(105 days)
The Ear Pressure Relief Device is indicated for the treative middle ear pressure. Negative middle ear pressure can lead to fluid accumulation in the middle ear, impaired hearing loss. The Ear Pressure Reliever provides a method of ventilating the middle ear by momentarily increasing the air pressure in the eustachian tube. Equalizing the pressure can prevent the accumulation of fluid and prevent hearing loss.
The Ear Pressure Relief Device is designed to blow a controlled flow of air into the nose to facilitate opening the eustachian tubes. For use, the nosepiece is fitted tightly against one nostril to make an airtight seal. While pinching the other nostril shut, the Ear Pressure Relief Device is activated by pressing and holding the adjustment button. The patient swallows while the device is running, allowing regulated air to move from the nose to the eustachian tube to help open the eustachian tube and equalize pressure in the middle ear. Ear Pressure Relief Device is provided non-sterile, and is designed for reuse with a single patient.
The provided FDA 510(k) summary for the "Ear Pressure Relief Device (ER813B)" does not contain the level of detail typically found in a study focused on establishing acceptance criteria and proving device performance for an AI/ML-driven device. This document describes a physical medical device that appears to operate without AI or complex algorithms.
However, I can extract the information relevant to what I understand you’re asking for, aligning it with the structure you provided, even if some categories are not directly applicable to this type of device.
Key takeaway: This medical device clearance is based on substantial equivalence to a predicate device, primarily demonstrated through bench testing for physical performance, electrical safety, EMC, and biocompatibility, rather than a clinical study with human readers or AI performance metrics.
Here's the analysis based on the provided document:
1. A table of acceptance criteria and the reported device performance
Since this is a physical medical device and not an AI/ML diagnostic tool, the "acceptance criteria" are based on engineering specifications and regulatory compliance rather than diagnostic performance metrics like sensitivity, specificity, or AUC. The reported device performance is a confirmation that these specifications were met through bench testing.
| Acceptance Criteria Category | Specific Acceptance Criteria (Target) | Reported Device Performance (Test Result) |
|---|---|---|
| Air Pressure | 31 – 41 kPa (4.5 to 6 PSI) | 31 – 41 kPa (4.5 to 6 PSI) (Confirmed, implicitly met for substantial equivalence) |
| Air Flow Rate | 1.7 – 2.1 LPM | 1.7 – 2.1 LPM (Confirmed, implicitly met for substantial equivalence) |
| Electrical Safety | Compliance with ANSI AAMI ES60601-1, IEC 60601-1-2, IEC 60601-1-11 | Passed electrical safety testing, complies with listed standards. |
| EMC (Electromagnetic Compatibility) | Compliance with IEC 60601-1-2, IEC 60601-1-11 | Passed EMC testing, complies with listed standards. |
| Biocompatibility | Compliance with ISO 10993-5 (cytotoxicity), ISO 10993-10 (irritation/sensitization), ISO 10993-23 (irritation) | Passed biocompatibility tests, complies with listed standards. |
| Dimensional Verification | (Implied: Meets design specifications of 152.335.529.7mm) | Verified (Met design specifications for dimension). |
| Pressure Value Verification | (Implied: Meets specified Air Pressure range) | Verified (Met specified Air Pressure range). |
| Flow Rate Verification | (Implied: Meets specified Air Flow Rate range) | Verified (Met specified Air Flow Rate range). |
| Drop Test Verification | (Implied: Withstands specified drop height/impact without failure affecting performance) | Verified (Met specified drop test requirements). |
| Software Verification & Validation | Not applicable (No software in device) | "This product does not include software," so no software V&V was required or performed. |
| Labeling | Meet FDA's requirement | Declared to "Meet FDA's requirement" (implicitly through review of submission documents and proposed labeling). |
2. Sample size used for the test set and the data provenance
- Sample Size: Not applicable in the context of a "test set" for an AI/ML algorithm or a clinical trial. The testing involved physical units of the device for bench, electrical, EMC, and biocompatibility tests. The document doesn't specify the number of physical units tested, but these are typically small numbers (e.g., 3-5 units for bench tests, relevant samples for biocompatibility).
- Data Provenance: The tests (bench, electrical, EMC, biocompatibility) were conducted on the "Ear Pressure Relief Device (ER813B)" itself. The document does not specify the origin of the samples if different from the manufacturing site (Ningbo Albert Novosino Co., Ltd., China). The tests are prospective in the sense that they are conducted on newly manufactured devices to verify performance against design specifications.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable to this type of device. There is no "ground truth" established by human experts in the context of diagnostic accuracy for this physical medical device. The "ground truth" here is adherence to engineering specifications and regulatory standards, verified by testing specialists and accredited labs.
4. Adjudication method for the test set
Not applicable. There was no "adjudication method" involving multiple experts for a diagnostic task. Testing involves objective measurements against predefined engineering specifications and regulatory standards.
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. This device is a standalone physical product, not an AI-assisted diagnostic tool. Therefore, an MRMC comparative effectiveness study was not performed, nor is there any mention of human readers or AI assistance.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
No. This device is a physical product for direct patient use to relieve ear pressure, not an algorithm.
7. The type of ground truth used
The "ground truth" for this device's performance is adherence to engineering specifications (e.g., air pressure range, flow rate, dimensions), biocompatibility standards, electrical safety standards, and electromagnetic compatibility (EMC) standards. These are objective, measurable criteria.
8. The sample size for the training set
Not applicable. This is not an AI/ML device, so there is no "training set."
9. How the ground truth for the training set was established
Not applicable. As there is no training set, there is no ground truth established for one.
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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 USA seal. To the right of the seal is the FDA logo in blue, with the words "U.S. FOOD & DRUG" stacked on top of the word "ADMINISTRATION".
June 9, 2023
Ningbo Albert Novosino Co., Ltd. % Doris Dong General manager Shanghai CV Technology Co., Ltd. Room 903, No.19 Dongbao Road, Songjiang Area, Shanghai, Shanghai 201613 China
Re: K230502
Trade/Device Name: Ear Pressure Relief Device (ER813B) Regulatory Class: Unclassified Product Code: MJV Dated: May 10, 2023 Received: May 12, 2023
Dear Doris Dong:
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
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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 (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,
Shuchen Peng -S
Shu-Chen Peng, Ph.D. Assistant Director DHT1B: Division of Dental and ENT Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental 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)
Device Name Ear Pressure Relief Device
Indications for Use (Describe)
The Ear Pressure Relief Device is indicated for the treative middle ear pressure. Negative middle ear pressure can lead to fluid accumulation in the middle ear, impaired hearing loss. The Ear Pressure Reliever provides a method of ventilating the middle ear by momentarily increasing the air pressure in the eustachian tube. Equalizing the pressure can prevent the accumulation of fluid and prevent hearing loss.
| Type of Use (Select one or both, as applicable) | |
|---|---|
| Prescription Use (Part 21 CFR 801 Subpart D) | |
| Over-The-Counter Use (21 CFR 801 Subpart C) | ☒ |
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510(k) Summary [As required by 21 CFR 807.92]
1. Submission Information
| 510(k) Number: | K230502 |
|---|---|
| Date: | June 8, 2023 |
| Type of 510(k) Submission: | Traditional 510(k) |
| Basis for 510(k) Submission: | New device |
| Owner: | Ningbo Albert Novosino Co.,Ltd.No. 28 Yunshan Middle Road, Sanqishi town, Yuyao, Zhejiang 315412, ChinaContact person: Victor ZhouTel: 86-574-87527882Email: victor@albertnovosino.com |
| Contact: | Doris Dong[Consultant, from Shanghai CV Technology Co., Ltd.]Add: Room 602, No. 19 Dongbao Road, Songjiang Area, Shanghai, 201613 ChinaE-mail: doris.d@ceve.org.cnTel: 86 21-31261348 / Fax: 86 21-57712250 |
2. Device Description
| Proprietary Name: | Ear Pressure Relief Device |
|---|---|
| Model: | ER813B |
| Common Name: | Middle Ear Inflation Device |
| Classification Name: | Device, Inflation, Middle Ear |
| Product Code: | MJV |
| Device Class: | Unclassified |
| Review Panel: | Ear Nose & Throat |
| Device Description: | The Ear Pressure Relief Device is designed to blow a controlled flow of air into the nose to facilitate opening the eustachian tubes.For use, the nosepiece is fitted tightly against one nostril to make an airtight seal. While pinching the other nostril shut, the Ear Pressure Relief Device is activated by pressing and holding the adjustment button. The patient swallows while the device is running, allowing regulated air to move from the nose to the eustachian tube to help open the eustachian tube and equalize pressure in the middle ear.Ear Pressure Relief Device is provided non-sterile, and is designed for reuse with a single patient. |
| Indications for use: | The Ear Pressure Relief Device is indicated for the treatment of negative middle ear pressure. Negative middle ear pressure can lead to fluid accumulation in the middle ear, impaired hearing, and hearing loss. The Ear Pressure Relief Device provides a method of ventilating the middle ear by momentarily increasing the air pressure in the nose and the eustachian tube. Equalizing the pressure can prevent the accumulation of fluid and prevent hearing loss. |
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3. Predicate Device Information
| Predicate 510(k) Number: | K203754 |
|---|---|
| Marketing clearance date: | 02/19/2021 |
| Product name: | Eustachi Ear Pressure Relief Device |
| Manufacturer: | Exercore, LLC |
| Parameters | New Device | Predicate Device | Comparison |
|---|---|---|---|
| 510(k) number | K230502 | K203754 | -- |
| Submitter | Ningbo Albert Novosino Co.,Ltd. | Exercore, LLC | -- |
| Device name | Ear Pressure Relief Device | Eustachi Ear Pressure ReliefDevice | -- |
| Model | ER813B | / | -- |
| Device class | Unclassified | Unclassified | Same |
| Product code | MJV | MJV | Same |
| Classificationname | Device, Inflation, Middle Ear | Device, Inflation, Middle Ear | Same |
| Indications for use | The Ear Pressure Relief Device isindicated for the treatment ofnegative middle ear pressure.Negative middle ear pressure canlead to fluid accumulation in themiddle ear, impaired hearing, andhearing loss. The Ear PressureRelief Device provides a methodof ventilating the middle ear bymomentarily increasing the airpressure in the nose andtheeustachian tube. Equalizing thepressurecanpreventtheaccumulation of fluid and preventhearing loss. | The Eustachi is indicated for thetreatment of negative middle earpressure. Negative middle earpressure can lead to fluidaccumulation in the middle ear,impaired hearing, and hearingloss. The Eustachi provides amethod of ventilating the middleear by momentarily increasing theair pressure in the nose and theeustachian tube. Equalizing thepressure can prevent theaccumulation of fluid and preventhearing loss. | Same |
| Type of Use | Over-the-Counter | Over-the-Counter | Same |
| Patient Use | Performed at home by patient ontheir own or under adultsupervision | Performed at home by patient ontheir own or under adultsupervision | Same |
| IntendedUseEnvironment | Home Use | Home Use | Same |
| Sterile | Non-Sterile | Non-Sterile | Same |
| Product | 152.335.529.7mm | 1553045mm | Similar |
| Dimension(mm)[HWD] | Note 1 | ||
| Product Weight | 105g | 116.4g | |
| Output Head | One output head | One output head | Similar |
| Diameter:16mm | Diameter:22mm | Note 3 | |
| Components | Handheld unit | Handheld unit | Same |
| Power Supply | Lithium battery | Alkaline Battery-powered (2 AA) | SimilarNote 2 |
| Mechanism of Action | Provides flow of air to openeustachian tube | Provides flow of air to openeustachian tube | Same |
| User Interface | Press on power button,then presson working button | Single button press on handheldunit | SimilarNote 1 |
| Air Pressure | 31 – 41 kPa (4.5 to 6 PSI) | 31 – 41 kPa (4.5 to 6 PSI) | Same |
| Air Flow Rate | 1.7 – 2.1 LPM | 1.7 – 2.1 LPM | Same |
| Patient Contact Type | Surface-contact device in contactwith mucosal tissue for limitedduration (less than 24 hours) | Surface-contact device in contactwith mucosal tissue for limitedduration (less than 24 hours) | Same |
| Materials | ABS plastic | ABS plastic | Same |
| Labeling | Meet FDA's requirement | Meet FDA's requirement | Same |
4. Comparison to predicate device
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Differences between New device and Predicate Device:
Note 1:
The weight, dimensions and user Interface of the proposed device are a little different from the predicate device, this is a slightly different product design, but these differences are minor and do not affect device performance as compared to the predicate device.
Note 2:
The power supply of the proposed device are a little different from the predicate device,but these differences are insignificant in terms of safety or effectiveness.In addition, the proposed device has passed the electrical safety test and ,so these differences don't raise any new safety and effectiveness issues.
Note 3:
The predicate device requests that the user to press the nosepiece tightly against one nostril making an airtight seal and pinch other nostril tightly shut with other hand making an airtight seal. While the subject device requires the user to press the silicone heads tightly into both nostrils and ensure air tightness. The only difference is that instead of using hand to seal the other nostril, the new device uses its own silicon head. We have studied the diameter of nasal products on the market from 5 to 12 mm, and the diameter of the output head of both the new device and the predicate device can cover this range.In order to prove the same sealing effect, we did an additional air tightness test with the silicon head.
In addition, we have added in the instruction manual that users can use hand instead of silicone head to block the other nostril during treatment, depending on their personal habits. Therefore, we believe that this difference will not affect the device performance as compared to the predicate device.
5. Non-clinical Testing
Non clinical tests were conducted to verify that the proposed device met all design specifications as was Substantially Equivalent (SE) to the predicate devices. The test results demonstrated that the proposed device complies with the following standards:
Electrical safety and electromagnetic compatibility (EMC):
- ANSI AAMI ES60601-1:2005/(R)2012 And A1:2012, C1:2009/(R)2012 And A2:2010/(R)2012
(Consolidated Text) Medical Electrical Equipment - Part 1: General Requirements For Basic Safety And Essential Performance (IEC 60601-1:2005, MOD);
- IEC 60601-1-2:2014, Medical Electrical Equipment -- Part 1-2: General Requirements For Basic Safety And Essential Performance -- Collateral Standard: Electromagnetic Disturbances -- Requirements And Tests;
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- IEC 60601-1-11 Edition 2.1 2020-07 CONSOLIDATED VERSION, Medical electrical equipment - Part 1-11: General requirements for basic safety and essential performance - Collateral Standard: Requirements for medical electrical equipment and medical electrical systems used in the home healthcare environment.
Biocompatibility testing:
The biocompatibility evaluation for the Ear Pressure Relief Device was conducted in accordance with the FDA Blue Book Memorandum #G95-1 "Use of International Standard ISO-10993, "Biological Evaluation of Medical Devices Part 1: Evaluation and Testing," May 1, 1995, and International Standard ISO 10993-1 "Biological Evaluation of Medical Devices - Part 1: Evaluation and Testing Within a Risk Management Process," as recognized by FDA. A series of tests include the following tests:
-
ISO 10993-5 Third edition 2009-06-01, Biological evaluation of medical devices - Part 5: Tests for in vitro cytotoxicity.
-
ISO 10993-10Third Edition 2021-11, Biological evaluation of medical devices - Part 10: Tests for irritation and skin sensitization.
-
ISO 10993-23 First edition 2021-01, Biological evaluation of medical devices - Part 23: Tests for irritation.
Bench Testing:
Bench testing was conducted to validate intended performance of the Ear Pressure Relief Device:
- a. Dimensional verification
- b. Pressure value verification
- c. Flow rate verification
- d. Drop test verification
Software Verification and Validation Testing: This product does not include software.
6. Animal Study
Animal testing was not required for this submission.
7. Clinical Testing
Clinical testing was not required for this submission.
8. Conclusion
The biocompatibility, electrical safety, EMC, and bench testing conducted provide evidence that the proposed device performs comparable to the predicate device. The conclusions drawn from the nonclinical tests that demonstrate that the device is as safe, as effective, and performs as well as the predicate device.
N/A