Tuohy NRFit

{0}------------------------------------------------ Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized caduceus symbol, which is a staff with two snakes entwined around it. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" are arranged in a circular pattern around the caduceus symbol. Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002 October 28, 2016 PAJUNK GmbH Medizintechnologie Christian Quass Director Regulatory Affairs Karl-hall-str. 1 Geisingen, 78187 DE Germany Re: K160297 Trade/Device Name: Tuohy NRFit™ Regulation Number: 21 CFR 868.5150 Regulation Name: Anesthesia Conduction Needle Regulatory Class: Class II Product Code: BSP Dated: September 23, 2016 Received: September 27, 2016 Dear Christian Quass: 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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading. If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to 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 Federal Register. 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); medical device reporting (reporting of medical devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in {1}------------------------------------------------ the quality systems (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050. If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance. You may obtain other general information on your responsibilities under the Act from the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. Sincerely yours, # Tejashri Purohit-Sheth, M.D. Tejashri Purohit-Sheth, M.D. Clinical Deputy Director DAGRID/ODE/CDRH FOR Tina Kiang, Ph.D. Acting Director Division of Anesthesiology. General Hospital, Respiratory, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health Enclosure {2}------------------------------------------------ # Indications for Use 510(k) Number (if known) K160297 Device Name Tuohy NRFit™ Indications for Use (Describe) The Tuohy NRFit™ cannulas/ needles for anesthesia are intended for the transient delivery of anesthetics to provide regional anesthesia and analgesia or to facilitate placement of an epidural catheter. The device is intended for adult and pediatric patients. | Type of Use (Select one or both, as applicable) | | |---------------------------------------------------------------------------------------------------------------------------------------------|--| | <span style="font-size: 10pt;"> <span style="font-family: Wingdings;">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) </span> | | | <span style="font-size: 10pt;"> ☐ Over-The-Counter Use (21 CFR 801 Subpart C) </span> | | #### CONTINUE ON A SEPARATE PAGE IF NEEDED. This section applies only to requirements of the Paperwork Reduction Act of 1995. #### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.* The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to: > Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov "An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number." {3}------------------------------------------------ Image /page/3/Picture/0 description: The image shows the word "PAJUNK" in white letters against a teal background. The letters are bold and sans-serif. A small registered trademark symbol is located to the right of the letter "K". # 510(k) Summary as required by 21 CFR 807.92(c). Date of Preparation: September 23, 2016 **Document Control Number:** # Document Control Number: K160297 # 510(k) owner: PAJUNK® GmbH Medizintechnologie Karl-Hall-Str. 1 78187 Geisingen Baden-Wuerttemberg, Germany Fon: +49(0)7704-9291-586 Fax: +49(0)7704-9291-605 Establishment Registration Number: 9611612 # Submitter Information/ production site: PAJUNK® GmbH Medizintechnologie Karl-Hall-Str. 1 78187 Geisingen Baden-Wuerttemberg, Germany Fon: +49(0)7704-9291-586 Fax: +49(0)7704-9291-605 Establishment Registration Number: 9611612 # Contact: Christian G. H. Quass Director Regulatory Affairs, Safety Officer Patricia Weisbrod Regulatory Affairs Manager Fon: +49(0)7704-9291-586 Fax: +49(0)7704-9291-605 E-Mail: christian.quass@pajunk.com E-Mail: patricia.weisbrod@pajunk.com # USA Contact: PAJUNK MEDICAL SYSTEMS 6611 Bay Circle, Suite 140 Norcross, GA 30071 Phone +1 (888) 9PAJUNK (72-5865) Fax +1 (678) 514-3388 Establishment Registration Number: 3004076349 # Contact Marco Wohnig President PAJUNK® Medical Systems L.P. Phone: (770) 493-6832 Direct: (470) 448-4070 Cell: (770) 757-2449 Fax: (678) 514-3388 E-Mail: marco.wohnig@pajunk-usa.com {4}------------------------------------------------ | Device Information: | | |------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | Device Name: | Tuohy NRFit™ | | Sterilization method: | Ethylene Oxide<br>disposable device, supplied sterile to the end<br>user and non-sterile intended to be sterilized<br>prior to use to repackagers/ medical device<br>manufacturers | | Contract Sterilizer: | Sterigenics Germany GmbH<br>Kasteler straße 45<br>65203 Wiesbaden<br>Germany, Hessen<br>Establishment Registration Number:<br>3002807090 | | Document Control Number | K160297 | | Classification Name: | Anesthesia Conduction Needle | | Classification Reference: | 21 CFR § 868.5150 | | Product Code: | BSP | | Establishment Registration Number: | 9611612 | | Regulatory Class: | II | | Panel: | Anesthesiology | | Predicate Devices: | K040965<br>(Owner: PAJUNK® GmbH Medizintechnologie)<br>PAJUNK TUOHY NEEDLES, QUINCKE<br>NEEDLES, CHIBA NEEDLES & CRAWFORD<br>NEEDLES | PAJUNK® GmbH Medizintechnologie is submitting this Premarket Notification according to 510(k) for Tuohy NRFit™ Anaesthesia conduction needles. The intended use as well as the basic technical description of the needle which is relevant to clinical use is identical to the predicate device and has been cleared in 510(k)s sent in earlier by the sponsor. The only difference between the predicate device and the subject device is the design of the needle´s hub. While the predicate devices are equipped with a LUER taper connector the subject devices are equipped with a NRFit connector as it is described in ISO 80369-6 for neuroaxial devices. The clinical technique, the indications for use, the technical specification, the materials used, the sterility status (validation and sterility assurance level) as the biocompatibility status is absolutely identical. None of these is affected by the altered hub as it is subject to this submission. {5}------------------------------------------------ Image /page/5/Picture/0 description: The image shows the word "PAJUNK" in white letters against a teal background. The letters are bold and sans-serif. A small registered trademark symbol is located to the right of the letter "K". ### Indications for use subiect device: The Tuohy NRFit™ cannulas/ needles for anesthesia are intended for the transient delivery of anesthetics to provide regional anesthesia and analgesia or to facilitate placement of an epidural catheter. The device is intended for adult and pediatric patients. # Device Description: The Tuohy NRFit™ anaesthesia conduction needles are available in different sizes (length and diameter). Optional Accessories are retaining plate and stylet made from plastic or stainless steel as it has been cleared in the predicate device's 510(k)s. The Tuohy NRFit™ anaesthesia conduction needles can be used for both, epidural anaesthesia and peripheral nerve blocks each equipped with appropriate labelling as the Tuohy needle in general is a commonly used needle with both clinical demands and techniques. # 12.1 Identification of Predicate devices The Tuohy NRFit™ cannulas/ needles for anesthesia are intended for the transient delivery of anesthetics to provide regional anesthesia and analqesia or to facilitate placement of a catheter. # Predicate Device The predicate device for the Tuohy NRFit™ anaesthesia conduction needles is: - K040965 (Owner: PAJUNK® GmbH Medizintechnologie) PAJUNK TUOHY NEEDLES, QUINCKE NEEDLES, CHIBA NEEDLES & CRAWFORD NEEDLES # 12.2 Determination of Substantial Equivalence # 12.2.1 Intended Use # Intended Use Subject Device The Tuohy NRFit™ cannulas/ needles for anesthesia and analgesia are intended for the transient delivery of anesthetics to provide regional anesthesia and analgesia or to facilitate placement of an epidural catheter. #### Intended Use K040965 Predicate Device Pajunk's anesthesia conduction needles - Tuohy, Quincke, Chiba, and Crawford - are intended for the transient delivery of anesthetics to provide regional anesthesia or to facilitate placement of an epidural catheter. {6}------------------------------------------------ Image /page/6/Picture/0 description: The image shows the word "PAJUNK" in white letters against a teal background. The letters are bold and sans-serif. There is a registered trademark symbol to the right of the K. # 12.2.2 Technical Description # 12.2.2.1 Technical Description Tuohy and Tuohy NRFit™ | Materials used in Tuohy NRFit™ anaesthesia conduction needles: | | | | | Predicate Device | |----------------------------------------------------------------|-----------------------------------|----------------|---------------------------------------------------------|-------------------|----------------------------------------------------------------------------| | | MATERIAL K911221 | | MATERIAL | BODY CONTACT | MATERIAL K040965 | | 01 | Needle/ cannula | Tubing | Stainless Steel 1.4301<br>(X5CrNi18-10), AISI 304 (V2A) | Direct, limited | Stainless Steel 1.4301<br>(X5CrNi18-10), AISI<br>304 (V2A) | | | | Hub | Polycarbonate PC | Indirect, limited | Polycarbonate PC - | | | | Optional: Glue | Epoxy resin | No contact at all | Epoxy resin | | 03 | Stylet<br>(Subcomponent) | Tubing | Stainless Steel 1.4301<br>(X5CrNi18-10), AISI 304 (V2A) | Direct, limited | Stainless Steel 1.4301<br>(X5CrNi18-10), AISI<br>304 (V2A) or<br>Polyamide | | | | knob | Polycarbonate PC - | Indirect, limited | Polycarbonate PC - | | | | Glue | Epoxy resin | No contact at all | Epoxy resin | | 04 | Retaining plate<br>(Subcomponent) | Plate | Polycarbonate PC - | No contact at all | Polycarbonate PC - | Based on substantial equivalence testing listed below the following devices are subject to this premarket notification and shall be cleared: Tuohy NRFit™ in a range from 14G to 22G at a rage of length from 90mm to 150mm. {7}------------------------------------------------ Image /page/7/Picture/0 description: The image shows the word "PAJUNK" in white letters against a teal background. The letters are bold and slightly blurred, giving them a soft appearance. A small registration mark is visible to the upper right of the letter "K". # 12.2.2.1.1 Discussion of differences There are no differences besides the hub connector between the predicate device and the subject device. In order to define regional anesthesia more precise, the Tuohy NRFit™ cannulas/ needles for anesthesia and analgesia shall be cleared for epidural and peripheral use. # 12.2.2.3 Devices under test For demonstrating substantial equivalence the items listed below have been compared: Subject devices under test | # | Devices/ Materials | Item-number | Length [mm] | Gauge | |---|--------------------|-------------|-------------|-------| | 1 | Tuohy NRFit™ | 1166-4T100 | 100 | 14 | | 2 | Tuohy NRFit™ | 1166-4O150 | 150 | 16 | | 3 | Tuohy NRFit™ | 1166-4M090 | 90 | 17 | | 4 | Tuohy NRFit™ | 1166-4K090 | 90 | 18 | | 5 | Tuohy NRFit™ | 1166-4I090 | 90 | 19 | | 6 | Tuohy NRFit™ | 1166-4G090 | 90 | 20 | | 7 | Tuohy NRFit™ | 1166-4F090 | 90 | 21 | | 8 | Tuohy NRFit™ | 1166-4E090 | 90 | 22 | Predicate devices under test | # | Devices/ Materials | Item-number | Length<br>[mm] | Gauge | |---|--------------------|-------------|----------------|-------| | 1 | Tuohy | 1150-4T100 | 100 | 14 | | 2 | Tuohy | 1150-4O150 | 150 | 16 | | 3 | Tuohy | 1150-4M090 | 90 | 17 | | 4 | Tuohy | 1150-4K090 | 90 | 18 | | 5 | Tuohy | 1150-41090 | 90 | 19 | | 6 | Tuohy | 1150-4G090 | 90 | 20 | | 7 | Tuohy | 1150-4F090 | 90 | 21 | | 8 | Tuohy | 1150-4E090 | 90 | 22 | Both, the subject devices as well as the predicate devices have been tested ready to use right after sterilization and have been subject to testing after accelerated aging (1year, 3years, 5years) in order to demonstrate substantial equivalence and Shelf Life. {8}------------------------------------------------ #### Sterilization The predicate device as well as the subject device only differs in design of the hub. This difference does not have any impact on Sterilization. Therefore the Sterilization is still valid. The contract sterilizer and the sterilizing process are identical to the contract sterilizer and the sterilizing process used for all PAJUNK® - manufactured devices which are already cleared for market or exempt. Sterilization parameters are | SAL | 10-6 | |-----------------|----------------------------------------------------------------------------------| | Type of gas | Ethylene Oxide 99,99% | | Exposure time | 300 min. | | Aeration method | evacuation<br>2 airwashes | | Aeration period | residual EtO-gas is removed in circulating<br>air at 40° C (±5) for at least 48h | Sterilization has been validated according to ISO 11135-1 Overkill Approach (1 sublethal cycle, 2 half cycle, 1 full cycle) Residuals of EO and ECH are in compliance with ISO 10993-7. Cleaning and Sterilization method, which ensures an SAL of 10° as well as compliance with limits for chemical burden, bioburden (i.e. LAL and the rabbit pyrogen test) and EtOresiduals as well as shelf life have been validated. The limits listed below are met by each device: Limits for Residuals: 25ppm = 25μg(g/device) of Ethyleneoxide (EO); 25ppm = 25μg/(g/device) Ethylene chlorhydrine Limit for Pyroburden/ endotoxine: 0,06 EU/ml and 2,15 EU/ device acc. to FDA GUIDELINE ON VALIDATION OF LIMULUS AMEBOCYTE LYSATE TEST AS AN END-PRODUCT ENDOTOXIN TEST FOR HUMAN AND ANIMAL PARENTERAL DRUGS, BIOLOGICAL PRODUCTS, AND MEDICAL DEVICES - Issued 12/ 1987 The needles are also available in bulk non sterile. If appropriately packed and sterilized with Ethylene oxide according to the parameters above the technological parameters remain unchanged. However, final responsibility for sterilization remains with the customer of needles purchased bulk non-sterile. {9}------------------------------------------------ ### Shelf Life The predicate device as well as the subject device only differs in design of the hub. This difference does not have any impact on Shelf Life. Therefore the Shelf Life is still valid. Efficacy of sterile product's lifecycle has been validated using similar products and worst case devices. Sterility tests have been performed using worst case devices with similar characteristics made from identical material after 5 years. The devices were found to be sterile after 5 years, the sterile barrier system is efficient. Performance of the essential performance of the device (LUER/ NRFit™ connection, stability of bonding connections, catheter's tensile strength, needle's bending rigidity) has been tested with real time aqed needles and catheters made from identical material employing identical processes and those are found to work properly. There is no decrease in performance after 5 years. The needles are also available in bulk non sterile. If appropriately packed and sterilized with Ethyleneoxide according to the parameters above the technological parameters remain unchanged. However, final responsibility for sterilization remains with the customer of needles purchased bulk non-sterile. Shelf-life is set to 5 years (60 month). {10}------------------------------------------------ Image /page/10/Picture/0 description: The image shows the word "PAJUNK" in white letters against a teal background. The letters are bold and sans-serif. A small registered trademark symbol is located to the right of the letter K. # Biocompatibility: The predicate device as well as the subject device only differs in design of the hub. The manufacturing processes of the subject device and the predicate device are identical. The difference in design does not have any impact on Biocompatibility of the device because the materials used as well as the processes employed (glue or/and direct injection moulding) remain unaltered. Therefore the biocompatibility testing conducted with the predicate device is still valid. All devices comply with ISO 10993-1, 2nd and 3rd edition. According to Table A.1 of Attachment A of this guidance the Tuohy NRFit™ needles, subject to this submission, have been identified as - External communicating device - - -Blood Path, indirect - Limited (<24h) The FDA-recommended tests are: - -Cytotoxicity - -Sensitization - -Irritation or Intracutaneous Reactivity - -Acute Systemic Toxicity - Hemocompatibility - Therefore and based upon sterilization validation and residuals validation the devices are considered to be biocompatible. {11}------------------------------------------------ # Technoloqy Characteristics: The predicate device as well as the subject device only differs in design of the hub. This difference does not have any impact on the performance tests listed below. Therefore performance testing is still valid and applies to both, subject device and predicate device. The performance tests have been accomplished in order to comply with the standards listed below (even though 6-366 and 6-362 are not directly linked with Product Code BSP): | Recognition-# | Standard Number | Title | |---------------|-----------------|-------------------------------------------------------------------------------------------------------------------------------| | 6-366 | ISO 9626 | Stainless steel needle tubing for the manufacture of<br>medical devices - Requirements and test methods | | 6-362 | ISO 7864 | Sterile hypodermic needles for single use -<br>Requirements and test methods | | 5-108 | ISO 80369-6 | Small bore connectors for liquids and gases in<br>healthcare applications - Part 6: Connectors for<br>neuraxial applications. | Stability test Bonding-to-Hub has to be conducted in order to compare the stability of the LUER Hub with the stability of the NRFit™ hub. Furthermore compliance of the needle hub with ISO 80369-6 has to be proven. Standard testing regarding the remaining sections of the recognized performance standards can be conducted using either the predicate device or the subject device because the needle tubing is absolutely identical. #### Needle: stability test bending rigidity Reason for test: The needle has to demonstrate bending stability and resistance against breakage in order to resist forces reasonably assumed to the needle in situ under the defined intended use Procedure of test: The test procedure is defined by international standard ISO/FDIS 9626:2016 Stainless steel needle tubing for manufacture of medical devices. Pass/ Fail criteria: The acceptance criterion of bending rigidity for the cannula is defined in above mentioned standard. Results: The bending rigidity of the predicate device's needles and the subject device's needles is compliant with the standard. Conclusion: Substantially Equivalent {12}------------------------------------------------ Image /page/12/Picture/0 description: The image shows the word "PAJUNK" in white letters against a teal background. The letters are slightly blurred, giving them a soft appearance. A small circle with an R inside is located to the upper right of the K. #### Needle: stability test bonding to hub Reason for test: The needle has to demonstrate stability at the bonding of the hub in order to resist forces reasonably assumed to be applied to the needle in situ under the defined intended use. Procedure of test: The test procedure is defined by international standard ISO/FDIS 7864:2016 Sterile hypodermic needles for single use Pass/ Fail criteria: The acceptance criterion for the bond between hub and needle tube (pull-off force) is ≥22N. Results: For the needles of the subject device and the needles of the predicate device a force significantly higher than the target value has to be applied. Therefore the predicate device 's needles as well as the subject device's needles are substantially equivalent. Conclusion: Substantially Equivalent #### Needle: Penetration force Reason for test: The needles have to demonstrate less trauma when applied with the patient under the intended use. ISO/FDIS 7864:2016 Sterile hypodermic needles for single use recommends penetration force testing only without giving a normative test method. Procedure of test: According to international European standard EN 13097. Pass/ Fail criteria: -none- objective comparison only. Results: The subject device's needles as well as the predicate device's needles show identical penetration/ insertion forces. Conclusion: Substantially Equivalent #### Conclusion: The comparison between the predicate devices and the subject device of this submission as well as the validated sterilization process and the results of the standard testing, bench testing and bench marking demonstrates that the subject devices are substantially equivalent to the predicate devices and substantially equivalent in technical description to devices already cleared for market and therefore demonstrated to be as safe and effective as the legal predicate devices. Actually besides the design of the hub (Subject Device: NRFit™, Predicate Device: LUER) the devices are identical. Based on the rationale provided above and additionally conducted dimension compliance testing for the ISO 80369-6 NRFit™ hub, acceptable performance was demonstrated for Tuohy NRFit™ anaesthesia conduction needles.