Clinical observation of individual patient use; Clinical testing via 'BUTTON' access in pediatric patients
The device was evaluated through informal clinical testing and observation of patient use to assess ease of use, accuracy, and patient anxiety levels during gravity-fed medication delivery.
Clinical observation; Pediatric use; Gravity-fed delivery; Ease of use
Clinical Evidence
Study Design
Population
Comparator
Key Endpoints
Clinical test of the FROG; Observational clinical testing
Pediatric patients using 'BUTTON' access
Not applicable for this study
Ease of use, accuracy, and patient anxiety levels
Indications for Use
A non-sterile gravity medicine delivery device for use with a nasogastric or percutaneous endoscopic gastrostomy ( PEG) tube to administer crushed and diluted medications and liquids.
Device Story
The FROG is a gravity-fed delivery device for medications and liquids; designed for use with nasogastric or PEG feeding tubes. Device consists of a 240cc polypropylene barrel, delivery tubing with a drip chamber, a cap, and a hanger. Operates by gravity; eliminates need for manual plunger use. Drip chamber allows back-priming to clear blockages from crushed medication. Used in home settings by patients or caregivers. Enables hands-free, accurate delivery without spillage or waste; reduces need to disconnect from feeding tube, minimizing risk of medication loss. Benefits patients by facilitating hydration and nourishment while supporting activities of daily living.
Clinical Evidence
Clinical testing performed on a small sample size using 'BUTTON' access (popular in children). Reported ease and accuracy of use; reduced patient/caregiver anxiety regarding dosing. Non-clinical testing confirmed that the airway on the tubing, cap, and hanger resolved reflux issues observed in initial testing.
Indicated for patients requiring administration of crushed/diluted medications and liquids via nasogastric or PEG feeding tubes.
Regulatory Classification
Identification
A gastrointestinal tube and accessories is a device that consists of flexible or semi-rigid tubing used for instilling fluids into, withdrawing fluids from, splinting, or suppressing bleeding of the alimentary tract. This device may incorporate an integral inflatable balloon for retention or hemostasis. This generic type of device includes the hemostatic bag, irrigation and aspiration catheter (gastric, colonic, etc.), rectal catheter, sterile infant gavage set, gastrointestinal string and tubes to locate internal bleeding, double lumen tube for intestinal decompression or intubation, feeding tube, gastroenterostomy tube, Levine tube, nasogastric tube, single lumen tube with mercury weight balloon for intestinal intubation or decompression, and gastro-urological irrigation tray (for gastrological use).
Special Controls
*Classification.* (1) Class II (special controls). The barium enema retention catheter and tip with or without a bag that is a gastrointestinal tube and accessory or a gastronomy tube holder accessory is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.(2) Class I (general controls) for the dissolvable nasogastric feed tube guide for the nasogastric tube. The class I device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to § 876.9.
Submission Summary (Full Text)
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K072831
Pg 1 of 3
# (h) 510 (k) Summary
DEC 12 2008
Submitter's name: Karla N Coombs 21 Union Turnpike Branchville, NJ 07826 973-948-3796
Karla N Coombs Contact person:
October 2, 2007 Date prepared:
Name of device:
Dosage vessel to be used with a indwelling feeding tube.
Trade name:
FROG = Fluids- Rx( medications)- Qn the- Go See Logo on label information
Equivalence data:
The FROG is functionally similar to the syringe used for delivery of "bolus feedings and medications through a nasogastric feeding tube or a "Peg" feeding tube. By adapting the tip of the syringe barrel to accommodate the secondary medication tubing, adding a cap and hanger and enlarging the barrel of the syringe to accommodate the 240cc capacity, the FROG is capable of delivering a can (240cc) of feeding or medications, hands free and accurately without spillage or waste.
The FROG is made of polypropolene, latex free and dishwasher safe for home use.
The drip chamber on the delivery tubing allows for back priming in the event crushed medication particles clump and cause a blockage in the flow. The syringe currently used to give medications
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K072831 pg 2 of 3
## (h) 510 k Summary continued
does not accommodate any alternative in this area and the caregiver has no choice but to disconnect the syringe from the patient's feeding tube and risk loss of medication or feeding in the process.
In a single clinical test, the 60cc syringe tip was shortened and a secondary medication tubing was inserted into the tip to provide a more controllable (using the roller clamp) flow rate for a client who was capable of giving self feedings and medications. The reflux continued to be a problem, with no untoward effects physically on the client and in subsequent non-clinical testing, the airway on the tubing, the cap and hanger have proven to resolve these issues as well. The plunger was not used, as bolus feedings and medication are to be given by gravity. *
A clinical test of the "FROG" with cap and hanger was performed via the "BUTTON" access, popular for use in children. The ease and accuracy of use was reported and the level of anxiety related to fear of inaccurate dosing was relieved.
*Perry & Potter-Clinical Nursing Skills & Techniques-5 the Edition.
11
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K072831 pg 30f3
# (h) 510 k Summary continued
In conclusion, the FROG, will prove to be a welcomed relief to those already burdened with the inability to eat and swallow as they have done under normal circumstances in the past. This device will allow them and their caregivers more freedom to go about their activities of daily living with less disruption in their routine and ease in their ability to be medicated, hydrated and nourished.
Respectively submitted,
Karla N Coombs
{3}------------------------------------------------
### DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/3/Picture/1 description: The image shows the seal of the Department of Health & Human Services - USA. The seal is circular and contains the department's name around the perimeter. In the center of the seal is an abstract symbol that resembles an eagle or bird with stylized wings and tail feathers. The image is black and white.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
DEC 1 2 2008
Karla N. Coombs, R.N. Owner Newby-Coombs, L.L.C. 21 Union Turnpike P.O. Box 20. BRANCHVILLE NJ 07826
K072831 Re:
> Trade/Device Name: The FROG Device Regulation Number: 21 CFR §876.5980 Regulation Name: Gastrointestinal tube and accessories Regulatory Class: II Product Code: FPD Dated: November 25, 2008 Received: December 2, 2008
Dear Ms. Coombs:
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 (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. 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 (PMA), 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 898. In addition, FDA may publish further announcements concerning your device in the Rederal Register.
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#### Page 2
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); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
This letter will allow you to begin marketing your device as described in your Section 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), please contact the Office of Compliance at one of the following numbers, based on the regulation number at the top of this letter:
| 21 CFR 876.xxx | (Gastroenterology/Renal/Urology | 240-276-011 |
|----------------|---------------------------------|-------------|
| 21 CFR 884.xxx | (Obstetrics/Gynecology) | 240-276-011 |
| 21 CFR 894.xxx | (Radiology) | 240-276-012 |
| Other | | 240-276-010 |
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding postmarket surveillance, please contact CDRH's Office of Surveillance and Biometrics' (OSB's) Division of Postmarket Surveillance at 240-276-3474. For questions regarding the reporting of device adverse events (Medical Device Reporting (MDR)), please contact the Division of Surveillance Systems at 240-276-3464. You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely vours,
Jorge M. Zhang
Joyce M. Whang, Ph.D. Acting Director, Division of Reproductive, Abdominal, and Radiological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
{5}------------------------------------------------
# Indications for Use
510(k) Number (if known): KO72831
Device Name: The FROG Device
Indications for Use:
A non-sterile gravity medicine delivery device for use with a nasogastric or percutaneous endoscopic gastrostomy ( PEG) tube to administer crushed and diluted medications and liquids.
Prescription Use (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Dulla Reen
(Division Sign-Off) Division of Reproductive, Abdominal, and Radiological Devic 510(k) Number.
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Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
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Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
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Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
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Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.