K Number
K243317
Device Name
NUVENTUS NV.C™ Surgical Cassette and Tray
Manufacturer
Date Cleared
2025-02-11

(112 days)

Product Code
Regulation Number
880.6850
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The NUVENTUS NV.C™ Surgical Cassette and Tray is intended to enclose other medical devices that are to be sterilized by a health care provider. The NUVENTUS NV.C™ Surgical Cassette and Tray is intended to allow sterilization of the enclosed medical devices. The NUVENTUS NV.C™ Surgical Cassette and Tray requires the use of an FDA cleared wrap to maintain the sterility of the enclosed devices. The NUVENTUS NV.C™ Surgical Cassette and Tray should be enclosed in a sterilization wrap that is FDA cleared for the indicated cycle, and moist heat (steam) sterilized using the following cycle: Pre-vacuum steam: 132°C (270°F) for 4 minutes with 30 minutes drying time. The NUVENTUS NV.C™ Surgical Cassette and Tray is intended for sterilization of non-porous loads. The NUVENTUS NV.C™ Surgical Cassette and Tray is recommended not to be stacked during sterilization. The combined weight of the NUVENTUS NV.C™ Surgical Cassette and Tray and the associated instruments is 220 grams. The weight of the empty NUVENTUS NV.C™ Surgical Cassette and Tray is 200 grams.
Device Description
The subject device is a reusable rigid container, comprising a base (bottom), a removable inner tray, and a lid (cover). It is designed to organize and protect NUVENTUS NV.CTM instruments that fall within the cleaning and sterilization validation scope and are sterilized in the tray by a healthcare provider. The base, inner tray, and lid components are designed to be integrated into a single unit which contains and protects the interior contents during sterilization. The tray is perforated to allow for penetration of the sterilant, are to be used with moist heat (steam), and require the use of an FDA cleared wrap to maintain sterility. The subject device components are manufactured from injection molded polyphenylsulfone (PPSU), and holders of various geometries to position instruments in the trays are manufactured from silicone.
More Information

Not Found

No
The device description and performance studies focus on the physical properties, cleaning, sterilization, and biocompatibility of a surgical cassette and tray, with no mention of AI or ML technology.

No.
The device is a surgical cassette and tray used for sterilizing other medical devices, which is not a therapeutic function.

No

The device is a surgical cassette and tray used for sterilizing other medical devices, not for diagnosing medical conditions. Its function is to enclose and allow sterilization of instruments, not to detect or identify diseases or conditions.

No

The device description clearly states it is a reusable rigid container made of physical materials (polyphenylsulfone and silicone) and is intended to enclose and facilitate the sterilization of other medical devices. There is no mention of software components.

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

Here's why:

  • Intended Use: The intended use clearly states that the device is for enclosing other medical devices for sterilization and allowing that sterilization to occur. It is a container for instruments.
  • Device Description: The description details a reusable rigid container designed to organize and protect instruments during sterilization.
  • Lack of IVD Characteristics: An IVD is a medical device used to perform tests on samples taken from the human body (like blood, urine, or tissue) to provide information about a person's health. The provided text does not mention any testing of biological samples or diagnostic purposes.
  • Performance Studies: The performance studies focus on cleaning, sterilization, use life, and biocompatibility – all related to the function of a sterilization container, not an IVD.

Therefore, the NUVENTUS NV.C™ Surgical Cassette and Tray is a device intended for the sterilization of other medical instruments, not for in vitro diagnostic testing.

N/A

Intended Use / Indications for Use

The NUVENTUS NV.C™ Surgical Cassette and Tray is intended to enclose other medical devices that are to be sterilized by a health care provider. The NUVENTUS NV.C™ Surgical Cassette and Tray is intended to allow sterilization of the enclosed medical devices.

The NUVENTUS NV.C™ Surgical Cassette and Tray requires the use of an FDA cleared wrap to maintain the sterility of the enclosed devices. The NUVENTUS NV.C™ Surgical Cassette and Tray should be enclosed in a sterilization wrap that is FDA cleared for the indicated cycle, and moist heat (steam) sterilized using the following cycle: Pre-vacuum steam: 132°C (270°F) for 4 minutes with 30 minutes drying time.

The NUVENTUS NV.C™ Surgical Cassette and Tray is intended for sterilization of non-porous loads.

The NUVENTUS NV.C™ Surgical Cassette and Tray is recommended not to be stacked during sterilization. The combined weight of the NUVENTUS NV.C™ Surgical Cassette and Tray and the associated instruments is 220 grams. The weight of the empty NUVENTUS NV.C™ Surgical Cassette and Tray is 200 grams.

Product codes

KCT

Device Description

The subject device is a reusable rigid container, comprising a base (bottom), a removable inner tray, and a lid (cover). It is designed to organize and protect NUVENTUS NV.C™ instruments that fall within the cleaning and sterilization validation scope and are sterilized in the tray by a healthcare provider. The base, inner tray, and lid components are designed to be integrated into a single unit which contains and protects the interior contents during sterilization. The tray is perforated to allow for penetration of the sterilant, are to be used with moist heat (steam), and require the use of an FDA cleared wrap to maintain sterility. The subject device components are manufactured from injection molded polyphenylsulfone (PPSU), and holders of various geometries to position instruments in the trays are manufactured from silicone.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

health care provider

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)

Non-clinical Performance Testing:

  • Validation of the Manual Cleaning Process: Evaluate and validate the manual cleaning of the subject devices. Acceptance Criteria: Extraction Recovery - The extraction efficiency for each marker should be no less than 70%. The amounts of each marker residual detected in the fourth extract should be less than 10% of that detected in the first extraction. Residual marker testing - Protein Assay Acceptance criterion: less than 6.4 µg/cm2 Assay quantitation limits: 2.5 µg/mL Hemoglobin assay Acceptance criterion: less than 2.2 µg/cm2 Assay quantitation limits: 10.0 µg/mL. Results: Pass.
  • Validation of the Automated Cleaning Process: Evaluate and validate the automated cleaning of the subject devices. Acceptance Criteria: Extraction Recovery - The extraction efficiency for each marker should be no less than 70%. The amounts of each marker residual detected in the fourth extract should be less than 10% of that detected in the first extraction. Residual marker testing - Protein Assay Acceptance criterion: less than 6.4 µg/cm2 Assay quantitation limits: 2.5 µg/mL Hemoglobin assay Acceptance criterion: less than 2.2 µg/cm2 Assay quantitation limits: 10.0 µg/mL. Results: Pass.
  • Sterilization Validation: Validate a sterilization cycle and drying time of the subject devices. Acceptance criteria: 3 consecutive half-cycles will demonstrate complete inactivation of all biologic indicators; A minimum SAL of 10-6 is achieved if the Instructions for Use are followed. Acceptance criterion: Using pre-cycle and post-cycle weights, the weight gain after drying will not exceed +3%. Results: Pass.
  • Use Life Testing: Life Cycle (simulated use) testing after 225 cleaning, disinfection and sterilization cycles. Acceptance criteria: Visual inspection, functional verification for 225 use cycles. Results: Pass.
  • Biocompatibility of Subject Device (by cytotoxicity testing): Evaluate the cytotoxicity potential of the test article using an in vitro cell culture assay. Acceptance criterion: ≤ 2 reactivity grade after exposure to extract of the device. Results: Pass.

No clinical data were included in this submission.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s)

K201878

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 880.6850 Sterilization wrap.

(a)
Identification. A sterilization wrap (pack, sterilization wrapper, bag, or accessories, is a device intended to be used to enclose another medical device that is to be sterilized by a health care provider. It is intended to allow sterilization of the enclosed medical device and also to maintain sterility of the enclosed device until used.(b)
Classification. Class II (performance standards).

0

Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food & Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo is in blue and includes the letters "FDA" in a square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in a stacked format.

February 11, 2025

Infinitum Eta Ltd. Avital Barlev Vice President QA&RA Hatnufa St. 6 Petach Tikva, 4951024 Israel

Re: K243317

Trade/Device Name: NUVENTUS NV.CTM Surgical Cassette and Tray Regulation Number: 21 CFR 880.6850 Regulation Name: Sterilization Wrap Regulatory Class: Class II Product Code: KCT Dated: October 22, 2024 Received: October 22, 2024

Dear Avital Barlev:

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"

1

(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).

2

Sincerely,

Image /page/2/Picture/3 description: The image contains the text "Stephen A. Anisko -S". The text is arranged in a vertical format, with "Stephen A." on the first line, "Anisko" on the second line, and "-S" on the third line. The text is in a simple, sans-serif font and is black in color. The background of the image is white.

Digitally signed by Stephen A. Anisko -S Date: 2025.02.11 11:03:44 -05'00'

for: Christopher K. Dugard Division Director DHT4C: Division of Infection Control Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

3

Indications for Use

510(k) Number (if known) K243317

Device Name

NUVENTUS NV.CTM Surgical Cassette and Tray

Indications for Use (Describe)

The NUVENTUS NV.C™ Surgical Cassette and Tray is intended to enclose other medical devices that are to be sterilized by a health care provider. The NUVENTUS NV.C™ Surgical Cassette and Tray is intended to allow sterilization of the enclosed medical devices.

The NUVENTUS NV.C™ Surgical Cassette and Tray requires the use of an FDA cleared wrap to maintain the sterility of the enclosed devices. The NUVENTUS NV.C™ Surgical Cassette and Tray should be enclosed in a sterlization wrap that is FDA cleared for the indicated cvcle, and moist heat (steam) sterilized using the following cvcle: Pre-vacum steam: 132°C (270°F) for 4 minutes with 30 minutes drying time.

The NUVENTUS NV.CTM Surgical Cassette and Tray is intended for sterilization of non-porous loads.

The NUVENTUS NV.C™ Surgical Cassette and Tray is recommended not to be stacked during sterilization. The combined weight of the NUVENTUS NV.C™ Surgical Cassette and Tray and the associated instruments is 220 grams. The weight of the empty NUVENTUS NV.C™ Surgical Cassette and Tray is 200 grams.

Type of Use (Select one or both, as applicable)X Prescription Use (Part 21 CFR 801 Subpart D)

| Over-The-Counter Use (21 CFR 801 Subpart C)

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4

INFIN

510(K) Summary (K243317) for Infineta's NUVENTUS NV.CTM Surgical Cassette and Tray

Date Prepared:11 February 2025
1. Submitter
Company Name:Infinitum Eta Ltd
Address:Hatnufa St. 6, Petach Tikva, 4951024, Israel
Phone and E-mail:avitalb@infinetamed.com; +972-54-2272773
Contact Person:Avital Barlev, Vice President QA&RA
2. Device:
Proprietary/Trade Name:NUVENTUS NV.CTM Surgical Cassette and Tray
Common Name:Instrument Sterilization Trays
Regulation Number:21 CFR 880.6850
Regulation Name:Containers, Trays, Surgical Cassettes & Other Accessories
Regulatory Class:Class II
Product Code:KCT
  1. Predicate Device: Z-Systems AG's ST-Z5, cleared under K201878.

4. Device Description

The subject device is a reusable rigid container, comprising a base (bottom), a removable inner tray, and a lid (cover). It is designed to organize and protect NUVENTUS NV.CTM instruments that fall within the cleaning and sterilization validation scope and are sterilized in the tray by a healthcare provider. The base, inner tray, and lid components are designed to be integrated into a single unit which contains and protects the interior contents during sterilization. The tray is perforated to allow for penetration of the sterilant, are to be used with moist heat (steam), and require the use of an FDA cleared wrap to maintain sterility. The subject device components are manufactured from injection molded polyphenylsulfone (PPSU), and holders of various geometries to position instruments in the trays are manufactured from silicone.

5. Indications for Use

The NUVENTUS NV.C™ Surgical Cassette and Tray is intended to enclose other medical devices that are to be sterilized by a health care provider. The NUVENTUS NV.C™ Surgical Cassette and Tray is intended to allow sterilization of the enclosed medical devices.

The NUVENTUS NV.C™ Surgical Cassette and Tray requires the use of an FDA cleared wrap to maintain the sterility of the enclosed devices. The NUVENTUS NV.C™ Surgical Cassette and Tray should be enclosed in a sterilization wrap that is FDA cleared for the indicated cycle, and moist heat (steam) sterilized using the following cycle: Pre-vacuum steam: 132°C (270°F) for 4 minutes with 30 minutes drying time.

The NUVENTUS NV.C™ Surgical Cassette and Tray is intended for sterilization of non-porous loads.

5

INFINETA

The NUVENTUS NV.C™ Surgical Cassette and Tray is recommended not to be stacked during sterilization. The combined weight of the NUVENTUS NV.C™ Surgical Cassette and Tray and the associated instruments is 220 grams. The weight of the empty NUVENTUS NV.C™ Surgical Cassette and Tray is 200 grams.

Comparison of Technological Characteristics 6.

A tabular comparison of technological characteristics is presented herein:

Table 1: Indications for Use Comparison

Device NameIndications for Use
Subject
DeviceNUVENTUS
NV.CTM Surgical
Cassette and
Tray
(K243317)The NUVENTUS NV.CTM Surgical Cassette and Tray is intended to enclose other medical
devices that are to be sterilized by a health care provider. The NUVENTUS NV.CTM Surgical
Cassette and Tray is intended to allow sterilization of the enclosed medical devices.
The NUVENTUS NV.CTM Surgical Cassette and Tray requires the use of an FDA cleared wrap
to maintain the sterility of the enclosed devices. The NUVENTUS NV.CTM Surgical Cassette
and Tray should be enclosed in a sterilization wrap that is FDA cleared for the indicated cycle,
and moist heat (steam) sterilized using the following cycle: Pre-vacuum steam: 132°C (270°F)
for 4 minutes with 30 minutes drying time.
The NUVENTUS NV.CTM Surgical Cassette and Tray is intended for sterilization of non-
porous loads.
The NUVENTUS NV.CTM Surgical Cassette and Tray is recommended not to be stacked
during sterilization. The combined weight of the NUVENTUS NV.CTM Surgical Cassette and
Tray and the associated instruments is 220 grams. The weight of the empty NUVENTUS
NV.CTM Surgical Cassette and Tray is 200 grams.
Primary
Predicate
DeviceST-Z5
(K201878)ST-Z5 surgical trays are intended to be used to enclose other medical devices that are to be
sterilized by a health care provider. ST-Z5 surgical trays are intended to allow sterilization of
the enclosed medical devices. ST-Z5 surgical trays require the use of an FDA cleared wrap to
maintain the sterility of the enclosed devices. The trays are to be enclosed in a sterilization
wrap that is FDA cleared for the indicated cycle, and moist heat (steam) sterilized using the
following cycle: Pre-vacuum steam: 132 °C (270 °F) for 4 minutes with 20 minutes drying
time. ST-Z5 surgical trays are intended for sterilization of non-porous loads. ST-Z5 surgical
trays are recommended not to be stacked during sterilization. The combined weight of the ST-
Z5_c_m_c(t)_m(t) tray and the associated instruments is 441 grams. The weight of the empty
ST-Z5_c_m_c(t)_m(t) tray is 361 grams. The combined weight of the Z5-BL/TL tray and the
associated instruments is 427 grams. The weight of the empty Z5-BL/TL tray is 363 grams.

Table 2: Technological Characteristics Comparison

| Feature | Subject Device | Primary Predicate Device | Technological
Characteristics
Comparison |
|--------------|---------------------------------------------------------|------------------------------------------------------|------------------------------------------------|
| | NUVENTUS NV.CTM Surgical
Cassette and Tray (K243317) | ST-Z5 (K201878) | |
| Product Code | KCT | KCT | Identical |
| Design | Rigid polymer base, lid, and removable
inner tray | Rigid polymer base, lid, and removable
inner tray | Identical |
| Materials | Polyphenylsulfone [lid, base, tray] | Polyphenylsulfone [lid, base, tray] | Identical |

6

INFINETA

| | Subject Device | Primary Predicate Device | Technological
Characteristics
Comparison |
|------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------|
| Feature | NUVENTUS NV.CTM Surgical
Cassette and Tray (K243317) | ST-Z5 (K201878) | |
| | Medical grade silicone
[grommets/holders] | Medical grade silicone
[grommets/holders] | |
| Materials
compatible
with
Sterilization
Method | Yes | Yes | Identical |
| Perforated | Yes; allows moist heat (steam)
penetration to achieve sterilization | Yes; allows moist heat (steam)
penetration to achieve sterilization | Identical |
| Number of
Overall Sizes | 1 | 1 | Identical |
| Number of
Configurations | 1 | 2 | Similar |
| Overall
Dimensions | 138L x 98W x 62H [mm] | 185.1L x 133.6W x 61.5H [mm] | Similar |
| Vent to
Volume Ratio | 0.0172 cm2 / cm3 | 0.01596 cm2 / cm3 | Similar |
| Reusable | Yes | Yes | Identical |
| Number of
Uses | 225 | 101 | Similar |
| Use Life
Testing | Reusable up to 225 cycles
Assembled, cleaned, disinfected and
sterilized
Visual inspection
Defect and deformation
Functional performance (Cassette and
Tray) | Reusable up to 101 cycles
Assembled and sterilized
Visual inspection
Component dimensional fit verification
Functional closure (lid-base latch)
verification | Similar |
| Sterilization
Method | Moist Heat | Moist Heat | Identical |
| Sterilization
Cycles | Fractionated vacuum (pre-vacuum)
Exposure at 132 °C (270 °F) for 4
minutes with 30 minutes drying time | Fractionated vacuum (pre-vacuum)
Exposure at 132 °C (270 °F) for 4
minutes with 20 minutes drying time | Similar |
| Sterile
Barrier | Sterilization wrap, FDA cleared for
indicated method and cycle | Sterilization wrap, FDA cleared for
indicated method and cycle | Identical |

7. Technological Comparison Discussion:

The subject device is similar in indications and design principles to the predicate device.

The subject device and the predicate device have the same intended use, the same product classification and product code (KCT), and have similar Indications for Use statements.

Except for the details concerning the weights of the empty and loaded trays, the indications for use statement for the subject device is identical to that of the predicate device K201878.

7

INFINETA

The subject device and the predicate device are reusable rigid sterilization trays intended to be used to enclose other medical devices that are to be sterilized by a health care provider. Components of the subject device and the predicate device are perforated to allow for penetration of the sterilant, are to be used with the same moist heat (steam) sterilization cycle and require the use of an FDA-cleared wrap to maintain sterility.

The subject device and the predicate device include components manufactured from polyphenylsulfone (PPSU) and silicone, and both devices are provided in one overall size. While the predicate device is provided in two configurations, the subject device is provided in one configuration. The overall dimensions of the subject device are smaller than the overall dimensions for the predicate device and the vent to volume ratio of the subject device is larger than the vent to volume ratio of the predicate device.

There are minor differences in the configurations, sizes, or designs between the subject device and the predicate device. The differences are related to the specific design features and system components and are supported by the cleaning and sterilization validation and use life testing performed.

The subject device and the predicate device have different use life, 225 compared to 101, respectively.

8. Non-clinical Testing Summary

Provided below is a summary of the non-clinical performance testing included in this submission, including the test methods, purpose, acceptance criteria, and results.

Test MethodologyPurposeAcceptance CriteriaResults
Validation of the Manual
Cleaning Process
According to the ISO
17664 and the AAMI
ST98 StandardsEvaluate and validate the
manual cleaning of the
subject devicesExtraction Recovery - The extraction efficiency for
each marker should be no less than 70%. The amounts
of each marker residual detected in the fourth extract
should be less than 10% of that detected in the first
extraction.
Residual marker testing - Protein Assay Acceptance
criterion: less than 6.4 µg/cm2 Assay quantitation
limits: 2.5 µg/mL Hemoglobin assay Acceptance
criterion: less than 2.2 µg/cm2 Assay quantitation
limits: 10.0 µg/mLPass
Validation of the
Automated Cleaning
Process According to the
ISO 17664 and the AAMI
ST98 StandardsEvaluate and validate the
automated cleaning of
the subject devicesExtraction Recovery - The extraction efficiency for
each marker should be no less than 70%. The amounts
of each marker residual detected in the fourth extract
should be less than 10% of that detected in the first
extraction.
Residual marker testing - Protein Assay Acceptance
criterion: less than 6.4 µg/cm2 Assay quantitation
limits: 2.5 µg/mL Hemoglobin assay Acceptance
criterion: less than 2.2 µg/cm2 Assay quantitation
limits: 10.0 µg/mLPass
Sterilization Validation
According to the ISO
17664 - ISO 17665
Standards and the AAMI
TIR 12 Technical ReportValidate a sterilization
cycle and drying time of
the subject devicesAcceptance criterion: 3 consecutive half-cycles will
demonstrate complete inactivation of all biologic
indicators; A minimum SAL of 10-6 is achieved if the
Instructions for Use are followedPass

Table 3: Non-Clinical Testing Summary

8

I N

Test MethodologyPurposeAcceptance CriteriaResults
Acceptance criterion: Using pre-cycle and post-cycle
weights, the weight gain after drying will not exceed
+3%
Use Life Testing
FDA Guidance
Reprocessing Medical
Devices in Health Care
Settings: Validation
Methods and Labeling and
ISO 13402:1995Life Cycle (simulated
use) testing after 225
cleaning, disinfection
and sterilization cyclesAcceptance criteria: Visual inspection, functional
verification for 225 use cyclesPass
Biocompatibility of
Subject Device (by
cytotoxicity testing)
ISO 10993-5
ISO 10993-12The purpose of this test
is to evaluate the
cytotoxicity potential of
the test article using an in
vitro cell culture assay.Acceptance criterion: ≤ 2 reactivity grade after
exposure to extract of the devicePass

In summary, the nonclinical testing provided for these devices met the acceptance criteria for each standard and test methodology used to evaluate the devices as shown in the table above.

No clinical data were included in this submission.

9. Conclusion

To conclude, the conclusions drawn from the nonclinical tests demonstrate that the subject device is as safe, as effective, and performs as well as or better than the legally marketed predicate device cleared under K201878.