(76 days)
The Zerowet Splashield is intended for use as an accessory to an irrigation syringe. It is intended to be attached to the end of said syringe during wound irrigation, in place of the commonly used needle, thereby eliminating the use of a needle during this procedure. Additionally, the Zerower Splashield protects the user from contaminated (bloody) fluid splashing back during wound irrigation.
The device of the current submission is an unsterilized styrene bell-shaped unit, with a 19g nozzle integrated in the stem which attaches to the end of a syringe. The intended use is as attached to the end of an irrigation syringe, during wound irrigation, to protect the user from (a) needlesticks (by eliminating the use of a needle), and (b) bloody splash during this procedure.
This submission, K974288, is for a modified version of an existing device, the Zerowet Splashield. The only difference is the sterility level. The original device was gamma-radiation-sterilized, while the new submission is for an unsterilized, clean device. The manufacturer is arguing for substantial equivalence based on the premise that the sterility level does not impact the device's integrity or performance for its intended use.
Here's an analysis of the provided information regarding acceptance criteria and the supporting study:
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria | Reported Device Performance |
|---|---|
| No substantial difference in integrity or performance between: 1) Radiation sterilized device (predicate) 2) Unsterilized device (new submission) 3) Unsterilized device, to be user-sterilized via EtO 4) Unsterilized device, to be kit-packer-sterilized via EtO or radiation | The applicant asserts that "there is no substantial difference in the integrity or performance of the Zerowet Splashield between the following four formats." |
| No reasonable likelihood that the use of unsterilized components would adversely impact wound healing, wound infection rates, or general patient care. | The applicant asserts this, stating it's "based on requests from a number of end users who are themselves specialists in the field of emergency wound care, who would prefer to use the Zerowet Splashield in an unsterilized format and feel that sterilization of this component for irrigation of a traumatic, contaminated wound is unnecessary." |
| Sterilization by end user or kit assembler using standard EtO or radiation protocols would not adversely affect the integrity or performance of the device. | The applicant asserts this without further supporting data in the provided text. |
Important Note: The provided document is a 510(k) summary, not a full study report. It primarily contains assertions made by the applicant and the FDA's decision based on that information. It does not present detailed study results or data to prove these acceptance criteria were met through a formal study.
2. Sample Size Used for the Test Set and Data Provenance
The provided text does not describe any formal test set or corresponding sample size. The primary argument is based on:
- Requests/Opinions from end-users: "requests from a number of end users who are themselves specialists in the field of emergency wound care"
- Assertion of no "reasonable likelihood" of adverse impact: This is a qualitative argument, not based on a statistically designed test set.
- Assumption of equivalence in integrity/performance: This is also asserted without presenting data from a test set.
Given this, there is no information on data provenance (country of origin, retrospective/prospective).
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
- Number of experts: The text refers to "a number of end users who are themselves specialists in the field of emergency wound care." A specific number is not provided.
- Qualifications of experts: They are described as "specialists in the field of emergency wound care." Further details like years of experience or specific credentials (e.g., surgeon, emergency physician) are not given.
- Ground truth: Their opinions formed the basis of the applicant's assertion regarding the adequacy of an unsterilized device for traumatic, contaminated wounds. This is a qualitative "ground truth" based on expert opinion, not a quantitative measurement.
4. Adjudication Method for the Test Set
No formal adjudication method is described because no structured test set with adjudicated outcomes is presented. The "ground truth" relies on the collective opinion of unspecified "specialists."
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was Done, What was the Effect Size of How Much Human Readers Improve with AI vs Without AI Assistance?
No, an MRMC comparative effectiveness study was not done. This device is a physical medical accessory (splash shield), not an AI-powered diagnostic or assistive tool. Therefore, the concept of human readers improving with AI assistance is not applicable.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was Done?
No, a standalone algorithm performance study was not done. This is a physical device, not an algorithm.
7. The Type of Ground Truth Used
The ground truth primarily used in this submission is expert opinion/consensus (from "specialists in the field of emergency wound care") and the assertion of common practice/clinical judgment that an unsterilized device is adequate for traumatic, contaminated wounds.
There is no mention of pathology, outcomes data (e.g., wound infection rates from a comparative study), or other empirical data to establish ground truth.
8. The Sample Size for the Training Set
There is no mention of a training set in the context of this device. This submission relies on justifying the equivalence of a modified (unsterilized) version of an existing device based on clinical judgment and the perceived lack of clinical impact.
9. How the Ground Truth for the Training Set Was Established
Since no training set is mentioned, this question is not applicable.
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K 974288
JAN 2 9 1998
510(k) Summary
Submitted by-Zerowet, Inc. PO Box 4375 Palos Verdes Peninsula, CA 90274 (310) 544-1600 Phone (310) 544-4411 FAX
Contact person-Keith Stamler, MD Date-November 10, 1997 Trade name-Zerowet Splashield Common name-Same Classification name-Irrigation syringe-Accessory Predicate legally marketed device-Zerowet Splashield (sterile)
The device of the current submission is an unsterilized styrene bell-shaped unit, with a 19g nozzle integrated in the stem which attaches to the end of a syringe. The intended use is as attached to the end of an irrigation syringe, during wound irrigation, to protect the user from (a) needlesticks (by eliminating the use of a needle), and (b) bloody splash during this procedure.
The only difference between the current device and the predicate device is the sterility level. Whereas the predicate device is marketed as a gamma-radiation-sterilized device, the current device is to be marketed as a clean, but unsterilized device. This is in response to requests from:
(1) some end users (hospitals/physicians) who feel that an unsterilized Zerowet Splashield is adequate to irrigate a traumatic, already contaminated wound,
(2) some end users (hospitals/physicians) who prefer a sterile product, but who wish to use in-house EtO sterilization facilities to sterilize the Zerowet Splashield as a component of a wound repair tray, and
(3) independent kit packers who would like to include the unsterilized Zerowet Splashield as a component part of a disposable wound prep/repair tray, to be sterilized by a method of their choosing (either EtO or radiation), to then be marketed to end users (hospitals/physicians).
It is felt that there is no substantial difference in the integrity or performance of the Zerowet Splashield between the following four formats:
-
as a radiation sterilized device (as currently permitted by FDA),
-
as an unsterilized device, to be used as such,
-
as an unsterilized device, to be sterilized by the end user using in-house EtO.
-
as an unsterilized device, to be sterilized by a kit packer using EtO or radiation.
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Although there is no body of literature comparing the use of sterilized versus unsterilized wound irrigation components, it is felt that there is no reasonable likelihood that the use of unsterilized components (as in the present submission) would adversely impact wound healing, wound infection rates, or general patient care. This is based on requests from a number of end users who are themselves specialists in the field of emergency wound care, who would prefer to use the Zerowet Splashield in an unsterilized format and feel that sterilization of this component for irrigation of a traumatic, contaminated wound is unnecessary.
Additionally, it is felt that sterilization by the end user or kit assembler using standard EtO or radiation protocols would not adversely affect the integrity or performance of this device.
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Image /page/2/Picture/1 description: The image is a black and white logo for the U.S. Department of Health & Human Services. The logo features the department's name in a circular arrangement around a stylized symbol. The symbol consists of three abstract human figures or profiles, stacked on top of each other, with flowing lines suggesting movement or connection.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
JAN 2 9 1998
Keith Stamler, MD President ZeroWet®, Incorporated P.O. Box 4375 Palos Verdes Peninsula, California 90274
Re : K974288 Trade Name: ZeroWet Splashield Regulatory Class: I Product Code: KYZ Dated: November 10, 1997 Received: November 14, 1997
Dear Dr. Stamler:
We have reviewed your Section 510(k) notification of intent to market the device referenced above and we have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to 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 (Act). You may, therefore, market the device, subject to the general controls provisions The general controls provisions of the Act of the Act. include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.
If your device is classified (see above) into either class II (Special Controls) or class III (Premarket Approval), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Requlations, Title 21, Parts 800 to 895. ਰ substantially equivalent determination assumes compliance with the current Good Manufacturing Practice requirement, as set forth in the Quality System Regulation (QS) for Medical General regulation (21 CFR Part 820) and that, Devices: through periodic (QS) inspections, the Food and Drug Administration (FDA) will verify such assumptions. Failure to comply with the GMP regulation may result in regulatory action. In addition, FDA may publish further announcements concerning your device in the Federal Register. Please note: this response to your premarket notification submission does
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Page 2 - Dr. Stamler
not affect any obligation you might have under sections 531 through 542 of the Act for devices under the Electronic Product Radiation Control provisions, or other Federal laws or requlations.
This letter will allow you to begin marketing your device as described in your 510 (k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and additionally 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4618. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its internet address "http://www.fda.gov/cdrh/dsmamain.html".
Sincerely yours,
Timothy A. Ulatowski
Ulat Director Division of Dental, Infection Control and General Hospital Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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40003
510(k) Number (if known): K 974288 Device Name: Zerowet Splashield
Indications For Use:
.
Allery Pre
"The Zerowet Splashield is intended for use as an accessory to an irrigation syringe. It is intended to be attached to the end of said syringe during wound irrigation, in place of the commonly used needle, thereby eliminating the use of a needle during this procedure. Additionally, the Zerower Splashield protects the user from contaminated (bloody) fluid splashing back during wound irrigation."
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Patucia Cucendi
(Division Sign-Off)
Division of Dental, Infection Control,
and General Hospital Devices
510(k) Number X974288
Prescription Use ✓
(Per 21 CFR 801.109)
OR
Over-The-Counter Use__
(Optional Format 1-2-96)
§ 880.6960 Irrigating syringe.
(a)
Identification. An irrigating syringe is a device intended for medical purposes that consists of a bulb or a piston syringe with an integral or a detachable tube. The device is used to irrigate, withdraw fluid from, or instill fluid into, a body cavity or wound.(b)
Classification. Class I (general controls). The device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter, subject to the limitations in § 880.9. If the device is not labeled or otherwise represented as sterile, it is also exempt from the current good manufacturing practice requirements of the quality system regulation in part 820 of this chapter, with the exception of § 820.180, with respect to general requirements concerning records, and § 820.198, with respect to complaint files.