(187 days)
The device is designed for using suction to remove nasal secretion and mucus in Children (age 2~12 years old) at home environment.
The additional spray/irrigation function helps moisten and loosen/soften nasal secretions in Children (over 3 years old), making them easier to aspirate.
This AViTA nasal aspirator (Model NS13) consists of a pump that can generate negative pressure suction, a silicone tip for contacting the nostrils, a collecting nasal mucus, a sprayer head module for moistening the nasal cavity, and two buttons that activate suction and sprayer functions. This nasal aspirator is powered by two AAA batteries. The accessories are the batteries, silicone tips.
The provided text describes the performance testing and validation for the AViTA Nasal Aspirator (Model NS13). However, it does not contain the specific details required to fully address all parts of your request, particularly regarding acceptance criteria for a "device" in the context of an AI/ML medical device. This document describes a physical medical device (nasal aspirator), not an AI/ML algorithm. Therefore, many of your questions related to AI/ML specific criteria (such as "sample size for the training set," "number of experts used to establish ground truth," "MRMC comparative effectiveness study," etc.) are not applicable to the information provided.
Based on the provided text, here's what can be extracted and inferred:
1. A table of acceptance criteria and the reported device performance
The document lists performance specifications for the device and indicates that testing was conducted to demonstrate these specifications were met. While it doesn't provide a direct "acceptance criteria vs. reported performance" table for each specific parameter, it states that "The results of those testing show that the required limits for mean difference and standard deviation are fulfilled by the subject device."
| Criterion Category | Specifics Mentioned in Document | Performance/Compliance Statement |
|---|---|---|
| Biocompatibility | - In vitro cytotoxicity (ISO 10993-5) - Irritation and skin sensitization (ISO 10993-10) - Systemic toxicity (ISO 10993-11) - Irritation (ISO 10993-23) | "The biocompatibility evaluation and testing of the Product name was conducted in accordance with the following standards and guidance... [and passed]." |
| Cleaning and Disinfecting | - 1000 times cleaning verification with mild non-abrasive soap and 70℃ water and soft dry cloth wiping | "This product has passed the cleaning verification... confirming that the product can be used continuously without any functional abnormalities." |
| Safety (Electrical/Medical Device Standards) | - IEC 60601-1:2005+A1:2012 (Medical electrical equipment - General requirements for basic safety and essential performance) - IEC 60601-1-11:2010 (Medical electrical equipment - Requirements for medical electrical systems used in the home healthcare environment) | "the subject device has passed the relevant tests of IEC 60601-1" and "has passed the relevant tests in accordance with IEC 60601-1-11" |
| Software Verification and Validation | - "Basic documentation" level of concern | "Software verification and validation testing were conducted and documentation was provided as recommended by FDA's Guidance..." |
In the comparison table on page 8, the subject device's performance specifications are listed, which can be interpreted as its target acceptance criteria for technical performance:
| Parameter | Acceptance Criteria (Subject Device NS13) | Reported Performance (Assumed to meet criteria) |
|---|---|---|
| Effective Vacuum Pressure | 100-120 mmHg | Assumed to be 100-120 mmHg |
| Sound Pressure Level | ≤60dB | Assumed to be ≤60dB |
| Spray Capacity | 0.4 | Assumed to be 0.4 |
| Operating Temperature Range | 16°C ~ 35°C (60.8°F ~ 95°F), 15%~85% RH | Assumed to operate within this range |
| Storage Temperature Range | -25°C ~ 55°C (-13°F ~ 131°F), 15%~85% RH | Assumed to store within this range |
2. Sample sized used for the test set and the data provenance
The document does not specify "sample size" in terms of patient data or clinical study cohorts, as this is a K510 submission for a physical device, not an AI/ML algorithm. The performance testing refers to engineering and laboratory tests on the device itself.
- Data Provenance: Not applicable in the sense of patient data. The tests are conducted on the device hardware and software.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable. Ground truth as typically defined for AI/ML (e.g., expert labels on medical images) is not relevant for the testing of this physical nasal aspirator. The "ground truth" here is the adherence to established technical standards and engineering specifications.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. This is not a study involving human adjudication of results in the context of an AI/ML algorithm.
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
Not applicable. No MRMC study was performed as this is not an AI-assisted diagnostic device. The document explicitly states "Clinical Studies None."
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This is a physical device, not an AI algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
The "ground truth" for this device's performance is adherence to established international standards (e.g., ISO, IEC) for biocompatibility, electrical safety, and general performance, as well as the manufacturer's own internal specifications (e.g., vacuum pressure, sound level).
8. The sample size for the training set
Not applicable. This is not an AI/ML device that requires a training set.
9. How the ground truth for the training set was established
Not applicable.
Summary of the Study Proving Device Meets Acceptance Criteria:
The document states that the AViTA Nasal Aspirator (Model NS13) meets its acceptance criteria through a series of non-clinical performance tests, biocompatibility tests, cleaning and disinfecting tests, and safety tests (electrical and general).
- Non-Clinical Performance Testing: Implied to include assessments of vacuum pressure, sound level, spray capacity, and operating/storage conditions. The document states these tests "show that the required limits for mean difference and standard deviation are fulfilled."
- Biocompatibility Testing: Conducted in accordance with recognized ISO 10993 standards (Parts 5, 10, 11, and 23) for cytotoxicity, irritation, skin sensitization, and systemic toxicity. The device "passed" these evaluations.
- Cleaning and Disinfecting Test: The device underwent "1000 times" of cleaning verification, confirming its ability for continuous use without functional abnormalities.
- Safety Testing: Compliance with IEC 60601-1 and IEC 60601-1-11 for basic safety and essential performance, particularly for home healthcare environments, was verified. The device "passed" these relevant tests.
- Software Verification and Validation: Performed according to FDA guidance for "Basic documentation" level of concern software in medical devices, demonstrating the software performs as intended.
The overall conclusion is that these non-clinical data support the device's safety and effectiveness, and its comparable performance to predicate devices already on the market.
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Image /page/0/Picture/0 description: The image contains two logos. On the left is the Department of Health & Human Services logo. On the right is the FDA logo, which includes the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.
December 31, 2024
AViTA Corporation Maggie Chao Adm. Manager 9F, No.78, Sec.1, Kwang Fu Road, Sanchong Dist. New Taipei City, 24158 Taiwan
Re: K241852
Trade/Device Name: Nasal Aspirator (NS13) Regulation Number: 21 CFR 878.4780 Regulation Name: Powered Suction Pump Regulatory Class: Class II Product Code: BTA, KMA Dated: December 2, 2024 Received: December 2, 2024
Dear Maggie Chao:
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 (the 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 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"
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(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 OS 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.
All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rue"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-devices/device-advicecomprehensive-regulatory-assistance/unique-device-identification-system-udi-system.
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 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).
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Sincerely,
Joyce C. Lin -S
for 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 Quality Center for Devices and Radiological Health
Enclosure
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Indications for Use
Submission Number (if known)
Device Name
Nasal Aspirator (NS13)
Indications for Use (Describe)
The device is designed for using suction to remove nasal secretion and mucus in Children (age 2~12 years old) at home environment.
The additional spray/irrigation function helps moisten and loosen/soften nasal secretions in Children (over 3 years old), making them easier to aspirate.
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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Image /page/4/Picture/1 description: The image shows the logo for AViTA. The logo consists of the word "AViTA" in blue, with a stylized heart shape to the right. The heart is colored in three sections: the top is yellow, the bottom is red, and the right side is green. There is a registered trademark symbol to the bottom right of the heart.
AVITA CORPORATION
510(k) Submission for AViTA Nasal Aspirator
510(K) Summary
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Image /page/5/Picture/0 description: The image shows the logo for AViTA. The logo features the word "AViTA" in blue, with the "i" dotted with a yellow semi-circle. The word is set to the left of a heart shape, which is formed by a red curve at the bottom and a green curve at the top and right. A registered trademark symbol is located at the bottom right of the heart.
| Applicant: | AVITA Corporation |
|---|---|
| Address: | 9F, No.78, Sec.1, Kwang-Fu Rd., San-Chung District, New TaipeiCity 24158, Taiwan |
| Applicant Establishment Number: | 9617543 |
| Applicant Contact: | Maggie Chao |
| Email: | Maggie_chao@avita.com.tw |
| Phone Number: | +886-2-8512-1568 |
| Fax Number: | +886-2-8512-1347 |
| Date of Submission: | November 28, 2024 |
DEVICE
| Trade/Proprietary Name: | AViTA Nasal Aspirator |
|---|---|
| Common Name: | Nasal Aspirator |
| Model: | NS13 |
| Review Panel: | General & Plastic Surgery |
| Classification Product Code: | BTA KMA |
| Regulation Number: | 870.4780- Powered suction pump |
| Device Class: | II |
DEVICE DESCRIPTION
This AViTA nasal aspirator (Model NS13) consists of a pump that can generate negative pressure suction, a silicone tip for contacting the nostrils, a collecting nasal mucus, a sprayer head module for moistening the nasal cavity, and two buttons that activate suction and sprayer functions. This nasal aspirator is powered by two AAA batteries. The accessories are the batteries, silicone tips.
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Image /page/6/Picture/0 description: The image shows the logo for AViTA. The logo consists of the word "AViTA" in blue, with a heart shape to the right. The heart shape is made up of three different colors: yellow at the top, red at the bottom, and green on the right side. There is also a registered trademark symbol to the bottom right of the heart.
INDICATIONS FOR USE
The device is designed for using suction to remove nasal secretion and mucus in children (age 2~12 years old) at home environment.
The additional spray function helps moisturize and soften nasal secretions in children (over 3 years old), making them easier to aspirate.
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Image /page/7/Picture/0 description: The image shows the logo for AVITA. The logo has the word "AVITA" in blue font on the left side of the image. To the right of the word is a heart shape that is made up of three different colors: yellow, red, and green.
COMPARISON WITH PREDICATE DEVICE
| Item | Subject(AVITA Nasal Aspirator NS13) | Predicate(AVITA Nasal Aspirator NS1 Series) | Predicate(Geonic Nasal Cleaner) |
|---|---|---|---|
| K number | - | K090379 | NA |
| Classification | 21CFR 878.4780 | 21CFR 878.4780 | 21 CFR 874.5550 |
| Product code | BTA | BTA | KMA |
| FDA class | II | II | I |
| Intended use | The device is designed for using suction to remove nasalsecretion and mucus in Children (age 2~12 years old) at homeenvironment. The additional spray/irrigation function helpsmoisten and loosen/soften nasal secretions in Children (over 3years old), making them easier to aspirate. | The device is designed for using intermittent suction to removenasal secretion and mucus in Children (age 2-12 years old) athome environment. | Geonic Nasal Cleaner (Model Name:H2) additionally providepositivepressure to moisturize the nasal cavitiesby using saline solution in the form ofspray for adults and pediatrics (3 yearsold). The nasal cleaner is intended forover-the-counter (OTC) use at homeenvironment. |
| EffectiveVacuum Pressure | Vacuum Pressure: 100-120 mmHg | Max.120mmHg | N/A |
| Optional Levels | N/A | N/A | N/A |
| SoundPressure Level | ≤60dB | 65±3dB | N/A |
| Spray Capacity | 0.4 | N/A | 5 ml/min |
| OperatingTemperature Range | 16°C ~ 35°C(60.8°F ~ 95°F)15%~85% RH | 15°C ~ 40°C<95% RH | 5°C ~ 40°C (41°F~104°F)RH15%~90% 700-1060pa |
| Storage TemperatureRange | - 25°C ~ 55°C(-13°F ~ 131°F) | - 20°C ~ 50°C<95% RH | -25°C ~ 70°C(-13°F~158°F) |
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| 15%~85% RH2 x 1.5V AAA batteriesABS | 2 x 1.5V AA batteriesABS | RH up to 90% | ||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| A Power Requirements | 3.7 V Li-ion rechargeable battery | |||||||||||||
| Housing ® | ABS | |||||||||||||
| Storage pouch | No | No Traditional 510(k) | No | |||||||||||
| Unit Weight | Approx.158g(Exclude batteries) | approx.250g(Exclude batteries) | N/A | |||||||||||
| Tip type | Picture | Suggestions for use: | Depth: | Size: OD x D x L (mm) | Tip type | Picture | Suggestions for use: | Depth: | Size: OD x D x L (mm) | |||||
| Gourd shape tip | Image: Gourd shape tip | With a stopper that does not go deep into. | Shallow | $Ф5хФ2.6x35.68$ | Long tip | Image: Long tip | Recommended for use when mucus is thinner. | Deep | $Ф4.02 x Ф2.6 x 28.0$ | |||||
| Long tip | Image: Long tip | Recommended for use when mucus is thinner. | Deep | $Ф5хФ3х35.68$ | Short tip | Image: Short tip | Recommended for use when mucus is thick. | Medium | $Ф6.23 x Ф2.0 x 22.2$ | |||||
| Tips Information | Short tip | Image: Short tip | Recommended for use when mucus is thick. | Medium | $Ф5.68хФ3х27.68$ | N/A | ||||||||
| OD: outside diameter / D: diameter | ||||||||||||||
| OD: outside diameter / D: diameter | ||||||||||||||
| NS13 tip type based on the anticipated use. These three types of tips are suitablefor children aged 2 to 12 years. |
Comparison:
The proposed device and the predicated device have the same principle. There is no additional question of safety and effectiveness as compared to the predicate device.
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Image /page/9/Picture/1 description: The image shows the logo for AViTA. The logo has the word "AViTA" in blue, with a heart shape behind it. The top of the heart is yellow, the right side is green, and the bottom left is red. There is a registered trademark symbol in the bottom right corner of the heart.
There is a device currently on the US market that has the same clinical and biological characteristic as the subject device AVITA Nasal Aspirator NS 13.
In Clinical terms, Subject Device and Predicate device have the same intended uses for moistening and clearing nasal congestion and are applicable to the same patient groups, users, and usage environments. In Technical terms, the two have exactly the same working principle and performance specifications. In Biological terms, the parts that contact the human body are exactly the same in terms of materials, process, contact time and contact location.
The following technological differences exist between the subject and predicate devices:
-
About clinical difference (differences in intended use) ।
Regarding the intended use there no difference. -
About technical difference (differences in Power Supply, Dimensions, Weight, Spray Capacity and Number of Push Button)
Regarding the difference in power requirement, the subject device has passed the relevant tests of IEC 60601-1.
The differences in dimensions, weight, number of push button and spray capacity do not affect the device's safety and effectiveness, as the subject device has passed the relevant tests in accordance with IEC 60601-1-11, and these aspects have been verified through the relevant performance tests.
In conclusion, the difference in power requirement, dimensions, weight, spray capacity and number of push button do not affect product performance.
Performance testing has been completed to demonstrate that the Subject device, AVITA Nasal Aspirator NS 13 is substantially equivalent to the Predicate device. AVITA Nasal Aspirator NS 1 Series and Geonic Nasal Cleaner.
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Image /page/10/Picture/1 description: The image shows the logo for AViTA. The logo consists of the word "AViTA" in blue, with a stylized heart shape to the right. The heart is colored with three different colors: yellow at the top, green in the middle, and red at the bottom. The registered trademark symbol is located at the bottom right of the heart.
PERFORMANCE DATA
Performance testing has been carried out to demonstrate that this device meets the performance specifications for its intended use. The following tests were performed on the device. The results of those testing show that the required limits for mean difference and standard deviation are fulfilled by the subject device.
Biocompatibility testing
The biocompatibility evaluation and testing of the Product name was conducted in accordance with the following standards and guidance, as recognized by the FDA:
- FDA Draft Guidance Use of International Standard ISO- 10993, "Biological Evaluation of - Medical Devices, Part 1: Evaluation and Testing".
- -ISO 10993-5, Biological evaluation of medical devices- Part 5: Tests for in vitro cytotoxicity
- 10993-10, Biological evaluation of medical devices- Part 10: Tests for irritation and skin sensitization
- ISO 10993-11. Biological evaluation of medical devices- Part 11: Tests for systemic toxicity. -
- -ISO 10993-23, Biological evaluation of medical devices- Part 23: Test for irritation.
Cleaning and Disinfecting Test
The Nasal Aspirator is a medical device that does not supply sterilized. This product has passed the cleaning verification of 1000 times with mild mom-abrasive soap and 70℃ water and soft dry cloth wiping, confirming that the product can be used continuously without any functional abnormalities.
Safety Test:
- -IEC 60601-1:2005+A1:2012, Medical electrical equipment - Part 1: General requirements for basic safety and essential performance
- -IEC 60601-1-11:2010, Medical electrical equipment-Part 1-11: General Requirement for basic safety and essential performance- Collateral Standard: Requirements for medical electrical systems used in the home healthcare environment
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Image /page/11/Picture/0 description: The image shows the logo for AViTA. The logo consists of the word "AViTA" in blue, with a stylized heart shape surrounding it. The heart shape is made up of three different colors: yellow at the top, red at the bottom left, and green on the right side. There is also a registered trademark symbol to the right of the heart.
Software Verification and Validation Testing
Software verification and validation testing were conducted and documentation was provided as recommended by FDA's Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices." The software for this device was considered as a "Basic documentation" level of concern, since a failure or latent flaw in the software could not directly result in serious injury or death to the patient or operator.
Clinical Studies None
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Image /page/12/Picture/0 description: The image shows the logo for AViTA. The logo has the text "AViTA" in blue, with a stylized heart shape around it. The heart shape is made up of three different colored sections: yellow at the top, red at the bottom, and green on the right side. There is a registered trademark symbol to the right of the heart.
CONCLUSION
The substantial equivalence is supported by the results of non-clinical performance testing, labeling and other provided data. The non-clinical data supports the safety of the device and the hardware and software verification and validation demonstrate that the AViTA Nasal Aspirator NS 13 should perform as intended in the specified use conditions and performs comparably to the predicate device that is currently marketed for the same intended use.
§ 878.4780 Powered suction pump.
(a)
Identification. A powered suction pump is a portable, AC-powered or compressed air-powered device intended to be used to remove infectious materials from wounds or fluids from a patient's airway or respiratory support system. The device may be used during surgery in the operating room or at the patient's bedside. The device may include a microbial filter.(b)
Classification. Class II.