K Number
K242167
Device Name
Sterile and Non-Sterile Ultrasonic Coupling Agent
Date Cleared
2024-09-19

(57 days)

Product Code
Regulation Number
892.1570
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
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.
Device Description
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.
More Information

Not Found

No
The device is an ultrasonic coupling agent (gel) and the description focuses on its physical properties and function in transmitting sound waves, with no mention of AI/ML for image processing or analysis.

No
The device, an ultrasonic coupling agent, is described as an accessory used to facilitate diagnostic ultrasound procedures by improving the transmission of sound waves for imaging. It does not provide therapy itself.

No

The device is an ultrasonic coupling agent, which is an accessory used in diagnostic ultrasound procedures to facilitate sound wave transmission. It does not perform diagnostic functions itself, but rather aids in the process of imaging for diagnosis.

No

The device is a physical gel product used as an acoustic couplant, not a software application.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In Vitro Diagnostics are medical devices intended for use in vitro for the examination of specimens, including blood, tissue, and urine, derived from the human body, solely or principally for the purpose of providing information concerning a physiological or pathological state, or a congenital abnormality, or to determine the safety and compatibility with potential recipients, or to monitor therapeutic measures.
  • Device Function: The described device, Ultrasonic Coupling Agent, is used externally on intact skin to facilitate the transmission of sound waves during ultrasound procedures. It does not examine specimens derived from the human body in vitro.
  • Intended Use: The intended use is to couple sound waves between the patient and the medical imaging electronics for diagnostic ultrasound procedures. This is a physical coupling function, not an in vitro diagnostic test.

Therefore, the Ultrasonic Coupling Agent is a medical device, but it falls under a different classification than IVD. It is an accessory used in conjunction with an ultrasound imaging system.

N/A

Intended Use / Indications for Use

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.

Product codes

MUI

Device Description

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.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Ultrasound

Anatomical Site

Intact skin

Indicated Patient Age Range

adults and pediatrics

Intended User / Care Setting

professional healthcare facility

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

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 completed.

Table 1: Performance testing summary - Bench

Test ItemDescriptionTest Results
Sound Velocity (Acoustic Velocity)Measured at 35°C, The Sound Velocity (Acoustic Velocity) shall be 1520-1620m/s1541.8m/s ~1551.7m/s Pass
Acoustic ImpedanceMeasured at 35°C ,Acoustic Impedance shall be 1.5x10^6 ~ 1.7x10^6 Pa·s/m1.58x10^6 Pa·s/m~ 1.59x10^6 Pa·s/m Pass
Sound AttenuationMeasured at 35°C ,Sound Attenuation shall be

§ 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.

0

Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & 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.

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.

1

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.

2

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

3

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, 200120
China
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

5

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

6

completed.

Test ItemDescriptionTest Results
Sound Velocity
(Acoustic Velocity)Measured at 35°C, The Sound Velocity
(Acoustic Velocity) shall be 1520-1620m/s1541.8m/s ~1551.7m/s

Pass |
| Acoustic
Impedance | Measured at 35°C ,Acoustic Impedance shall
be $1.5×10^6$ ~ $1.7×10^6$ Pa·s/m | $1.58×10^6$ Pa·s/m~
$1.59×10^6$ Pa·s/m

Pass |
| Sound Attenuation | Measured at 35°C ,Sound Attenuation shall
be ≤0.1dB/(cm·MHz) | 0.04dB/(cm · MHz)~
0.07dB/(cm · MHz)

Pass |
| Viscosity | Measured at 25°C, the viscosity of the
product should not be less than 15Pa·s. | 42Pa·s~50 Pa·s

Pass |
| Density | The density of the product shall be
987-1049kg/m3 | 1024.5kg/m3~1029.7kg/m3

Pass |
| pH | The pH value of the product should be
5.58.0 | 6.626.86

Pass |
| Microbial Limit
(Non-sterile
Ultrasonic Coupling
Agent ) | The total number of aerobic bacteria shall not
exceed 102cfu/g, and the total number of fungi
and yeast shall not exceed 101cfu/g;
Staphylococcus aureus , Pseudomonas
aeruginosa , and Candida albicans cannot be
detected. | Pass |
| Sterility
(Sterile Ultrasonic
Coupling Agent )) | The product should be sterile after being
sterilized by confirmed gamma sterilization. | Pass |
| Appearance | 1) The product shall generally be colorless or
light colored transparent gel without
insoluble foreign matters.
2) Under normal storage conditions, the
product 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

7

ItemSubject DevicePredicate Device
510(k) No.K242167K181363
Product CodeMUIMUI
Regulation No.21 CFR 892.157021 CFR 892.1570
ClassIIII
Intended
Use/Indication for
UseUltrasonic 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.EcoVue® Sterile and Non-Sterile
Ultrasound Gels 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.
Patient-contactingwater-based polymer gel
(sterile and non-sterile)Water-based gel
(sterile and non-sterile)
ModelTubes 10g,20g, 30g (Sterile)
Bottles 50g,100g, 250g,1000g,
2500g,5000g(non-sterile)20g individual packets (both
sterile and non-sterile)
250g pouch (non-sterile)
SterileBoth in Gamma sterilization
and non-sterile , SAL 10-6Both in Gamma
sterilization
and non-sterile
Shelf Life3 years1 years
AppearanceThe product shall be colorless or
light-colored transparent gel
without insoluble foreign mattersClear to Hazy Color; free from
foreign matter
Sound Velocity
(Acoustic Velocity)1520-1620m/s1398-1750 m/s
Acoustic
Impedance1.5×106~1.7×106 Pa·s/m1.40x106-1.80 x106 Pa·s/m
Sound
Attenuation≤0.1dB/(cm·MHz)0.32-0.95 dB/cm at 5 MHz
0.65-1.10 dB/cm at 7.5 MHz
0.85-1.55 dB/cm at 10 MHz
Viscosity≥15Pa·s>35,000 cP
Density987-1049kg/m³850-1150 kg/cm³
pH5.5~8.05.5 – 7.8
BiocompatibilityConform with ISO 10993 standardsConform with ISO 10993 standards

Table 2- Comparison of Technology Characteristics

8

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.