(143 days)
SteriChek™ Total Chlorine Test Kit provides a quick convenient means of testing for low levels of total chlorine (i.e. total chloramines plus free chlorine) in water used to prepare dialysate. The water sample changes color relative to the amount of total chlorine in the water sample.
The device consists of utilizing a fixed sample size of powdered reagent with a predetermined water sample volume in a test tube to effect a color reaction in the water sample. The color of the sample is then visually compared to a colormetric comparator to determine the total chlorine level in the sample. The device utilizes a recognized standard method of analysis for determining levels of total chlorine in water according to the Association for the Advancement of Medical Instrumentation (1993 Association for the Advancement of Medical Instrumentation-ANSI/AAMI;RD5-1992).
The provided text describes a medical device, the SteriChek™ Total Chlorine Test Kit, and its 510(k) submission for market clearance. However, the document primarily focuses on the device's description, intended use, and a comparison of its performance to a predicate device. It does not explicitly state specific acceptance criteria (performance targets/thresholds) or a detailed study plan that demonstrates the device meets those criteria.
Instead, it states that the "Performance of both devices was equivalent," referring to the SteriChek™ kit and its predicate device (Serim™ HiSense Test Strips). This implies that the acceptance criteria for the SteriChek™ kit were to show performance equivalent to the legally marketed predicate device.
Therefore, many of the requested details about the study are not explicitly available or are not applicable in the typical sense for a substantial equivalence submission relying on a predicate device.
Here's a breakdown of the available information:
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria (Implied) | Reported Device Performance |
|---|---|
| Equivalent performance to the predicate device (Serim™ HiSense Test Strips) in detecting total chlorine concentrations between 0 and 0.7 ppm. | "Performance of both devices [SteriChek™ and predicate device] was equivalent." |
2. Sample size used for the test set and the data provenance:
- Sample Size for Test Set: Not explicitly stated. The document mentions "water samples in which either sodium hypochlorite or monochloramines were added to give a range of free chlorine or combined chlorine levels." The number of these samples is not provided.
- Data Provenance: Not explicitly stated, but the submission is from Environmental Test Systems, Inc. in Elkhart, IN, USA. It's likely the testing was conducted in the USA, but this is not explicitly confirmed. The study appears to be prospective in the sense that the SteriChek™ kit was analyzed with new samples.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Number of Experts: Not mentioned.
- Qualifications of Experts: Not mentioned.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Adjudication Method: Not mentioned. The device involves visual comparison to a colorimetric comparator. It's possible that a single operator/technician compared the colors, but details are not provided.
5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:
- MRMC Study: No. This device is a chemical test kit, not an AI-assisted diagnostic tool for human readers. Therefore, an MRMC study and AI-related effect sizes are not applicable.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done:
- Standalone Performance: The device itself is a "standalone" chemical test kit. Its performance is based on the chemical reaction and visual comparison, not an algorithm. The description implies human-in-the-loop for visual comparison, as the color of the sample is "visually compared to a colormetric comparator."
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- Type of Ground Truth: The ground truth was established by adding known concentrations of "sodium hypochlorite or monochloramines" to water samples. This creates a synthetic but precisely known (reference) concentration of free or combined chlorine, against which the device's readings are compared.
8. The sample size for the training set:
- Sample Size for Training Set: Not applicable. The device is a chemical test kit, not a machine learning algorithm that requires a "training set."
9. How the ground truth for the training set was established:
- Ground Truth for Training Set: Not applicable, as there is no "training set" for this type of device.
Summary of the Study:
The study performed was a comparison study where the SteriChek™ Total Chlorine Test Kit was evaluated against a predicate device, Serim™ HiSense Test Strips. Both devices were tested with water samples prepared with known concentrations of either sodium hypochlorite (for free chlorine) or monochloramines (for combined chlorine). The objective was to demonstrate that the SteriChek™ kit's performance was "equivalent" to the predicate device. Details on the specific number of samples, how the comparison was quantified (e.g., specific accuracy metrics), or who performed the readings are not provided in this summary. The ground truth was based on the precisely prepared known concentrations of chlorine in the water samples.
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K983997 p.1/2
Image /page/0/Picture/1 description: The image shows the SteriChek logo with the words "REAGENT STRIPS" underneath. The word "SteriChek" is in large, bold, black letters with a white outline. The words "REAGENT STRIPS" are in smaller, black letters. Above the logo is a handwritten date of 4/2/99.
510(k) SAFETY AND EFFECTIVENESS SUMMARY
| Prepared: | November 5, 1998 |
|---|---|
| Submitter: | Environmental Test Systems, Inc. |
| Address: | 23575 County Road 106Elkhart, IN 46514-0659U.S.A.(219) 262-2060 |
| Contact: | Bruce G. Piekarski, Director-Business Development |
| Device Trade/Proprietary Name: | SteriChek™ Total Chlorine Test Kit |
| Device CommonName: | ETS DPD Chlorine Test Kit |
| Classification Name: | Class IICH |
| Predicate Device: | Serim™ HiSense Test Strips |
| Device Description: | The device consists of utilizing a fixed sample size of powderedreagent with a predetermined water sample volume in a test tube toeffect a color reaction in the water sample. The color of the sample isthen visually compared to a colormetric comparator to determine thetotal chlorine level in the sample. The device utilizes a recognizedstandard method of analysis for determining levels of total chlorine inwater according to the Association for the Advancement of MedicalInstrumentation (1993 Association for the Advancement of MedicalInstrumentation-ANSI/AAMI;RD5-1992). |
| Intended Use: | SteriChek™ Total Chlorine Test Kit provides a quick convenientmeans of testing for low levels of total chlorine (i.e. total chloraminesplus free chlorine) in water used to prepare dialysate. The watersample changes color relative to the amount of total chlorine in thewater sample. |
Simply Accurate
Environmental Test Systems, Inc. • 102 Box 4659 • Elkhart, Indiana 46514-0659 219-262-2060 • Fax 219-262-2495 • 1-888-ETS-STRIps (1-888-387-7874) • www. etsstrips.com
ISO 9001 Certified
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SteriChek™ Total Chlorine Test Kit 510(k) Safety and Effectiveness Summary - November 5, 1998 Environmental Test Systems, Inc. (Page 2 of 2)
The concentration of total chlorine in water is obtained by comparing the Technological color of the water sample mixed with the powdered reagent to the color Characteristics: comparator. The color comparator is calibrated in terms of total chlorine concentration in parts per million (ppm). The device is used as a quantitative method to detect total chlorine concentrations between 0 and 0.7 ppm.
SteriChek™ Total Chlorine Test Kit contains DPD and potassium iodide that serves as the indicator system and a pH buffer. Chlorine oxidizes DPD (a colorless compound) to form a magenta (red) color. Chloramines oxidize potassium iodide to iodine, which oxidizes DPD to form the magenta color. The intensity of the color is proportional to the concentration of total chlorine (chloramines and free chlorine).
The performance characteristics of the predicate device was analyzed Assessment of Performance: with water samples in which either sodium hypochlorite or monochloramines were added to give a range of free chlorine or combined chlorine levels (See Predicate Device "Product Insert"). The SteriChek™ Total Chlorine Test Kit was also analyzed with samples in which either sodium hypochlorite or monochloramines were added to give a range of free chlorine or combined chlorine levels. Performance of both devices was equivalent.
The SteriChek™ Total Chlorine Test Kit has the same intended use as Conclusion: the Predicate Device. The predicate device's indicator system (qualitative combined dry and liquid reagent colorimetric method) is different than SteriChek™ Total Chlorine Test Kit (quantitative powdered reagent colorimetric method). However, SteriChek™ Total Chlorine Test utilizes the recognized standard method of analysis of the Association for the Advancement of Medical Instrumentation. In fact, the SteriChek™ Total Chlorine Test Kit has no technological characteristics that raise new types of safety or effectiveness questions.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
APR 2 1999
Mr. Bruce G. Piekarski Director - Business Development Environmental Test Systems, Inc. P.O. Box 4659 Elkhart, IN 46514-0659
Re: K983997
SteriChek™ Total Chlorine Test Kit Dated March 5, 1999 Received: March 8, 1999 Regulatory Class: II 21 CFR 876.5665/Procode: 78 MSY and 78 FIP
Dear Mr. Piekarski:
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 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). You may, therefore, market the device, subject to the general controls provisions of the Act. 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.
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 Regulations, Title 21, Parts 800 to 895. A substantially equivalent determination assumes compliance with the Current Good Manufacturing Practice requirements, as set forth in the Quality System Regulation (QS) for Medical Devices: General requlation (21 CFR Part 820) and that, 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 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 regulations.
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) 594-4613. 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/dsma/dsmamain.html".
Sincerely yours,
Dan Setiz
BART Daniel G. Seitel, M.D.
CAPT Daniel G. Schultz, M.D. Acting Director, Division of Reproductive. Abdominal, Ear, Nose and Throat, and Radiological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
Image /page/2/Picture/15 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized caduceus symbol, which is a staff with two snakes coiled around it, and the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged in a circle around the symbol. The text is in all caps and is evenly spaced around the circle.
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SteriChekTM Total Chlorine Test Kit 510(k) Submission - November 5, 1998 Environmental Test Systems, Inc.
510(k) Number (if known)
Device Name: SteriChek™ Total Chlorine Test Kit
Indications for Use:
SteriChek™ Total Chlorine Test Kit provides a quick convenient means of testing for low levels of total chlorine (i.e. total chloramines and free chlorine) in water used to prepare dialysate.
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
7
| Prescription Use | ✓ | OR |
|---|---|---|
| (Per 21 CFR 801,109) |
Signature
on Sign-Off)
sion of Reproductive, Abdominal, ENT,
• Radiological Devices
| 10(k) Number | K983997 / 5004 |
|---|---|
| -------------- | ---------------- |
Over-The Counter Use _________________________________________________________________________________________________________________________________________________________
§ 876.5665 Water purification system for hemodialysis.
(a)
Identification. A water purification system for hemodialysis is a device that is intended for use with a hemodialysis system and that is intended to remove organic and inorganic substances and microbial contaminants from water used to dilute dialysate concentrate to form dialysate. This generic type of device may include a water softener, sediment filter, carbon filter, and water distillation system.(b)
Classification. Class II (special controls). The device, when it is a water purification subsystem disinfectant, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.