(107 days)
The ProSeal™ Closed System drug Transfer Device (CSTD) mechanically prohibits environmental contaminants from entering the system and the escape of drug or vapor concentrations from thereby minimizing individual and environmental exposure to drug vapor, aerosols, and spills. The ProSeal™ system also prevents the introduction of microbial contaminations into the drug or fluid path for up to 7 days when used as intended.
The ProSeal™ CSTD is a sterile, single-use, pyrogen-free CSTD for the preparation, reconstitution, compounding, and administration of antineoplastic and hazardous drugs, intended for use in clinical settings by trained health care professionals and/or pharmacists.
The ProSeal™ Closed System Bag Access is a component of the ProSeal™ CSTD system which is intended for connection to a standard I.V. bag and appropriate ProSeal™ CSTD component devices for the injection and infusion of I.V. infusion fluids. It is an adaptor between IV bags and ProSeal™ CSTD components for closed system fluid transfer into and out of the I.V. bag. The Subject bag access is compatible with the ProSeal™ Injector or the ProSeal™ Injector Plus (cleared K240171) and other ProSeal™ component devices, e.g. ProSeal™ Closed System Administration Set (for infusion from the I.V. bag). The ProSeal™ Closed System Bag Access and all its corresponding interface membranes exhibit a dry connection with the communicating surfaces in a fluid transfer. The use of this component device and its appropriate ProSeal CSTD connecting component device reduces the risk of microbial ingress for up to 168 hours or 7 days, when used as intended.
The closed transfer of liquid that takes place with the use of the ProSeal™ CSTD system as follows:
- A double membrane septum design utilizing self-sealing elastomeric membranes tightly fits . together when the system components engage. A cannula within the ProSeal™ Injector Plus housing perforates the double membranes for the transfer of liquid. When the cannula is retracted, the membranes seal off the transfer of environmental contaminants into the system and/or escape of drug or vapor concentrations outside the system, thereby minimizing the individual and environmental exposure to drug vapor, aerosols, and spills, and also minimizing the risk of microbial contamination, when used as intended.
Based on the provided FDA 510(k) summary for the ProSeal™ Closed System Bag Access (K241988), here's a breakdown of the acceptance criteria and the study that proves the device meets them:
Disclaimer: This document is a 510(k) summary, which provides an overview of the substantial equivalence determination. It does not contain the full details of all the studies performed. Therefore, specific quantitative performance metrics beyond what is explicitly stated for acceptance and observed results are not available in this summary.
1. Table of Acceptance Criteria and Reported Device Performance
The provided document describes functional performance, biocompatibility, sterility, shipping, and shelf-life testing. While specific quantitative acceptance criteria are not explicitly listed in a single table with corresponding numerical results, the document states conformance to various ISO and FDA recognized standards. The "Comment/Discussion" column in the comparison table indicates "Same" or "Similar" for many characteristics, implying that the acceptance criteria are met by demonstrating equivalence to the predicate device and adherence to standards.
For functional performance, the document lists the following tests and their corresponding standards, implying that meeting these standards constitutes the acceptance criteria. The performance data "supporting substantial equivalence" suggests that the device met these criteria.
| Acceptance Criteria (Implied by Standard Conformance) | Reported Device Performance (Implied) |
|---|---|
| Functional Performance | |
| Leak integrity (per ISO 8536-4:2019, 7.2 & A.3) | Bench performance verifications and validations performed, indicating conformance. |
| Tensile strength (per ISO 8536-4:2019, 7.3 & A.4) | Bench performance verifications and validations performed, indicating conformance. |
| Penetration force (per ISO 22413:2021, 6.6 & A.7) | Bench performance verifications and validations performed, indicating conformance. |
| Protective caps (per ISO 8536-4:2019, 7.13) | Bench performance verifications and validations performed, indicating conformance. |
| Vapor containment (per NIOSH CSTD 2016 draft protocol) | "from testing data on devices cleared under K222929" (implying met, as K222929 was cleared) |
| Microbial ingress (per FDA guidance & ANSI AAMI CN27:2021) | "from testing data on devices cleared under K222929" (implying met, as K222929 was cleared and previous devices established "up to 7 days" prevention) |
| Biocompatibility (Classified: Externally Communicating Device, Blood Path Indirect, Prolonged Contact) | |
| Cytotoxicity (per ISO 10993-5) | Performed on referred-to cleared devices (K222929), implying met. |
| Sensitization (per ISO 10993-10) | Performed on referred-to cleared devices (K222929), implying met. |
| Intracutaneous Reactivity (per ISO 10993-10) | Performed on referred-to cleared devices (K222929), implying met. |
| Acute Systemic Toxicity (per ISO 10993-11) | Performed on referred-to cleared devices (K222929), implying met. |
| 14-day Subacute/Subchronic Acute Systemic Toxicity (per ISO 10993-11) | Performed on referred-to cleared devices (K222929), implying met. |
| In-vitro Hemolysis Assessment (per ISO 10993-4) | Performed on referred-to cleared devices (K222929), implying met. |
| Material Mediated Pyrogenicity (per ISO 10993-11) | Performed on referred-to cleared devices (K222929), implying met. |
| Particulate matter (per ISO 8536-4:2019 and USP <788>) | Testing conducted on Subject device, implying met. |
| Sterility & Shelf-Life | |
| Sterilization (per ISO 11135:2014, SAL 10-6) | Complies with standard, testing/evaluations conducted on K222929, implying met. |
| Simulated shipping (per ASTM D 4169-16) | Testing conducted, implying met. |
| Package integrity (per ASTM F1980-21, F88/F88M-21, F1929-23, EN 868-5:2009) | Testing performed, implying met. |
| Pyrogen Tests (per ANSI/AAMI ST72/2019, USP <151>, <161>, <85>) | Testing conducted "on every lot", implying met. |
| Shelf-life (3 years) | Validated using ASTM 1980-21, implying met. |
2. Sample Sizes Used for the Test Set and Data Provenance
The document does not explicitly state the specific sample sizes used for each of the functional performance, biocompatibility, or sterility tests. It refers to various ISO and ASTM standards, which typically prescribe minimum sample sizes for such tests.
- Data Provenance: The document states "Bench performance verifications and validations referred-to and performed" and "testing data on devices cleared under K222929." This indicates that the testing was primarily benchtop testing (laboratory-based) and retrospective, leveraging data from previously cleared devices within the ProSeal™ CSTD system (specifically K222929). There is no mention of data provenance by country of origin or specific patient data since the studies are physical/chemical rather than clinical.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
This section is Not Applicable to this 510(k) submission. The device is a physical medical device (intravascular administration set component), not an AI/ML diagnostic or image analysis device that requires expert human interpretation to establish ground truth from medical images or clinical data. Its performance is evaluated through physical, mechanical, and biological testing against established standards.
4. Adjudication Method for the Test Set
This section is Not Applicable. Adjudication methods (like 2+1, 3+1 consensus) are typically used in clinical studies involving human interpretation or subjective assessments, especially for AI/ML devices where ground truth might be derived from multiple expert opinions. For a physical device undergoing performance and safety testing against objective engineering and biological standards, such adjudication is not relevant.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done, Effect Size of how much Human Readers Improve with AI vs. without AI Assistance
This section is Not Applicable. An MRMC study is relevant for diagnostic or AI-assisted diagnostic devices that evaluate human reader performance. The ProSeal™ Closed System Bag Access is a hardware component for drug transfer and does not involve human readers interpreting medical cases.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done
This section is Not Applicable. This concept applies to AI/ML software. The ProSeal™ Closed System Bag Access is a physical device component.
7. The Type of Ground Truth Used
The "ground truth" for this device's performance is established by conformance to internationally recognized performance standards (e.g., ISO, ASTM, USP, ANSI/AAMI) for medical devices, specifically for intravascular administration sets and closed system transfer devices. This includes:
- Engineering/Physical Standards: Defining acceptable ranges for leak integrity, tensile strength, penetration force, package integrity, etc.
- Biological Standards: Defining acceptable levels for biocompatibility (cytotoxicity, sensitization, systemic toxicity, hemolysis, pyrogenicity) and sterility.
- Functional Claim Validation: Demonstration of preventing microbial ingress and vapor containment as defined by specific test protocols (e.g., microbial ingress test, vapor containment test).
8. The Sample Size for the Training Set
This section is Not Applicable. The product is a physical medical device, not an AI/ML algorithm. Therefore, there is no "training set" in the machine learning sense. The design and manufacturing processes are validated through engineering principles and compliance with quality systems (e.g., 21 CFR Part 820).
9. How the Ground Truth for the Training Set Was Established
This section is Not Applicable for the same reason as point 8.
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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 and Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
October 23, 2024
Epic Medical Pte. Ltd. Freddie Lee CEO/md 105 Cecil Street #20-04, The Octagon Singapore, 069534 Singapore
Re: K241988
Trade/Device Name: ProSeal™ Closed System Bag Access Regulation Number: 21 CFR 880.5440 Regulation Name: Intravascular Administration Set Regulatory Class: Class II Product Code: ONB Dated: September 23, 2024 Received: September 23, 2024
Dear Freddie Lee:
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" (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).
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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 Rule"). 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-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,
Porsche Bennett
Porsche Bennett For David Wolloscheck, Ph.D. Assistant Director DHT3C: Division of Drug Delivery and General Hospital Devices, and Human Factors 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
510(k) Number (if known) K241988
Device Name ProSeal™ Closed System Bag Access
Indications for Use (Describe)
The ProSeal™ Closed System drug Transfer Device (CSTD) mechanically prohibits environmental contaminants from entering the system and the escape of drug or vapor concentrations from thereby minimizing individual and environmental exposure to drug vapor, aerosols, and spills. The ProSeal™ system also prevents the introduction of microbial contaminations into the drug or fluid path for up to 7 days when used as intended.
| 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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CDIL
K241988 – 510(k) Summary
I. Submitter
Epic Medical Pte. Ltd. 105 Cecil Street #20-04, The Octagon, Singapore 069534. Phone: +65 9635 2618 / +66 81 761 5292 Contact Person: Mr. Freddie LEE, Chief Executive Officer/ Managing Director Date Prepared: October 23, 2024 Content and Format: Prepared in accordance with 21 CFR 807.92 Type of Submission: Traditional
II. Subject Device
| 510(k) Number: | K241988 |
|---|---|
| Trade/ Device Name: | ProSeal™ Closed System Bag Access |
| Common/ Usual Name: | Closed Antineoplastic and Hazardous Drug Reconstitution andTransfer System |
| Regulation Number: | 21 CFR 880.5440 |
| Regulation Name: | Intravascular administration set |
| Regulatory Class: | Class: II |
| Product Code: | ONB |
III. Predicate
| 510(k) Number: | K201460 |
|---|---|
| Trade/ Device Name: | Closed System Transfer Device |
| Common/ Usual Name: | Closed Antineoplastic and Hazardous Drug Reconstitution andTransfer System |
| Regulation Number: | 21 CFR 880.5440 |
| Regulation Name: | Intravascular administration set |
| Regulatory Class: | Class: II |
| Product Code: | ONB |
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IV. Device Description
The ProSeal™ CSTD is a sterile, single-use, pyrogen-free CSTD for the preparation, reconstitution, compounding, and administration of antineoplastic and hazardous drugs, intended for use in clinical settings by trained health care professionals and/or pharmacists.
The ProSeal™ Closed System Bag Access is a component of the ProSeal™ CSTD system which is intended for connection to a standard I.V. bag and appropriate ProSeal™ CSTD component devices for the injection and infusion of I.V. infusion fluids. It is an adaptor between IV bags and ProSeal™ CSTD components for closed system fluid transfer into and out of the I.V. bag. The Subject bag access is compatible with the ProSeal™ Injector or the ProSeal™ Injector Plus (cleared K240171) and other ProSeal™ component devices, e.g. ProSeal™ Closed System Administration Set (for infusion from the I.V. bag). The ProSeal™ Closed System Bag Access and all its corresponding interface membranes exhibit a dry connection with the communicating surfaces in a fluid transfer. The use of this component device and its appropriate ProSeal CSTD connecting component device reduces the risk of microbial ingress for up to 168 hours or 7 days, when used as intended.
The closed transfer of liquid that takes place with the use of the ProSeal™ CSTD system as follows:
- A double membrane septum design utilizing self-sealing elastomeric membranes tightly fits . together when the system components engage. A cannula within the ProSeal™ Injector Plus housing perforates the double membranes for the transfer of liquid. When the cannula is retracted, the membranes seal off the transfer of environmental contaminants into the system and/or escape of drug or vapor concentrations outside the system, thereby minimizing the individual and environmental exposure to drug vapor, aerosols, and spills, and also minimizing the risk of microbial contamination, when used as intended.
V. Indications for Use Statement
The ProSeal™ Closed System drug Transfer Device (CSTD) mechanically prohibits environmental contaminants from entering the system and the escape of drug or vapor concentrations from the system, thereby minimizing individual and environmental exposure to drug vapor, aerosols, and spills. The ProSeal™ system also prevents the introduction of microbial contaminations into the drug or fluid path for up to 7 days when used as intended.
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Comparison of Intended Use & Technological Characteristics VI.
The Subject device and the Predicate device share the following similar characteristics:
Intended Use comparison
-
- Indications for use statements
-
- Primary product code and regulation number
-
- Intended user population/ intended use environment
Technological characteristics comparison Equivalencies - Technology & Design
The ProSeal" Closed System Bag Access and the Predicate device share the following similar design characteristics, and from the evaluation in the comparison table, there was no substantial difference from the Predicate device identified, that would raise a different question of safety or effectiveness:
-
- Principles of operation
-
- Number of access points
-
- Intended connector type to be used with the bag spike adapter
-
- Safety feature to prevent microbial contamination
- An overview table summarizing the comparison between the Subject and the Subject and the Predicate device is provided hereunder.
| Characteristiccompared | Predicate Device (K201460)CSTD - Spike Adapter | Subject Device (K241988)ProSeal™ Closed System Bag Access | Comment/Discussion |
|---|---|---|---|
| Intended useandIndications for Usestatement | "The Closed System Transfer Device (CSTD) forpreparation, reconstitution, compounding andadministration of drugs, includingantineoplastic and hazardous drugs. This closedsystem mechanically prohibits the transfer ofenvironmental contaminants into the systemand the escape of drug or vapor concentrationsoutside the system, thereby minimizingindividual and environmental exposure to drugvapor, aerosols, and spills and also preventsmicrobial ingress." | "The ProSeal™ Closed System drug TransferDevice (CSTD) mechanically prohibitsenvironmental contaminants from entering thesystem and the escape of drug or vaporconcentrations from the system, therebyminimizing individual and environmentalexposure to drug vapor, aerosols, and spills.The ProSeal™ system also prevents theintroduction of microbial contaminations intothe drug or fluid path for up to 7 days whenused as intended." | Similar |
| Characteristiccompared | Predicate Device (K201460)CSTD - Spike Adapter | Subject Device (K241988)ProSeal™ Closed System Bag Access | Comment/Discussion |
| Primary product codeand regulation number | ONB21 CFR 880.5440 | ONB21 CFR 880.5440 | Same |
| Intended userpopulation/ intendeduse environment | Adequately trainedhealth care professionals including pharmacists/clinical setting | Adequately trainedhealth care professionals including pharmacists/clinical setting | Same |
| Intended drug type | Parenteral drugs | Parenteral drugs | Same |
| Single use or reusable | Single use only | Single use only | Same |
| Principlesof operation | Infusion bag is connected with spike adapter,then in order to realize the connectionbetween infusion bag and spike adaptor, theyare connected with the matching end of thedispensing connector.All system components are sealed withresealing membranes, and elastomeric doublemembrane technology is used to ensure thatthere is no drug leakage at the connectingparts during the dispensing process. As closedInfusion Set, the working principle of theinfusion set is gravity infusion, which isconnected with the indwelling needle or otherconnector(s). Under the action of gravity, themedicine is infused into human blood vesselsthrough the infusion tube. | The infusion bag is connected with the bagaccess and, in order to create a fluid pathconnection between the infusion bag and thebag access, they are connected with thematching end of the ProSeal Injector orInjector Plus (K240171).All system components are sealed with self-resealing membranes incorporatingelastomeric double membrane technology thatfeatures airtight and leakage-proofconnections during the fluid transfer process.Transfer is performed through the connectionof an I.V. set with indwelling needle of theProSeal Injector (or Injector Plus) connector,e.g. the ProSeal Closed System AdministrationSet (cleared K230343), into the human veins. | Same |
| Components | • Vial Adapter• Spike Adapter• Dispensing Connector• Closed Infusion Set | • Spike Adapter | Different,See Comment #1 |
| Characteristiccompared | Predicate Device (K201460)CSTD - Spike Adapter | Subject Device (K241988)ProSeal™ Closed System Bag Access | Comment/Discussion |
| Numberof access points | Device has 2 access points:1. Closed system port2. Spiking/ administration port, IV spike bagaccess | Device has 2 access points:1. Closed system port2. Spiking/ administration port, IV spike bagaccess | Same |
| Compositionof fluid path materials | ABS (spike), synthetic rubber(sealing element/ membrane/ septum) | Polypropylene (PP) (spike), polyisoprene(IR) (sealing element/ membrane/ septum) | Different,See Comment #2 |
| Intendedconnector type to beused with the bagspike adapter | Image: Shiva Ande Healthcare Apparatus manufacturer's dedicated Dispensing Connector (K201460) male Luer lock tip, connected to an external standard MLL syringe | Image: Epic Medical Pte Ltd manufacturer's cleared ProSeal™ Injector or Injector Plus (K240433) male Luer lock tip, connected to an external standard MLL syringe | Same |
| Safety feature toprevent microbialcontamination | Leak proof connector with membranes(septums) seal – elastomeric resealingdouble membrane | Airtight and leakage-proof adaptor withmembranes (septums) seal – elastomericresealing double membrane – closed systemtechnology | Same |
| Sterile barrierpackaging | Medical grade paper andmedical plastic film, heat sealed | Medical grade paper andmedical plastic film, heat sealed | Same |
| Sterilization process | Ethylene Oxide (EO), SAL 10-6 | Ethylene Oxide (EO), SAL 10-6 | Same |
| Shelf-life validation | 3 years (36 months) | 3 years (36 months) | Same |
4) Intended drug type
-
- Single use or reusable, single patient use
-
- Sterile barrier packaging
-
- Sterilization process
-
- Shelf-life
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Image /page/9/Picture/0 description: The image shows the word "EPIC" in a stylized, bold, sans-serif font. The "E" has a circular dot in the upper left corner, and a horizontal line underlines the entire word. The letters are closely spaced, giving the word a compact appearance.
Discussion of difference in technological characteristics
Comment #1
Submission K241988 is to include an authorization of the ProSeal™ Closed System Vial Access, a single component device, to the existing ProSeal™ CSTD system of 11 component devices (K241823). Compared to Predicate K201460, the application was for 4 component devices. The different questions of safety and effectiveness as the Subject device of the Predicate device component devices. Bench top, biocompatibility, and sterility data demonstrate the difference does not raise different questions in safety and effectiveness as described in section VII.
Comment #2
Though the Subject device's bag spike and membrane material differ with the Predicate, both the PP and IR materials are the same in type, make, grade and manufacturer source as those used in the cleared ToxiSeal™ Vial Adaptor with External Balloon (K222929) that have been tested to demonstrate biocompatibility. In addition, performance testing demonstrates the difference in material does not raise different questions of safety and effectiveness.
VII. Performance Data Supporting Substantial Equivalence
A. Functional Performance
The Subject device in this Summary was evaluated to be in conformance with the following ISO and FDA recognized standards and FDA guidance document:
- ANSI AAMI CN27:2021, General requirements for Luer activated valves (LAVs) incorporated ● into medical devices for intravascular applications
- . ISO 8536-4: 019, Infusion equipment for medical use - Part 4: Infusion sets for single use, gravity feed
- ISO 22413:2010, Transfer sets for pharmaceutical preparations Requirements and test ● methods
- . Intravascular-Administration-Sets-Premarket-Notifications-J510(k)]---Guidancefor-Industry-and-FDA-Staff
Bench performance verifications and validations referred-to and performed:
- Leak integrity test (functional) per ISO 8536-4:2019, paragraph 7.2 and Annex A.3, performed ● on Subject devices
- Tensile strength test (functional) per ISO 8536-4:2019, paragraph 7.3 and Annex A.4, . performed on Subject devices
- . Penetration force test (functional) - per ISO 22413:2021, Section 6.6, Annex A.7, performed on Subject devices
- . Protective caps test (functional) - per ISO 8536-4:2019, Section 7.13, performed on Subject devices
- Vapor containment test per NIOSH CSTD 2016 draft test protocol (functional) from testing data ● on devices cleared under K222929
- Microbial ingress test per FDA guidance and ANSI AAMI CN27:2021 (functional) from testing ● data on devices cleared under K222929
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e Dio
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B. Biocompatibility
In accordance with ISO 10993-1: 2018, the Subject device just like the existing ProSeal™ CSTD devices, is classified as: Externally Communicating Device, Blood Path Indirect, Prolonged Contact (>24hr to 30d). The following testing were performed on referred-to cleared devices: -
Cytotoxicity to ISO 10993-5 under K222929 ●
-
Sensitization to ISO 10993-10 under K222929 ●
-
Intracutaneous Reactivity to ISO 10993-10 under K222929 ●
-
Acute Systemic Toxicity to ISO 10993-11 under K222929 .
-
14-day Subacute/ Subchronic Acute Systemic Toxicity to ISO 10993-11 under K222929 .
-
In-vitro Hemolysis Assessment to ISO 10993-4 under K222929 ●
-
. Material Mediated Pyrogenicity to ISO 10993-11 under K222929
Particulate matter testing was conducted on the Subject device, in accordance with ISO 8536-4: 2019, Infusion equipment for medical use - Part 4: Infusion sets for single use, gravity feed and USP <788> Particulate Matter in Injections.
C. Sterility, Shipping, and Shelf-Life
The Subject device complies with sterilization requirements of ISO 11135:2014, Sterilization of Health Care Products – Ethylene Oxide – Part 1: Requirements for Development, Validation and Routine Control of a Sterilization Process for Medical Devices and the following testing/ evaluations conducted devices cleared under K222929;
- Simulated shipping testing per ASTM D 4169-16, Standard Practice for Performance Testing . of Shipping Containers and Systems
- Package Integrity Tests per ASTM F1980-21, Standard guide for accelerated aging of sterile . barrier systems for medical devices and Sterile Barrier Packaging Testing performed on the proposed device: Seal strength – ASTM F88/F88M-21, Standard test method for seal strength of flexible barrier materials: Dye Penetration - ASTM F1929-23. Standard test method for detecting seal leaks in porous medical device packaging by dye penetration; EN 868-5:2009, Packaging materials and systems for medical devices which are to be sterilized – Part 5: Heat and self-sealable pouches and reels of paper and plastic film construction – Requirements and test methods
- Pyrogen Tests per ANSI/AAMI ST72/2019, Bacterial endotoxins Test methods, routing . monitoring, and alternatives to batch testing, USP 40 <151>, Pyrogen test (USP rabbit test), USP-NF <161>, Medical Devices-Bacterial Endotoxin and Pyrogen Tests, USP-NF <85>, Bacterial Endotoxins Test and testing will be conducted on every lot
- Shelf-life of 3 years has been validated using the FDA recognized standard, ASTM 1980-21, Standard Guide for Accelerated Aging of Sterile Barrier Systems for Medical Devices.
VIII. Clinical Tests
Not applicable.
IX. Conclusion
The difference between the Predicate and the Subject device does not raise any new or different questions of safety or effectiveness. The Subject device - ProSeal™ Closed System Bag Access is substantially equivalent to the Predicate device, CSTD-Spike Adapter (manufactured by Shinva Ande Healthcare Apparatus Co., Ltd.), (K201460) - with respect to its indications for use, principles of operation and technological characteristics.
§ 880.5440 Intravascular administration set.
(a)
Identification. An intravascular administration set is a device used to administer fluids from a container to a patient's vascular system through a needle or catheter inserted into a vein. The device may include the needle or catheter, tubing, a flow regulator, a drip chamber, an infusion line filter, an I.V. set stopcock, fluid delivery tubing, connectors between parts of the set, a side tube with a cap to serve as an injection site, and a hollow spike to penetrate and connect the tubing to an I.V. bag or other infusion fluid container.(b)
Classification. Class II (special controls). The special control for pharmacy compounding systems within this classification is the FDA guidance document entitled “Class II Special Controls Guidance Document: Pharmacy Compounding Systems; Final Guidance for Industry and FDA Reviewers.” Pharmacy compounding systems classified within the intravascular administration set are exempt from the premarket notification procedures in subpart E of this part and subject to the limitations in § 880.9.