palm | Minimum 0.05 | Minimum 0.05 | Same |
| Tensile Strength, Before Aging | 14MPa, min | 14MPa, min | Same |
| Ultimate Elongation,
Before Aging | 500%, min | 500%, min | Same |

6

Donggao Industrial Zone, Zanhuang, Hebei, 050000, China

Product: Sterile Powder Free Nitrile Examination Gloves (Blue), Tested for Use with Chemotherapy Drugs

| Tensile Strength, After

Accelerated Aging14MPa, min14MPa, minSame
Ultimate Elongation, After
Accelerated Aging400%, min400%, minSame
Freedom from holesIn accordance with ASTM D
5151-19, following ASTM
D6319- 19, G-I, AQL 2.5In accordance with ASTM D
5151-19, following ASTM
D6319- 19, G-I, AQL 2.5Same
Residual Powder≤ 2 mg per glove≤ 2 mg per gloveSame

Chemotherapy Permeation Comparison:

| Tested Chemotherapy Drug and

ConcentrationMinimum BDT (Minutes)Comparison
Subject DevicePredicate Device
K190725
Carmustine (BCNU) (3.3mg/ml)54.339Similar
Cyclophosphamide (20mg/ml)>240>240Same
Cytarabine (1.0 mg/ml)/>240Different
Doxorubicin Hydrochloride (2 mg/ml)>240>240Same
Etoposide (20mg/ml)>240>240Same
Fluorouracil (50mg/ml)>240>240Same
Paclitaxel (6mg/ml)>240>240Same
Thiotepa (10mg/ml)196.797.6Similar
Methotrexate (25mg/ml)>240>240Same
Cisplatin (1mg/ml)>240/Exceed
Vincristine Sulfate (1.0 mg/ml)>240/Exceed
Cytarabine HCL (100mg/ml)>240/Exceed
Mitoxantrone (2.0 mg/ml)>240/Exceed
Mitomycin C (0.5 mg/ml)>240/Exceed
Ifosfamide (50.0 mg/ml)>240/Exceed
Dacarbazine (10.0 mg/ml)>240/Exceed

8 Summary of Non-Clinical Testing

Non-clinical tests were performed to verify that the subject device will meet the acceptance criteria of the performance test shown below:

| Test Methodology | Purpose | Acceptance
Criteria | Result Summary |
|------------------|--------------------------------------------------------------------------------------|-----------------------------------------------------------------------|----------------|
| ASTM D6319-19 | The purpose of the testing is to
measure the dimensions of the
subject device. | XS-70±10
S-80±10
M-95±10
L-110±10
XL-120±10
XXL-130±10 | Meets |
| ASTM D6319-19 | The purpose of the testing is to
measure the physical properties of | Finger - Minimum 0.05 | Meets |

7

ggao Industrial Zone, Zanhuang, Hebei, 050000, China

the subject device.Palm - Minimum 0.05
Tensile Strength, before aging -
14MPa, min
Ultimate Elongation, Before Aging -
500%, min
Tensile Strength, After Accelerated
Aging - 14MPa, min
Ultimate
Elongation, After
Accelerated
Aging - 400%,
mi
ASTM D6319- 19
ASTM D5151-19The purpose of the testing is to
measure the freedom from holes of
the subject device.In accordance with ASTM D
5151-19, following ASTM
D6319- 19, G-I,
AQL 2.5Meets
ASTM D 6124-06(2017)
ASTM D6319- 19The purpose of the testing is to
measure the residual powder on the
subject device.≤2 mg per gloveMeets
ISO 10993-10:2010The purpose of the testing is to
measure the primary skin irritation
test of the subject device.Under the conditions of the study the
device extracts were not an irritantMeets
ISO 10993-10:2010The purpose of the testing is to
measure the Dermal sensitization
assay of the subject device.Under the conditions of the study
the device extracts were not a
sensitizerMeets
ISO 10993-11:2017The purpose of the testing is to
measure the Acute Systemic
Toxicity of the subject device.Under the conditions of this study,
there was no evidence of systemic
toxicity for the device extracts.Meets

8

Donggao Industrial Zone, Zanhuang, Hebei, 050000, China

Product: Sterile Powder Free Nitrile Examination Gloves (Blue), Tested for Use with Chemotherapy Drugs

The subject device meets the applicable requirements for patient examination gloves with regards to dimension and sizes, physical properties, freedom from holes and powder Residuals as found in the following standards: ASTM D6139, ASTM D5151, ASTM D6124.The subject device passes biological reactivity testing for dermal sensitization, irritation and acute systemic toxicity with accordance ISO10993-10 and ISO 10993-11.

9. Conclusion:

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