(57 days)
Sterile and Non-Sterile Ultrasonic Coupling Agent are ultrasound couplants intended to be used on intact skin during noninvasive medical ultrasound procedures to cound waves between a patient and the medical imaging electronics. The gels are intended for use in all diagnostic ultrasound procedures which require coupling gel or fluid. The gels can be used during the procedures that involved adults and pediatrics in professional healthcare facility.
The subject device, Sterile and Non-Sterile Ultrasonic Coupling Agent, are nonirritating, non-sensitizing acoustic couplants intended for use as a scanning gel in medical diagnostic ultrasound procedures. The Ultrasonic Coupling Agent is an accessory used to couple sound waves between the patient and the medical imaging electronic transducers during diagnostic ultrasound procedures. The Ultrasonic Coupling Agent is a type of conductive medium that enables a tight bond between the skin and the probe or transducer, allowing the waves to transmit directly to the tissues beneath and to the parts that need to be imaged. As such, the Ultrasonic Coupling Agent is formulated to improve the acoustic transmission of sound waves to create the ultrasound image.
The document describes the premarket notification (510(k)) for a medical device called "Sterile and Non-Sterile Ultrasonic Coupling Agent." It provides information about its intended use, technical characteristics, and performance testing to demonstrate its substantial equivalence to a predicate device.
Here's an analysis of the provided text in relation to acceptance criteria and supporting studies, formatted to answer your questions:
Acceptance Criteria and Study Proving Device Meets Criteria
The device under review is an "Ultrasonic Coupling Agent," which is a gel used to facilitate ultrasound imaging. The acceptance criteria for this type of device are primarily based on its physical and chemical properties, biocompatibility, and sterilization effectiveness (for sterile versions). The study proving the device meets these criteria is a series of non-clinical bench tests and compliance with recognized consensus standards, demonstrating substantial equivalence to a legally marketed predicate device. No clinical study was performed.
1. Table of Acceptance Criteria and Reported Device Performance
The document provides a table summarizing performance testing (bench tests) for the subject device against specified acceptance criteria.
| Test Item & Acceptance Criteria (Requirement Specification) | Reported Device Performance (Test Results) | Meets Criteria? |
|---|---|---|
| Sound Velocity (Acoustic Velocity) | ||
| Measured at 35°C, 1520-1620 m/s | 1541.8 m/s ~ 1551.7 m/s | Pass |
| Acoustic Impedance | ||
| Measured at 35°C, 1.5x10^6 ~ 1.7x10^6 Pa·s/m | 1.58x10^6 Pa·s/m ~ 1.59x10^6 Pa·s/m | Pass |
| Sound Attenuation | ||
| Measured at 35°C, ≤0.1 dB/(cm·MHz) | 0.04 dB/(cm · MHz) ~ 0.07 dB/(cm · MHz) | Pass |
| Viscosity | ||
| Measured at 25°C, ≥15 Pa·s | 42 Pa·s ~ 50 Pa·s | Pass |
| Density | ||
| 987-1049 kg/m³ | 1024.5 kg/m³ ~ 1029.7 kg/m³ | Pass |
| pH | ||
| 5.5 ~ 8.0 | 6.62 ~ 6.86 | Pass |
| Microbial Limit (Non-sterile Ultrasonic Coupling Agent) | ||
| Total aerobic bacteria ≤10² cfu/g; Fungi and yeast ≤10¹ cfu/g; Staphylococcus aureus, Pseudomonas aeruginosa, Candida albicans cannot be detected. | Pass | Pass |
| Sterility (Sterile Ultrasonic Coupling Agent) | ||
| Sterile after confirmed gamma sterilization. | Pass | Pass |
| Appearance | ||
| 1) Generally colorless or light-colored transparent gel without insoluble foreign matters. 2) Free from stratification, mildew, and odor under normal storage conditions. | Pass | Pass |
2. Sample Size Used for the Test Set and Data Provenance
The document does not specify the exact sample sizes (e.g., number of batches, number of samples per batch) used for each bench test. These are typically detailed in the full test reports, which are summarized here.
The data provenance is from non-clinical bench testing performed by the manufacturer, Anhui Deepblue Medical Technology Co., Ltd., located in Hefei, Anhui, PEOPLE'S REPUBLIC OF CHINA. The testing is retrospective in the sense that it was conducted as part of the product development and regulatory submission process.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of Those Experts
This document describes a premarket notification for an ultrasonic coupling agent, which is a physical material, not an AI/software device that generates diagnostic outputs requiring expert interpretation. Therefore, the concept of "ground truth established by experts" in the context of image interpretation (e.g., radiologists) does not apply to this submission. The "ground truth" for the performance tests (e.g., sound velocity, pH) is established by the validated measurement methods and equipment used in the laboratory.
4. Adjudication Method for the Test Set
As this is a submission for a physical medical product based on laboratory bench testing and not an AI or diagnostic imaging device requiring human expert consensus for "ground truth," an "adjudication method" involving multiple experts is not applicable. The results are determined by instrumental measurements and standardized material testing procedures.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No, an MRMC comparative effectiveness study was not done. This type of study is relevant for diagnostic devices (especially AI-powered ones) where human readers interpret cases, and the AI's impact on their performance is evaluated. For an ultrasonic coupling gel, this type of study is not relevant or required.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
No, a standalone performance study in the sense of an algorithm's performance without human interaction was not done. This device is a passive material, not an algorithm. Its "performance" is its physical and chemical properties and ability to conduct ultrasound waves.
7. The Type of Ground Truth Used
The "ground truth" for this device's performance is based on objective physical and chemical measurements obtained through validated laboratory testing methods (bench tests) and compliance with recognized standards. This includes:
- Physical properties (Sound Velocity, Acoustic Impedance, Sound Attenuation, Viscosity, Density, pH) measured by instruments.
- Microbial limits and sterility confirmed by microbiological testing.
- Biocompatibility assessed against ISO 10993 standards.
- Packaging and shelf-life validated per ISO 11607-1, ASTM F88/F88M-15, ASTM D3078.
There is no "expert consensus," "pathology," or "outcomes data" used as ground truth for a coupling agent's performance in the same way it would be for a diagnostic tool or treatment.
8. The Sample Size for the Training Set
The concept of a "training set" is not applicable to this submission. This device is a physical product (ultrasound gel), not an AI algorithm that undergoes training on a dataset. The formulation and manufacturing processes are developed and validated, but there isn't a "training set" in the machine learning sense.
9. How the Ground Truth for the Training Set Was Established
As there is no "training set" for this physical device, this question is not applicable.
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September 19, 2024
Anhui Deepblue Medical Technology Co., Ltd. % Boyle Wang General Manager Shanghai Truthful Information Technology Co., Ltd. Room 1801, No. 161 East Lujiazui Rd., Pudong Shanghai. 200120 CHINA
Re: K242167
Trade/Device Name: Sterile and Non-Sterile Ultrasonic Coupling Agent Regulation Number: 21 CFR 892.1570 Regulation Name: Diagnostic Ultrasonic Transducer Regulatory Class: Class II Product Code: MUI Dated: July 24, 2024 Received: July 24, 2024
Dear Boyle Wang:
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.
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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 (OS) 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.
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.
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For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Yanna S. Kang -S
Yanna Kang, Ph.D. Assistant Director Mammography and Ultrasound Team DHT8C: Division of Radiological Imaging and Radiation Therapy Devices OHT8: Office of Radiological Health 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) K242167
Device Name
Sterile and Non-Sterile Ultrasonic Coupling Agent
Indications for Use (Describe)
Sterile and Non-Sterile Ultrasonic Coupling Agent are ultrasound couplants intended to be used on intact skin during noninvasive medical ultrasound procedures to cound waves between a patient and the medical imaging electronics. The gels are intended for use in all diagnostic ultrasound procedures which require coupling gel or fluid. The gels can be used during the procedures that involved adults and pediatrics in professional healthcare facility.
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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K242167
510(k) Summary
This summary of 510(k) safety and effectiveness information is being submitted in accordance with requirements of 21 CFR 807.92.
1.0 Submitter's Information
| Name: | ANHUI DEEPBLUE MEDICAL TECHNOLOGY CO.,LTD. |
|---|---|
| Address: | No. 777 Jimingshan Road, High-Tech Development Zone, 230088 |
| Hefei, Anhui, PEOPLE'S REPUBLIC OF CHINA | |
| Tel: | +86-551-65326797 |
| Contact: | Ms. Fengling Chen |
Designated Submission Correspondent
| Contact: | Mr. Boyle Wang |
|---|---|
| Name: | Shanghai Truthful Information Technology Co., Ltd. |
| Address: | Room 1801, No. 161 East Lujiazui Rd., Pudong Shanghai, 200120China |
| Tel: | +86-21-50313932 |
| Email: | Info@truthful.com.cn |
Date submitted: Jul.19,2024
2.0 Device Information
| Trade name: | Sterile and Non-Sterile Ultrasonic Coupling Agent |
|---|---|
| Common name: | Diagnostic ultrasonic transducer |
| Classification name: | Media, Coupling, Ultrasound |
| Production code: | MUI |
| Regulation number: | 21 CFR 892.1570 |
| Classification: | Class II |
| Panel: | Radiology |
3.0 Predicate Device Information
| Manufacturer: | HR Pharmaceuticals, Inc. |
|---|---|
| Trade/Device Name: | EcoVue® Sterile and Non-Sterile Ultrasound Gels |
| 510(k) number: | K181363 |
4.0 Device Description
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The subject device, Sterile and Non-Sterile Ultrasonic Coupling Agent, are nonirritating, non-sensitizing acoustic couplants intended for use as a scanning gel in medical diagnostic ultrasound procedures. The Ultrasonic Coupling Agent is an accessory used to couple sound waves between the patient and the medical imaging electronic transducers during diagnostic ultrasound procedures. The Ultrasonic Coupling Agent is a type of conductive medium that enables a tight bond between the skin and the probe or transducer, allowing the waves to transmit directly to the tissues beneath and to the parts that need to be imaged. As such, the Ultrasonic Coupling Agent is formulated to improve the acoustic transmission of sound waves to create the ultrasound image.
5.0 Indication for Use Statement
Sterile and Non-Sterile Ultrasonic Coupling Agent are ultrasound couplants intended to be used on intact skin during non-invasive medical ultrasound procedures to couple sound waves between a patient and the medical imaging electronics. The gels are intended for use in all diagnostic ultrasound procedures which require coupling gel or fluid.
The gels can be used during the procedures that involved adults and pediatrics in professional healthcare facility.
6.0 Summary of Non-Clinical Testing
Summary of non-clinical and performance testing was performed to evaluate the performance and functionality of the subject device against requirement specification. The subject device has been subjected to compliance testing according to, by FDA, recognized consensus standards ISO 10993-1, ISO 11137-1, ISO 11607-1. Results from testing performed confirms that the design requirement specification and user needs have been met. The subject device is confirmed to be safe and effective for the intended use.
6.1 Sterilization - Sterile Ultrasonic Coupling Agent have successfully been tested according to ISO 11137-1.
6.2 Packaging Validation and Shelf Life - Sterile and Non-Sterile Ultrasonic Coupling Agent underwent packaging validation testing and real aging testing per ISO 11607-1, ASTM F88/F88M-15,ASTM D3078 standards in order to support three years shelf life. 6.2 Biocompatibility testing - Sterile and Non-Sterile Ultrasonic Coupling Agent have successfully been tested for cytotoxicity, sensitization and intracutaneously irritation. The test results verify that the biocompatibility criteria given in ISO 10993-1 are fulfilled. Sterile and Non-Sterile Ultrasonic Coupling Agent are non- irritating, non-sensitizing acoustic couplants.
6.3 Performance testing - Bench The performance of Sterile and Non-Sterile Ultrasonic Coupling Agent has been verified. Tests as described in table 1 have been
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completed.
| Test Item | Description | Test Results |
|---|---|---|
| Sound Velocity(Acoustic Velocity) | Measured at 35°C, The Sound Velocity(Acoustic Velocity) shall be 1520-1620m/s | 1541.8m/s ~1551.7m/sPass |
| AcousticImpedance | Measured at 35°C ,Acoustic Impedance shallbe $1.5×10^6$ ~ $1.7×10^6$ Pa·s/m | $1.58×10^6$ Pa·s/m~$1.59×10^6$ Pa·s/mPass |
| Sound Attenuation | Measured at 35°C ,Sound Attenuation shallbe ≤0.1dB/(cm·MHz) | 0.04dB/(cm · MHz)~0.07dB/(cm · MHz)Pass |
| Viscosity | Measured at 25°C, the viscosity of theproduct should not be less than 15Pa·s. | 42Pa·s~50 Pa·sPass |
| Density | The density of the product shall be987-1049kg/m3 | 1024.5kg/m3~1029.7kg/m3Pass |
| pH | The pH value of the product should be5.5~8.0 | 6.62~6.86Pass |
| Microbial Limit(Non-sterileUltrasonic CouplingAgent ) | The total number of aerobic bacteria shall notexceed 102cfu/g, and the total number of fungiand yeast shall not exceed 101cfu/g;Staphylococcus aureus , Pseudomonasaeruginosa , and Candida albicans cannot bedetected. | Pass |
| Sterility(Sterile UltrasonicCoupling Agent )) | The product should be sterile after beingsterilized by confirmed gamma sterilization. | Pass |
| Appearance | 1) The product shall generally be colorless orlight colored transparent gel withoutinsoluble foreign matters.2) Under normal storage conditions, theproduct shall be free from stratification,mildew and odor | Pass |
Table 1: Performance testing summary - Bench
7.0 _Summary of Clinical Testing
No clinical study is included in this submission.
8.0 Technological Characteristic Comparison Table
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| Item | Subject Device | Predicate Device |
|---|---|---|
| 510(k) No. | K242167 | K181363 |
| Product Code | MUI | MUI |
| Regulation No. | 21 CFR 892.1570 | 21 CFR 892.1570 |
| Class | II | II |
| IntendedUse/Indication forUse | Ultrasonic Coupling Agent areultrasound couplants intended tobe used on intact skin duringnon-invasive medical ultrasoundprocedures to couple sound wavesbetween a patient and the medicalimaging electronics. The gels areintended for use in all diagnosticultrasound procedures whichrequire coupling gel or fluid.The gels can be used during theprocedures that involved adultsand pediatrics in professionalhealthcare facility. | EcoVue® Sterile and Non-SterileUltrasound Gels are ultrasoundcouplants intended to be used onintact skin during non-invasivemedical ultrasound procedures tocouple sound waves between apatient and the medical imagingelectronics.The gels are intended for use inall diagnostic ultrasoundprocedures which requirecoupling gel or fluid. |
| Patient-contacting | water-based polymer gel(sterile and non-sterile) | Water-based gel(sterile and non-sterile) |
| Model | Tubes 10g,20g, 30g (Sterile)Bottles 50g,100g, 250g,1000g,2500g,5000g(non-sterile) | 20g individual packets (bothsterile and non-sterile)250g pouch (non-sterile) |
| Sterile | Both in Gamma sterilizationand non-sterile , SAL 10-6 | Both in Gammasterilizationand non-sterile |
| Shelf Life | 3 years | 1 years |
| Appearance | The product shall be colorless orlight-colored transparent gelwithout insoluble foreign matters | Clear to Hazy Color; free fromforeign matter |
| Sound Velocity(Acoustic Velocity) | 1520-1620m/s | 1398-1750 m/s |
| AcousticImpedance | 1.5×106~1.7×106 Pa·s/m | 1.40x106-1.80 x106 Pa·s/m |
| SoundAttenuation | ≤0.1dB/(cm·MHz) | 0.32-0.95 dB/cm at 5 MHz0.65-1.10 dB/cm at 7.5 MHz0.85-1.55 dB/cm at 10 MHz |
| Viscosity | ≥15Pa·s | >35,000 cP |
| Density | 987-1049kg/m³ | 850-1150 kg/cm³ |
| pH | 5.5~8.0 | 5.5 – 7.8 |
| Biocompatibility | Conform with ISO 10993 standards | Conform with ISO 10993 standards |
Table 2- Comparison of Technology Characteristics
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The technological characteristics of the subject device are identical to those of predicate device. The subject device has the same basic design as the predicate device. The comparison between the subject and predicate devices is based on the following:
- Same Intended Use
- Same Technological Characteristics
- Similar Physical Characteristics
- · Similar Performance Specifications
- · Provided in both sterile and non-sterile product offerings
- Biocompatible
- · Water-based gels
Physical and Chemical Properties of the subject device are a little different with those of the predicate device, but all the required values are within those of predicate device. Additionally, side-by-side testing confirmed that the subject devices are substantially equivalent to the predicate devices.
9.0 Conclusion
The conclusions drawn from the comparison and analysis above demonstrate that the proposed device is as safe, as effective, and performs as well as the legally marketed predicated device in K181363 and raises no new questions of safety or effectiveness. The differences between both devices are insignificant in terms of safety and effectiveness.
§ 892.1570 Diagnostic ultrasonic transducer.
(a)
Identification. A diagnostic ultrasonic transducer is a device made of a piezoelectric material that converts electrical signals into acoustic signals and acoustic signals into electrical signals and intended for use in diagnostic ultrasonic medical devices. Accessories of this generic type of device may include transmission media for acoustically coupling the transducer to the body surface, such as acoustic gel, paste, or a flexible fluid container.(b)
Classification. Class II.