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510(k) Data Aggregation

    K Number
    K230135
    Date Cleared
    2023-10-04

    (259 days)

    Product Code
    Regulation Number
    878.4040
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Copioumed Chemotherapy Isolation Gown

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Copioumed Chemotherapy Isolation Gown is intended to be worn by healthcare personnel to protect health care patients and health care personnel from the transfer of microorganisms, body fluids and particulate. Copioumed Chemotherapy Isolation Gown is non-sterile and for single use only.

    Copioumed Chemotherapy Isolation Gown meets the requirements of an AAMI Level 3 barrier protection for an isolation gown per ANSI/AAMI PB70:2012 Liquid Barrier Performance Classification of Protective Apparel Drapes Intended for Use in Health Care Facilities (ANSI/AAMI PB70).

    Copioumed Chemotherapy Isolation Gown is a disposable device intended to protect health care personal from exposure to chemotherapy drugs during preparation, handling, and administration.

    The Copioumed Chemotherapy Isolation Gown has been evaluated for resistance to permeation of various chemotherapy drugs per ASTM F739-20 "Standard Test Method for Permeation of Liquids and Gases Through Protective Clothing Materials Under Conditions of Continuous Contact." Chemotherapy drug permeation resistance, average standardized breakthrough time in minutes. *:

    Carmustine [3.3 mg/ml] >480
    Cisplatin [1.0 mg/ml] >480
    Cyclophosphamide [20 mg/ml] >480
    Cytarabine Hydrochloride [100 mg/ml] >480
    Dacarbazine [10 mg/ml] >480
    Daunorubicin Hydrochloride [5 mg/ml] >480
    Doxorubicin Hydrochloride [2 mg/ml] > 480
    Etoposide [20 mg/ml] >480
    Fluorouracil [50 mg/ml] >480
    Ifosfamide [50 mg/ml] > 480
    Methotrexate [25 mg/ml] >480
    Mitomycin C [0.5 mg/ml] >480
    Mitoxantrone [2.0 mg/ml] >480
    Paclitaxel [6 mg/ml] >480
    Thiotepa [10 mg/ml] >480
    Vincristine Sulfate [1 mg/ml] >480

    *No permeation was detected at either the minimum detectable permeation or 0.1 ug/cm2/min

    Device Description

    Copioumed Chemotherapy Isolation Gown is a disposable device intended to protect health care personal from exposure to chemotherapy drugs during preparation, handling, and administration. This device is non-sterile and for single use only. Copioumed Chemotherapy Isolation Gown is a Polypropylene Gown laminated with Polyethylene and Knit cuff in three styles: Tie neck closure, Velcro neck closure and Sticker neck closure.

    AI/ML Overview

    This document pertains to the 510(k) premarket notification for the "Copioumed Chemotherapy Isolation Gown," a Class II medical device. The information provided outlines the device's technical specifications, indications for use, and a comparison to predicate and reference devices, supported by non-clinical testing.

    Here's an analysis of the acceptance criteria and study proving the device meets these criteria, as presented in the document:

    1. Table of Acceptance Criteria and Reported Device Performance

    The device's performance is primarily evaluated against recognized standards for protective apparel and chemotherapy drug permeation. The criteria and results are summarized in section "L. SUMMARY OF NON-CLINICAL TESTING" on page 14.

    No.StandardsPurposeCriteriaResults
    1.AATCC 42To demonstrate resistance to penetration of sprayed water≤1.0 gPass
    2.AATCC 127To demonstrate resistance to penetration of pressurized water≥50 cm H2OPass
    3.ANSI/AAMI PB70:2012 AAMI Level 3To demonstrate adequate liquid barrier performanceLevel 3Pass
    4.ASTM F739-20 (For specified chemotherapy drugs)To demonstrate resistance to penetration of chemotherapy drugs≥480 minutes (for each listed drug)Pass
    5.ASTM D3776/D3776M-17To determine the mass of the fabricInformative (This standard does not have a pass/fail criterion; it's for characterization)Pass (meaning the test was conducted)
    6.ASTM D5034 - 9 2017To demonstrate adequate tensile strength of the material≥30 NPass
    7.ASTM 1683-17 (2018)To demonstrate adequate seam strength≥30 NPass
    8.ASTM D5587-15 (2019)To demonstrate adequate tear strength of the material≥10 NPass
    9.NWSP 160.1To determine the linting propertiesInformativePass (meaning the test was conducted)
    10.ISO 9073-10:2003To determine linting propertiesInformativePass (meaning the test was conducted)
    11.16 CFR 1610Standard for the Flammability for Clothing TextilesClass 1Pass
    12.ISO 10993-5:2009To assess the potential cytotoxicity of the gownUnder the conditions of the testing, non-cytotoxicPass
    13ISO 10993-10:2021To assess the sensitization potential of the gownUnder the conditions of the testing, not a sensitizerPass
    14ISO 10993-23:2021To assess the irritation potential of the gownUnder the conditions of the testing, not an irritantPass

    Chemotherapy Drug Permeation Resistance (detailed from page 3, 6, and 8):
    The device was evaluated for resistance to permeation based on ASTM F739-20. The acceptance criterion for each drug was a breakthrough time of >480 minutes, with "No permeation was detected at either the minimum detectable permeation or 0.1 µg/cm²/min." The device met this criterion for all 16 listed chemotherapy drugs:

    • Carmustine [3.3 mg/ml]: >480 min
    • Cisplatin [1.0 mg/ml]: >480 min
    • Cyclophosphamide [20 mg/ml]: >480 min
    • Cytarabine Hydrochloride [100 mg/ml]: >480 min
    • Dacarbazine [10 mg/ml]: >480 min
    • Daunorubicin Hydrochloride [5 mg/ml]: >480 min
    • Doxorubicin Hydrochloride [2 mg/ml]: >480 min
    • Etoposide [20 mg/ml]: >480 min
    • Fluorouracil [50 mg/ml]: >480 min
    • Ifosfamide [50 mg/ml]: >480 min
    • Methotrexate [25 mg/ml]: >480 min
    • Mitomycin C [0.5 mg/ml]: >480 min
    • Mitoxantrone [2.0 mg/ml]: >480 min
    • Paclitaxel [6 mg/ml]: >480 min
    • Thiotepa [10 mg/ml]: >480 min
    • Vincristine Sulfate [1 mg/ml]: >480 min

    2. Sample Size Used for the Test Set and Data Provenance

    The document does not specify the exact sample sizes (e.g., number of gowns or material samples) used for each specific non-clinical test. It only states that the tests were performed "under the test conditions" for biocompatibility and that results for physical tests (e.g., breaking strength, tearing strength) are given as means and standard deviations, implying multiple samples were tested.

    The data provenance is from non-clinical laboratory testing. The document does not explicitly state the country of origin of the data or whether it was retrospective or prospective, beyond acknowledging that these are test results supporting a 510(k) submission. Given it's a 510(k) submission to the US FDA from a Taiwanese company (Copioumed International Inc.), the testing would have been conducted to meet US regulatory requirements, likely in certified labs.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications

    This submission is for a physical medical device (isolation gown) and relies entirely on non-clinical laboratory testing against recognized industry standards (ASTM, AAMI, ISO, AATCC, CFR). Therefore:

    • No human experts were used to establish ground truth in the context of clinical interpretation (e.g., radiologists for imaging data).
    • The "ground truth" is defined by the numerical criteria outlined in the referenced performance standards. The qualifications of the personnel conducting these laboratory tests would be that they are trained and competent in performing the specific standard tests in accredited laboratories. The document does not provide details on these personnel.

    4. Adjudication Method for the Test Set

    Not applicable. Since the evaluation is based on non-clinical, objective laboratory tests with defined quantitative pass/fail criteria, there is no team of experts adjudicating results in the way one would for clinical data or imaging interpretations. The tests yield objective measurements that are compared against a pre-defined standard's requirements.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done

    No. This is a 510(k) submission for an isolation gown, not a software or AI-assisted diagnostic tool. MRMC studies are not relevant for this type of device.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

    Yes, in a sense. The "performance" of this device is its physical and chemical barrier properties and material strength. These are assessed in laboratory settings without human intervention in the loop beyond the initial setup and analysis of the test apparatus. The tests are designed to measure the inherent properties of the gown material and construction.

    7. The Type of Ground Truth Used

    The ground truth used for this device's performance evaluation is based on defined quantitative and qualitative criteria set by recognized consensus standards (e.g., AAMI PB70:2012 for liquid barrier performance, ASTM F739-20 for chemotherapy drug permeation, various ASTM standards for material strength, and ISO 10993 for biocompatibility). These standards specify the methodology and acceptance criteria for demonstrating the device's protective capabilities.

    8. The Sample Size for the Training Set

    Not applicable. This device is an isolation gown, not an AI/ML-based device that requires a training set. The evaluation is based on physical and chemical testing of the final product.

    9. How the Ground Truth for the Training Set Was Established

    Not applicable, as there is no training set for this device.

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