(177 days)
These single use, disposable, flexible sheath injection needles are intended to be used for the injection of various types of media through flexible endoscopes.
The Carr-Locke and Articulator Injection Needles are single use, disposable, flexible sheath injection needles that are intended to be used for the injection of various types of media through flexible endoscopes. All the needles have the same general design and consist of a handle luer, a handle hypo tube, a compression spring (except for PN 00711808), a PEEK tube, a spring sheath, a distal hub and an injection needle.
The Carr-Locke and Articulator needles are sterile, disposable devices that are used through the working channel of flexible endoscopes for the purpose of injecting media into the gastrointestinal tract.
The information provided is about the substantial equivalence of the STERIS Articulator and Carr-Locke Injection Needles (K232826) to a predicate device. This document is a 510(k) summary, which focuses on comparing a new device to a legally marketed predicate device to demonstrate that it is as safe and effective. It does not describe a study involving algorithms, AI, or human reader performance.
Therefore, many of the requested items (e.g., sample size for test set, data provenance, number of experts, adjudication method, MRMC study, standalone study, type of ground truth used, training set sample size, ground truth for training set) are not applicable to this type of device and submission.
However, I can extract the acceptance criteria and device performance from the tables in the "Summary of Nonclinical Tests" section.
Acceptance Criteria and Device Performance
The STERIS Articulator and Carr-Locke Injection Needles (K232826) underwent nonclinical testing to demonstrate substantial equivalence to the predicate device. The following table summarizes the acceptance criteria and reported results:
| Testing Category | Testing | Acceptance Criteria | Reported Device Performance |
|---|---|---|---|
| Functional Testing | Working Length | Meet design requirements | Pass |
| Needle Deployment Length | Meet design requirements | Pass | |
| Needle Handle Luer Compatibility | Meet design requirements | Pass | |
| Luer Compatibility | Meet design requirements | Pass | |
| Needle Deployment Length After Cycles | Meet design requirements | Pass | |
| Device Insertion Force | Meet design requirements | Pass | |
| Device Extraction Force | Meet design requirements | Pass | |
| Pentax Needle Scope Compatibility | Meet design requirements | Pass | |
| Device Catheter Kink Criteria | Meet design requirements | Pass | |
| Ferrule to Needle Tensile Force | Meet design requirements | Pass | |
| PEEK to Needle Tensile Force | Meet design requirements | Pass | |
| Handle Hypo Tube to PEEK Tensile Force | Meet design requirements | Pass | |
| Handle Hypo Tube to Luer Tensile Force | Meet design requirements | Pass | |
| Distal Hub to Spring Sheath Tensile Force | Meet design requirements | Pass | |
| Spring Sheath to Handle | Meet design requirements | Pass | |
| Handle Hypo Tube to Washer Tensile Force | Meet design requirements | Pass | |
| Male Handle to Female Handle Tensile Force | Meet design requirements | Pass | |
| Injection Force Gauge Comparison | Meet design requirements | Pass | |
| Needle Deployment Force & Retraction | Meet design requirements | Pass | |
| Needle Leakage Test | Meet design requirements | Pass | |
| Simulated Use Testing | Endoscope Channel Compatibility | Meet design requirements | Pass |
| Pentax Endoscope Compatibility | Meet design requirements | Pass | |
| Duodenoscope Compatibility | Meet design requirements | Pass | |
| Needle Deployment and Retraction | Meet design requirements | Pass | |
| Needle Deployment Lock | Meet design requirements | Pass | |
| Device Functions in a Straight and Articulated Position | Meet design requirements | Pass | |
| Needle Patency | Meet design requirements | Pass | |
| Duodenoscope Injection Compatibility | Meet design requirements | Pass | |
| Needle Penetration | Meet design requirements | Pass | |
| Leakage Requirement | Meet design requirements | Pass | |
| Device Maintains Structural Integrity | Meet design requirements | Pass |
Study Information (Relevant to this type of device)
- Sample size used for the test set and the data provenance: The document does not specify the exact sample sizes (number of devices or tests performed) for each nonclinical test. It only states that testing was performed. Data provenance is not described as this is a device performance study, not a clinical trial or AI model validation.
- Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. The tests are engineering/performance evaluations, not clinical diagnoses requiring expert ground truth.
- Adjudication method for the test set: Not applicable for nonclinical device performance tests.
- 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: Not applicable. This is not an AI/imaging device.
- If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable. This is not an AI/algorithm.
- The type of ground truth used: For these nonclinical tests, the "ground truth" is defined by the "design requirements" which are established engineering and performance specifications for the device.
- The sample size for the training set: Not applicable. This is not an AI/machine learning device that requires a training set.
- How the ground truth for the training set was established: Not applicable.
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March 8, 2024
STERIS Carroll Martin Director, Regulatory Affairs 5976 Heislev Rd Mentor, Ohio 44060
Re: K2328
Trade/Device Name: Articulator Injection Needle (00711807), Articulator Injection Needle (00711810), Articulator Injection Needle - enteroscope (00711808), Carr-Locke Injection Needle (00711811), Carr-Locke Injection Needle (00711812), Carr-Locke Injection Needle (00711813), Carr-Locke Injection Needle (00711814), Carr-Locke Injection Needle (00711822), Carr-Locke Injection Needle (00711823), Carr-Locke Injection Needle (00711824) Regulation Number: 21 CFR 876.1500 Regulation Name: Endoscope and accessories Regulatory Class: Class II Product Code: FBK Dated: February 5, 2024 Received: February 6, 2024
Dear Carroll Martin:
We have reviewed your section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food. Drug. and Cosmetic Act (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 available 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
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Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).
Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30, Design controls; 21 CFR 820.90, Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).
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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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).
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Sincerely,
Shanil P. Haugen -S
Shanil P. Haugen, Ph.D. Assistant Director DHT3A: Division of Renal, Gastrointestinal, Obesity and Transplant Devices OHT3: Office of GastroRenal, ObGyn, General Hospital and Urology Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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Indications for Use
Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2023 See PRA Statement below.
Submission Number (if known)
Device Name
| Articulator Injection Needle (00711807); |
|---|
| Articulator Injection Needle (00711810); |
| Articulator Injection Needle - enteroscope (00711808); |
| Carr-Locke Injection Needle (00711811); |
| Carr-Locke Injection Needle (00711812); |
| Carr-Locke Injection Needle (00711813); |
| Carr-Locke Injection Needle (00711814); |
| Carr-Locke Injection Needle (00711822); |
| Carr-Locke Injection Needle (00711823); |
| Carr-Locke Injection Needle (00711824) |
Indications for Use (Describe)
These single use, disposable, flexible sheath injection needles are intended to be used for the injection of various types of media through flexible endoscopes.
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 For the Carr-Locke and Articulator Injection Needles K232826
STERIS Corporation 5960 Heisley Road Mentor, OH 44060 Phone: (440) 354-2600 Fax No: (440) 357-9198
Contact: Carroll Martin Director, Regulatory Affairs
Telephone: (440) 392-7437 Fax No: (440) 358-6259 e-mail: Carroll_Martin@steris.com
Summary Date: September 13, 2023
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K232826 Page 2 of 6
Device Name Articulator Injection Needle (00711807), Articulator Injection Needle (00711810), Articulator Injection Needle - enteroscope (00711808), Carr-Locke Injection Needle (00711811), Carr-Locke Injection Trade Name: Needle (00711812), Carr-Locke Injection Needle (00711813), Carr-Locke Injection Needle (00711814), Carr-Locke Injection Needle (00711822), Carr-Locke Injection Needle (00711823), Carr-Locke Injection Needle (00711824) Device Class: Class II Endoscopic Injection Needles Common/usual Name: Endoscope and accessories Regulation Name: 21 CFR 876.1500 Regulation Number: FBK Product Code:
2. Predicate Device
Sclerotherapy Needle K212668
Table 1. Device Comnarison Table for Carr-Locke and Articulator Needles and Predicate
| Feature | Sclerotherapy Needle(Predicate Device/K212688) | Carr-Locke and ArticulatorNeedles(Proposed Device) | Comparison |
|---|---|---|---|
| Intended Use | The device is used for endoscopicinjection into gastrointestinal mucosaor to endoscopically introduce asclerosing agent into selected sites tocontrol actual or potential bleedinglesions in the digestive system | These single use, disposable, flexiblesheath injection needles are intendedto be used for the injection of varioustypes of media through flexibleendoscopes. | Similar. Thepredicate devicementions a sclerosingagent, but this is atype of media that isinjected into thegastrointestinal tract,which both devicesare intended to do. |
| Construction | Luer connectorHandleInfusion tubeSheathFixed buttonConnection tubeNeedle | Handle luerHandleHandle hypo tubeCompression spring (all needlesexcept P/N 00711808)PEEK tubeSpring sheathDistal hubInjection needle | Similar. Although theproposed deviceshave a slightlydifferent design inparticular, the generaldesign of the devices,a luer connection, ahandle, a sheath, atube through whichthe media flows and aneedle are the same.The slight differencesdo not impact safety,effectiveness or howthe device is used. |
| Sheath Diameter | 1.8mm and 2.4mm | 1.8mm and 2.5mm | Similar. Thedifferences in sheathdiameter between thepredicate andproposed are minor.This minor differencedoes not impact |
| Feature | Sclerotherapy Needle(Predicate Device/K212688) | Carr-Locke and ArticulatorNeedles | Comparison |
| (Proposed Device) | safety, effectivenessor how the device is | ||
| used. | |||
| Needle Size | 19 gauge21 gauge23 gauge25 gauge | 23 gauge25 gauge | Same |
| Working Length | 1200mm1800mm2000mm2300mm | 2300mm3500mm | Similar. The 3500mmlength of theproposed device is toallow the device to beused in anenteroscopyendoscope. Testinghas shown that thisdifference has notimpact on safety,effectiveness or howthe device is used. |
| Packaging | Single-use EO sterilized paper-plasticpouch with one device per pouch | Single-use EO sterilized Tyvek-polyester/polyethylene film pouch.All devices are packaged 5 devices toa pouch except for P/Ns 00711810,00711823 and 00711824 which arepackaged 10 to a pouch. | Similar. Thepredicate and theproposed devices arepackaged in sterilizedpouches. The largernumber of devicespackaged for theproposed device doesnot impact safety,effectiveness or howthe devices are used. |
| Materials | Luer connector: ABSHandle: ABSInfusion tube: PPSheath: PTFEFixed button: Y12Cr18Ni9Cu3Connection tube:SUS304(06Cr19Ni10)Needle:X5CrNi18-9 | Luer: polycarbonateMale handle: ABS plastic with eithersilver or white colorantFemale handle: ABS plastic witheither silver or white colorantPEEK: 381G PEEKSpring Sheath: 303 stainless steelSpring Sheath coating (PNs00711811,00711812,00711813,00711814 and 00711822): PTFEwith green colorantHandle hypo tube: 304 stainless steelDistal hub: 303 stainless steelFerrule: 304 stainless steelCompression spring: steel music wire | Similar. Both thepredicate andproposed devicescontain stainlesssteel, ABS plastic,and PTFE. The maindifference is thecolorant present insome of the proposeddevices, but testingprovided in thissubmission show thatthe colorant does notimpact safety,effectiveness or howthe device is used. |
| Sterilization | Ethylene Oxide | Ethylene Oxide (SAL: 10-6) | Same |
| MethodPrinciple ofOperation | The catheter sheath of theproduct is inserted into theendoscope channel. When the frontpart of the catheter sheath is placed | The user threads the catheter of thedevice through the working channelof the endoscope. Once the needlehas been threaded through the | Same |
| Feature | Sclerotherapy Needle(Predicate Device/K212688) | Carr-Locke and ArticulatorNeedles(Proposed Device) | Comparison |
| on the lesion site, push the Luerconnector for injection, the needle isexposed to the catheter sheath, andthe needle is inserted into the lesionsite, then drug injection. | endoscope and the injection site hasbeen reached, the user can lock theneedle into the deployed position bypressing the proximal luer againstthe distal luer and then turning theproximal luer until it stops. Theneedle can then be inserted into themucosa of the gastrointestinal tract.Once the needle has been inserted,the desired injection media can beadministered to the patient via thedistal luer connection. Onceinjection is completed, the user canretract the needle and remove thedevice from the endoscope. |
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The proposed devices have the same intended use as the predicate with the same technological characteristics. Based on the testing in this submission, the minor physical differences do not impact safety, effectiveness or how the devices are used.
3. Description of Device
The Carr-Locke and Articulator Injection Needles are single use, disposable, flexible sheath injection needles that are intended to be used for the injection of various types of media through flexible endoscopes. All the needles have the same general design and consist of a handle luer, a handle hypo tube, a compression spring (except for PN 00711808), a PEEK tube, a spring sheath, a distal hub and an injection needle.
The Carr-Locke and Articulator needles are sterile, disposable devices that are used through the working channel of flexible endoscopes for the purpose of injecting media into the gastrointestinal tract. Once the device is unpackaged from the sterile packaging, the user can purge the needle assembly of air by attaching the injection container (i.e. a syringe) to the proximal luer and dispensing 0.5 - 0.75 ccs of media. After purging the device, the user ensures the needle is fully retracted into the catheter of the device by slowly twisting the proximal luer until it disengages from the distal luer. Once verified that the needle has been fully retracted into the catheter, the user threads the catheter through the working channel of the endoscope. Once the needle has been threaded through the endoscope and the injection site has been reached, the user can lock the needle into the deployed position by pressing the proximal luer against the distal luer and then turning the proximal luer until it stops. The needle can then be inserted into the mucosa of the gastrointestinal tract. Once the needle has been inserted, the desired injection media can be administered to the patient via the distal luer connection. Once injection is completed, the user can retract the needle by disengaging the proximal and distal luers and allowing the compression spring to pull the needle into the sheath or by
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physically grasping the proximal luer and pulling in the proximal direction until the needle enters the sheath (PN 00711808). Once the needle is retracted, the user can then remove the device from the endoscope.
4. Intended Use/Indications for Use
These single use, disposable, flexible sheath injection needles are intended to be used for the injection of various types of media through flexible endoscopes.
ર. Summary of Nonclinical Tests
The Carr-Locke and Articulator Injection needles have a similar intended use and the same technological characteristics. The minor design differences and minor differences in intended use do not raise different questions of safety and effectiveness as compared to the predicate device. Testing to assess and demonstrate substantial equivalence to the predicate is summarized below:
| Functional Testing | |||
|---|---|---|---|
| Testing | Acceptance Criteria | Results | |
| Working Length | Meet design requirements | Pass | |
| Needle Deployment Length | Meet design requirements | Pass | |
| Needle Handle Luer Compatibility | Meet design requirements | Pass | |
| Luer Compatibility | Meet design requirements | Pass | |
| Needle Deployment Length After Cycles | Meet design requirements | Pass | |
| Device Insertion Force | Meet design requirements | Pass | |
| Device Extraction Force | Meet design requirements | Pass | |
| Pentax Needle Scope Compatibility | Meet design requirements | Pass | |
| Device Catheter Kink Criteria | Meet design requirements | Pass | |
| Ferrule to Needle Tensile Force | Meet design requirements | Pass | |
| PEEK to Needle Tensile Force | Meet design requirements | Pass | |
| Handle Hypo Tube to PEEK Tensile Force | Meet design requirements | Pass | |
| Handle Hypo Tube to Luer Tensile Force | Meet design requirements | Pass | |
| Distal Hub to Spring Sheath Tensile Force | Meet design requirements | Pass | |
| Spring Sheath to Handle | Meet design requirements | Pass | |
| Handle Hypo Tube to Washer Tensile Force | Meet design requirements | Pass | |
| Male Handle to Female Handle Tensile Force | Meet design requirements | Pass | |
| Injection Force Gauge Comparison | Meet design requirements | Pass | |
| Needle Deployment Force & Retraction | Meet design requirements | Pass | |
| Needle Leakage Test | Meet design requirements | Pass |
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| Simulated Use Testing | |||
|---|---|---|---|
| Testing | Acceptance Criteria | Result | |
| Endoscope Channel Compatibility | Meet design requirements | Pass | |
| Pentax Endoscope Compatibility | Meet design requirements | Pass | |
| Duodenoscope Compatibility | Meet design requirements | Pass | |
| Needle Deployment and Retraction | Meet design requirements | Pass | |
| Needle Deployment Lock | Meet design requirements | Pass | |
| Device Functions in a Straight and Articulated Position | Meet design requirements | Pass | |
| Needle Patency | Meet design requirements | Pass | |
| Duodenoscope Injection Compatibility | Meet design requirements | Pass | |
| Needle Penetration | Meet design requirements | Pass | |
| Leakage Requirement | Meet design requirements | Pass | |
| Device Maintains Structural Integrity | Meet design requirements | Pass |
6. Conclusion
Based on the intended uses, technological characteristics and non-clinical performance data, the subject device is as safe, as effective and performs at least as well as the legally marketed predicate device K212668, Class II (21 CFR 876.1500), product code FBK.
§ 876.1500 Endoscope and accessories.
(a)
Identification. An endoscope and accessories is a device used to provide access, illumination, and allow observation or manipulation of body cavities, hollow organs, and canals. The device consists of various rigid or flexible instruments that are inserted into body spaces and may include an optical system for conveying an image to the user's eye and their accessories may assist in gaining access or increase the versatility and augment the capabilities of the devices. Examples of devices that are within this generic type of device include cleaning accessories for endoscopes, photographic accessories for endoscopes, nonpowered anoscopes, binolcular attachments for endoscopes, pocket battery boxes, flexible or rigid choledochoscopes, colonoscopes, diagnostic cystoscopes, cystourethroscopes, enteroscopes, esophagogastroduodenoscopes, rigid esophagoscopes, fiberoptic illuminators for endoscopes, incandescent endoscope lamps, biliary pancreatoscopes, proctoscopes, resectoscopes, nephroscopes, sigmoidoscopes, ureteroscopes, urethroscopes, endomagnetic retrievers, cytology brushes for endoscopes, and lubricating jelly for transurethral surgical instruments. This section does not apply to endoscopes that have specialized uses in other medical specialty areas and that are covered by classification regulations in other parts of the device classification regulations.(b)
Classification —(1)Class II (special controls). The device, when it is an endoscope disinfectant basin, which consists solely of a container that holds disinfectant and endoscopes and accessories; an endoscopic magnetic retriever intended for single use; sterile scissors for cystoscope intended for single use; a disposable, non-powered endoscopic grasping/cutting instrument intended for single use; a diagnostic incandescent light source; a fiberoptic photographic light source; a routine fiberoptic light source; an endoscopic sponge carrier; a xenon arc endoscope light source; an endoscope transformer; an LED light source; or a gastroenterology-urology endoscopic guidewire, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.(2) Class I for the photographic accessories for endoscope, miscellaneous bulb adapter for endoscope, binocular attachment for endoscope, eyepiece attachment for prescription lens, teaching attachment, inflation bulb, measuring device for panendoscope, photographic equipment for physiologic function monitor, special lens instrument for endoscope, smoke removal tube, rechargeable battery box, pocket battery box, bite block for endoscope, and cleaning brush for endoscope. The devices subject to this paragraph (b)(2) are exempt from the premarket notification procedures in subpart E of part 807of this chapter, subject to the limitations in § 876.9.