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510(k) Data Aggregation

    K Number
    K221134
    Date Cleared
    2022-05-19

    (30 days)

    Product Code
    Regulation Number
    878.4040
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The SafeSource Direct Procedure Mask with Ear Loops is intended to be worn to protect both the patient and healthcare personnel from the transfer of microorganisms, bodily fluids, and particulate material. These procedure masks are intended for use in infection control practices to reduce to blood and bodily fluid. The procedure masks are single use, disposable devices, provided non-sterile.

    The SafeSource Direct Surgical Mask with Ties is intended to be worn to protect both the patient and healthcare personnel from the transfer of microorganisms, bodly fluids, and particulate material. These surgical masks are intended for use in infection control practices to reduce the potential exposure to blood and bodily fluid. The surgical masks are single use, disposable devices, provided non-sterile.

    Device Description

    The Procedure Mask with Ear Loops (PM3001, PM3003) is a non-sterile, single use, three-layer, flat-folded mask with ear loops, and a nose wire. The Procedure Mask with Ear Loops is constructed of inner and outer layers consisting of spunbond polypropylene and a middle layer of meltblown polypropylene. The welded ear loops made of spandex/elastane fiber and polyester filament keep the user's mouth and nose. The ethylene propylene copolymer coated aluminum nose wire allows the user to fit the mask around their nose.

    The Surgical Mask with Ties (SM3001, SM3003) is a non-sterile, single use, three-layer, flat-folded mask with ties, and a nose wire. The Surgical Mask with Ties is constructed of inner and outer layers consisting of spunbond polypropylene and a middle layer of meltblown polypropylene. The welded polypropylene tie straps keep the mask close to the user's mouth and nose. The ethylene propylene coated aluminum nose wire allows the user to fit the mask around their nose.

    AI/ML Overview

    This document describes the performance of a medical device, specifically Procedure Masks with Ear Loops and Surgical Masks with Ties, submitted for FDA 510(k) clearance (K221134). The device is compared to a predicate device (K202899) to establish substantial equivalence.

    Here's a breakdown of the requested information based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria are based on ASTM F2100-19 for medical face mask performance, and other relevant standards like ASTM F1862/F1862M-17 (Fluid Resistance), ASTM F2299/F2299M-03 (Particulate Filtration Efficiency), ASTM F2101-19 (Bacterial Filtration Efficiency), EN 14683:2019 + AC:2019 Annex C (Differential Pressure), 16 CFR 1610 (Flammability), ISO 10993-5: 2009 (Cytotoxicity), and ISO 10993-10: 2010 (Irritation and Sensitization).

    There are two tables provided in the document:

    • Table 1: Comparison of Performance Testing for Proposed ASTM Level 1 Procedure Mask with Ear Loops (PM3001) and Surgical Mask with Ties (SM3001) with Predicate Device
    • Table 2: Comparison of Performance Testing for Proposed ASTM Level 3 Procedure Mask with Ear Loops (PM3003) and Surgical Mask with Ties (SM3003) with Predicate Device

    Table 1: ASTM Level 1 Masks (PM3001 & SM3001)

    Non-Clinical TestAcceptance Criteria (ASTM Level 1)Proposed Device Performance (PM3001)Proposed Device Performance (SM3001)
    Fluid Resistance≥ 29 of 32 pass at 80 mmHgPass (96/96) at 80 mmHg, 32 samples from 3 non-consecutive lotsPass (96/96) at 80 mmHg, 32 samples from 3 non-consecutive lots
    Particulate Filtration Efficiency≥ 95% at 0.1 micronPass (96/96) at > 95%, 32 samples from 3 non-consecutive lotsPass (96/96) at > 95%, 32 samples from 3 non-consecutive lots
    Bacterial Filtration Efficiency≥ 95%Pass (96/96) at > 95%, 32 samples from 3 non-consecutive lotsPass (96/96) at > 95%, 32 samples from 3 non-consecutive lots
    Differential Pressure< 5.0 mmH2O/cm²Pass (96/96) at < 5.0 mmH2O/cm², 32 samples from 3 non-consecutive lotsPass (95/96) at < 5.0 mmH2O/cm², 32 samples from 3 non-consecutive lots
    FlammabilityClass 1Pass (96/96) at Class 1, 32 samples from 3 non-consecutive lotsPass (96/96) at Class 1, 32 samples from 3 non-consecutive lots
    Cytotoxicity(Not specified, assumed "Non-cytotoxic")Non-cytotoxicNon-cytotoxic
    Irritation(Not specified, assumed "Non-irritating")Negligibly irritating (Primary Irritation Index 0.0)Negligibly irritating (Primary Irritation Index 0.0)
    Sensitization(Not specified, assumed "Non-sensitizing")Not a contact sensitizerNot a contact sensitizer

    Table 2: ASTM Level 3 Masks (PM3003 & SM3003)

    Non-Clinical TestAcceptance Criteria (ASTM Level 3)Proposed Device Performance (PM3003)Proposed Device Performance (SM3003)
    Fluid Resistance≥ 29 of 32 pass at 160 mmHgPass (96/96) at 160 mmHg, 32 samples from 3 non-consecutive lotsPass (96/96) at 80 mmHg, 32 samples from 3 non-consecutive lots
    Particulate Filtration Efficiency≥ 98% at 0.1 micronPass (95/96) at > 98%, 32 samples from 3 non-consecutive lotsPass (95/96) at > 98%, 32 samples from 3 non-consecutive lots
    Bacterial Filtration Efficiency≥ 98%Pass (96/96) at > 98%, 32 samples from 3 non-consecutive lotsPass (96/96) at > 98%, 32 samples from 3 non-consecutive lots
    Differential Pressure< 6.0 mmH2O/cm²Pass (96/96) at < 6.0 mmH2O/cm², 32 samples from 3 non-consecutive lotsPass (96/96) at < 6.0 mmH2O/cm², 32 samples from 3 non-consecutive lots
    FlammabilityClass 1Pass (96/96) at Class 1, 32 samples from 3 non-consecutive lotsPass (96/96) at Class 1, 32 samples from 3 non-consecutive lots
    Cytotoxicity(Not specified, assumed "Non-cytotoxic")Non-cytotoxicNon-cytotoxic
    Irritation(Not specified, assumed "Non-irritating")Negligibly irritating (Primary Irritation Index 0.0)Negligibly irritating (Primary Irritation Index 0.0)
    Sensitization(Not specified, assumed "Non-sensitizing")Not a contact sensitizerNot a contact sensitizer

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

    • Sample Size for Test Set: For each non-clinical performance test (Fluid Resistance, Particulate Filtration Efficiency, Bacterial Filtration Efficiency, Differential Pressure, Flammability), the tests were conducted on 32 samples from 3 non-consecutive lots, totaling 96 samples for each test. For cytotoxicity, irritation, and sensitization, specific sample sizes are not explicitly stated, but the results indicate evaluation was performed.
    • Data Provenance: The document does not specify the country of origin of the data. It indicates these are "non-clinical testing" results, which implies laboratory testing. It does not state whether the data is retrospective or prospective, but as it concerns performance of the newly manufactured device, it would inherently be prospective testing.

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

    No information is provided regarding human experts or ground truth establishment in the context of the performance tests for the masks. The "ground truth" for these tests is the quantitative measurement against established ASTM/EN/CFR standards, which are objective and do not require expert human interpretation in the way medical image analysis might.

    4. Adjudication Method for the Test Set

    Not applicable. The tests are laboratory-based and yield quantitative results against defined criteria, not subjective interpretations requiring adjudication.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    No. The document explicitly states: "No clinical testing is included in this submission." This type of study would typically be done for AI/CAD devices, not for basic personal protective equipment like masks where performance is evaluated through standardized material tests.

    6. Standalone (i.e., algorithm only without human-in-the-loop performance) Performance

    Not applicable. This is a physical medical device (mask), not an algorithm or software.

    7. Type of Ground Truth Used

    The ground truth for the performance tests is based on pre-defined, internationally recognized standards and test methods (e.g., ASTM, EN, CFR, ISO). Each test has a specific methodology and acceptance criterion for properties like filtration efficiency, fluid resistance, breathability, and biological safety.

    8. Sample Size for the Training Set

    Not applicable. This is a physical medical device, not an AI/ML algorithm that requires a training set.

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

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

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