MR Conditional CGA 870
Device Facts
| Record ID | K162811 |
|---|---|
| Device Name | MR Conditional CGA 870 |
| Applicant | Essex Industries, Inc. |
| Product Code | CAN · Anesthesiology |
| Decision Date | Mar 2, 2017 |
| Decision | SESE |
| Submission Type | Traditional |
| Regulation | 21 CFR 868.2700 |
| Device Class | Class 1 |
| Attributes | Therapeutic |
Indications for Use
The Essex MR Conditional CGA 870 pressure regulators are used with a portable oxygen delivery system intended to provide supplemental oxygen to adults in hospital, sub-acute care, and pre-hospital / ground transport settings. It is offered in models that are MR-conditional (per ASTM F2052-15), and may be used during MR imaging for static magnetic fields of 3.0 T or less.
Device Story
The MR Conditional CGA 870 is a mechanical oxygen pressure regulator designed for attachment to medical CGA 870 post-valve cylinders. It regulates high-pressure oxygen (500–2,000 psig) down to a nominal 50 psig for delivery via an integrated flow selector valve (0–25 L/min). Operated by clinicians in hospitals, outpatient centers, and pre-hospital transport, the device allows for supplemental oxygen delivery during MRI procedures due to its MR-conditional material composition. It functions as a single-stage piston regulator. The device provides a visual contents gauge for monitoring. By enabling oxygen therapy within the MRI suite, it ensures patient safety and continuity of care during imaging. It does not require external power or software.
Clinical Evidence
No clinical data. Substantial equivalence is supported by bench testing, including performance testing per CGA E-4, CGA E-7, ISO 10524, and EN 738-1, as well as MR-conditional testing per ASTM F2052-15 and biocompatibility evaluations (VOC and PM2.5).
Technological Characteristics
Single-stage piston pressure regulator; yoke-style inlet (CGA 870); flow selector (0-25 L/min); output pressure ~50 psig. Materials meet ASTM F2052-15 for MR-conditional use (3.0 T or less). Standards: CGA E-4, CGA E-7, ISO 10524-1, EN 738-1. Mechanical operation; no energy source or software.
Indications for Use
Indicated for adult patients requiring supplemental oxygen in hospital, sub-acute care, and pre-hospital/ground transport settings, including during MR imaging (up to 3.0 T).
Regulatory Classification
Identification
A pressure regulator is a device, often called a pressure-reducing valve, that is intended for medical purposes and that is used to convert a medical gas pressure from a high variable pressure to a lower, more constant working pressure. This device includes mechanical oxygen regulators.
Predicate Devices
- Essex CGA 870 oxygen pressure regulator (Class 1, exempt)
Reference Devices
- Linde LIV Portable Oxygen System (K101792)
Submission Summary (Full Text)
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
March 2, 2017
Essex Industries, Inc. % Paul Dryden Consultant 7700 Gravois St. Louis, Missouri 63123
Re: K162811
Trade/Device Name: MR Conditional CGA 870 Regulation Number: 21 CFR 868.2700 Regulation Name: Pressure Regulator Regulatory Class: Class I Product Code: CAN Dated: January 27, 2017 Received: January 31, 2017
Dear Paul Dryden:
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 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.
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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,
# Lori A. Wiggins -S
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
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# Indications for Use
510(k) Number (if known) K162811
Device Name MR Conditional CGA 870
#### Indications for Use (Describe)
The Essex MR Conditional CGA 870 pressure regulators are used with a portable oxygen delivery system intended to provide supplemental oxygen to adults in hospital / ground transport settings. It is offered in models that are MR-conditional (per ASTM F2052-15), and may be used during MR imaging for static magnetic fields of 3.0 T or less.
Type of Use (Select one or both, as applicable)
| <span style="font-size:10px">☑</span> Prescription Use (Part 21 CER 801 Subpart D) |
|------------------------------------------------------------------------------------|
| ☐ Over-The-Counter Use (21 CFR 801 Subpart C) |
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#### 510(k) Summary Page 1 of 6 3/2/2017
Essex Industries, Inc. 7700 Gravois St. Louis, MO 63123
| Official Contact: | Russ Jacobsmeyer - Vice President of Engineering<br>Tel – 314.338.8723 |
|----------------------------------------|-----------------------------------------------------------------------------------------------------------|
| Proprietary or Trade Name: | Essex MR Conditional CGA 870 |
| Common/Usual Name: | Cylinder, Compressed Gas, and Valve |
| Classification Name/Code: | CAN - Cylinder, Compressed Gas, and Valve<br>Class I, 21 CFR 868.2700 |
| Predicate Device:<br>Reference Device: | Essex CGA 870 oxygen pressure regulator (Class 1, exempt)<br>K101792 – Linde – LIV Portable Oxygen System |
#### Device Description:
The Essex MR Conditional CGA 870 pressure regulator is designed to be installed on a medical CGA 870 post valve cylinder, regulate high pressure oxygen from 500 to 2,000 psig nominal, deliver a specific amount of oxygen to an attached flow selector, and be ignition resistant.
The device consists of:
- A yoke style inlet fitting per CGA 870. .
- The regulator can be installed on any cylinder with a CGA 870 connection. O
- A pressure regulator section is to reduce the pressure from 500-2,000 psig to 50 psig nominal. ●
- A flow selector valve to control the flow at the regulated pressure between 0 and 25 L/min. ●
- Made of materials which meet the MR Conditional requirements of ASTM F2052-15.
This is identical to our Class I, exempt model CGA 870 except for different materials to allow for the device to meet the ASTM F2052-15 - Standard Test Method for Measurement of Magnetically Induced Displacement Force on Medical Devices in the Magnetic Resonance Environment.
#### Indications for Use:
The Essex MR Conditional CGA 870 pressure regulators are used with a portable oxygen delivery system intended to provide supplemental oxygen to adults in hospital, sub-acute care, and pre-hospital / ground transport settings. It is offered in models that are MR-conditional (per ASTM F2052-15), and may be used during MR imaging for static magnetic fields of 3.0 T or less.
Environments of Use: Their environments of use include all healthcare settings including:
- Hospital, including intra-hospital transport ●
- Outpatient
- Imaging center (MRI Suite) ●
- Pre-hospital ●
#### Contraindications: None.
#### Summary of substantial equivalence
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#### 510(k) Summary Page 2 of 6 3/2/2017
The proposed device has been compared to the predicate Essex CGA 870 oxygen pressure regulator (Class 1, exempt) for the technical characteristics, see Table 1 and the reference device for environment of use, MR Conditional, and see Table 2.
# Device Comparison
| Description | Predicate | Subject Device |
|-----------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | CGA 870 Device, Class I, exempt | MR Conditional CGA 870 |
| Device Name | CGA 870 | MR Conditional CGA 870 |
| Device Classification<br>& Product code | Class I / CAN | Class I / CAN |
| Prescription Device | Yes | Yes |
| Indications for Use | The Essex CGA 870 pressure regulator<br>is a portable oxygen delivery system<br>intended to provide supplemental<br>oxygen too pediatrics and adults in<br>hospital, sub-acute care, and pre-hospital<br>/ ground transport settings. | The Essex MR Conditional CGA 870<br>pressure regulators are used with a<br>portable oxygen delivery system<br>intended to provide supplemental<br>oxygen to adults in hospital, sub-acute<br>care, and pre-hospital / ground<br>transport settings. It is offered in<br>models that are MR-conditional (per<br>ASTM F2052-15), and may be used<br>during MR imaging for static magnetic<br>fields of 3.0 T or less. |
| Flow selector and<br>Flow Outlet | Yes | Yes |
| Fixed pressure<br>outlet | Yes ~ 50 psig | Yes ~ 50 psig |
| Cylinder On/Off | Yes | Yes |
| Filling Port | No<br>When cylinder is empty the device is<br>attached to a new cylinder | No<br>When cylinder is empty the device is<br>attached to a new cylinder |
| Contents Gauge | Yes / active | Yes / active |
| Excess Flow | No | No |
| Burst Disk | Burst Disk is located on the cylinder<br>post valve. | Burst Disk is located on the cylinder<br>post valve. |
| Single stage piston<br>type | Yes | Yes |
| MR Conditional | N/A | 3.0 Tesla or less |
| Pressure Inlet | 2000 psig | 2000 psig |
| Flow rates | 0-25 L/min | 0-25 L/min |
| Operating Pressure<br>range | 500-2000 psig | 500-2000 psig |
| Operating<br>Temperature Range | -20°F to 130°F | -20°F to 130°F |
#### Table 1 - Comparison of Predicate Essex CGA 870 to the Subject Device -MR Conditional CGA 870
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# 510(k) Summary Page 3 of 6 3/2/2017
| Description | Predicate | Subject Device |
|------------------|-----------------------------------|-----------------------------------|
| Standards | CGA 870 Device, Class I, exempt | MR Conditional CGA 870 |
| | ISO 10524-1 | ISO 10524-1 |
| | CGA E-4 | CGA E-4 |
| | CGA E-7 | CGA E-7 |
| | EN 738-1 | EN 738-1 |
| | | ASTM F2052-15 |
| Biocompatibility | Externally communicating, Tissue, | Externally communicating, Tissue, |
| | Permanent duration | Permanent duration |
| | VOC | VOC |
| | PM2.5 | PM2.5 |
# Table 2 - Comparison of Reference Linde LIV (K101792) to the Subject Device -MR Conditional CG 870
| Description | Reference Device | Subject Device |
|-----------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | Linde LIV - K101792 | MR Conditional CGA 870 |
| Device Name | LIV | MR Conditional CGA 870 |
| Device Classification<br>& Product code | Unclassified/ECX | Class I / CAN |
| Prescription Device | Yes | Yes |
| Indications for Use | The LIV is an integrated portable oxygen<br>delivery system intended to provide<br>supplemental oxygen to pediatrics and<br>adults. The device is MR-conditional (per<br>ASTM F2503-05*), and intended for use<br>during MR imaging for MRI systems up to<br>3.0T.<br><br>Compressed gas cylinders in service or in<br>storage shall be stabilized or otherwise<br>secured to prevent falling and rolling. | The Essex MR Conditional CGA 870<br>pressure regulators are used with a<br>portable oxygen delivery system intended<br>to provide supplemental oxygen to adults<br>in hospital, sub-acute care, and pre-<br>hospital / ground transport settings. It is<br>offered in models that are MR-conditional<br>(per ASTM F2052-15), and may be used<br>during MR imaging for static magnetic<br>fields of 3.0 T or less. |
| Flow selector and<br>Flow Outlet | Yes | Yes |
| Fixed pressure<br>outlet | Yes ~ 50 psig | Yes ~ 50 psig |
| Cylinder On/Off | Yes | Yes |
| Filling Port | Yes | When cylinder is empty the device is<br>attached to a new cylinder |
| Contents Gauge | Yes / active | Yes / active |
| Excess Flow | No | No |
| Burst Disk | Yes integral to the system | Burst Disk is located on the cylinder post<br>valve. |
| Single stage piston<br>type | Yes | Yes |
| Hand grip | Yes | No |
| Access ports | Yes | No |
| MR Conditional | 3.0 Tesla | 3.0 Tesla or less |
| Pressure Inlet | 2000 psig | 2000 psig |
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#### 510(k) Summary Page 4 of 6 3/2/2017
| Description | Reference Device | Subject Device |
|-----------------------------|---------------------------------------------------------------------|-------------------------------------------------------------------------|
| | Linde LIV - K101792 | MR Conditional CGA 870 |
| DISS 1240 fittings | Yes | No<br>Not applicable |
| Flow rates | 0-25 L/min | 0-25 L/min |
| Operating Pressure range | Up to 3000 psig | 500-2000 psig |
| Operating Temperature Range | | -20°F to 130°F |
| | ISO 10524-3<br>ASTM G173-03<br>CGA E-7<br>CGA 540<br>ASTM F2503-05* | ISO 10524-1<br>CGA E-4<br>CGA E-7<br>EN 738-1<br>ASTM F2052-15* |
| Standards | | |
| Biocompatibility | Externally communicating, Tissue,<br>Permanent duration | Externally communicating, Tissue,<br>Permanent duration<br>VOC<br>PM2.5 |
*Note ASTM F2503-05 is a device marking and labeling standard whereas ASTM F2052-15 is the Testing and Performance standard.
The proposed MR Conditional CGA 870 is viewed as substantially equivalent to the predicate device for the performance, intended use and technical characteristics and the reference device for the addition of the MR conditional environment of use. In the tables above, we have outlined the similarities and differences, if any, between the subject device, the predicate and reference devices.
#### Indications -
- The MR Conditional CGA 870 is a standalone oxygen pressure regulator intended to provide supplemental oxygen.
- Discussion - The indications for the predicate and reference are similar with the predicate. One can find the indications for use to be similar and the differences do not raise any concerns of safety or effectiveness compared to the predicate or reference devices.
#### Patient Population -
- It is intended for adult patients requiring supplemental oxygen ●
- Discussion The patient population is similar to the predicate and reference device. There are ● no differences that raise any concerns of safety or effectiveness compared to the predicate or reference devices.
#### Environment of Use -
- For use in all healthcare settings hospitals, ambulatory, imaging centers, pre-hospital. ●
- Discussion The environments of use are similar to the predicate and reference devices. The . addition of MR Conditional use has been demonstrated to meet the standard which would not raise any new concerns of safety and effectiveness.
#### Technology -
- The principle of pressure regulating is based upon a single stage piston style with adjustable flow rates, flow gauge, burst disk and use of a separate cylinder.
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#### 510(k) Summary Page 5 of 6 3/2/2017
- . Discussion - This technology is identical to the predicate device and similar to the reference.
#### Differences
The only difference between the reference and the subject device is the change in materials to be MR Conditional. The difference between the reference and the subject device is that the predicate is an integrated regulator and the subject device is not. Discussion - These differences do not raise any new concerns of safety or effectiveness.
#### Non-clinical Testing Summary -
We have performed a number of tests appropriate for the proposed device. These tests include:
- CGA E-4: Standard for Gas Pressure Regulators ●
- o par. 4.1 Operating Temperature Range
- par. 4.2.2.3 Resistance to Ignition (Oxygen Service) O
- par. 4.4 Gas Tightness O
- par. 4.5 Mechanical Resistance O
- par. 4.6 Endurance O
- par. 5.4 Pressure Relief Devices O
- par. 6.1 Pressure Regulation Coefficient, i O
- par. 6.2 Static Increment, SI O
- par. 6.3 Flow Regulation O
- par. 6.4 Flow Capacity O
- CGA E-7: American National Standard for Medical Gas Regulators and Flowmeters ●
- par. 5.4 Relief Valves റ
- par. 5.6.1 Minimum Burst Strength O
- par. 5.6.2 Leakage o
- o par. 5.7 Temperature for Storage and Operation
- ISO 10524: Pressure Regulators and Pressure Regulators with Flow-Metering Devices for Medical Gas Systems
- o par. 7.3 Pressure relief valve
- par. 7.5 Resistance to ignition O
- par. 7.8 Gas tightness O
- par. 7.9.3 Mechanical resistance (high pressure section burst) O
- par. 7.9.4 Mechanical resistance (low pressure section burst) O
- par. 8.0 Environmental temperatures O
- EN 738-1: Pressure Regulators for use with Medical Gases ●
- par. 5.4.2.7 Performance, functional, and flow characteristics o
- O par. 5.4.2.8 Relief valve
- par. 5.4.2.9 Leakage o
- par. 5.4.2.10 Mechanical Strength O
- par. 5.4.2.11 Resistance to ignition O
- MR Conditional Testing per ASTM F2052-15 (Note testing was done according to ASTM ● F2052-06 but there are no testing differences between the 2006 version and the 2015 version.
- Biocompatibility (VOC and PM2.5) ●
#### Bench Testing -
- The performance testing is based upon standards for material, construction, ignition, MRI ● compatibility, and accuracy.
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### 510(k) Summary Page 6 of 6 3/2/2017
- . Discussion - Based upon the testing and comparison to the standards, we can find the subject device and the predicate and reference devices to be substantially equivalent.
# Biocompatibility of Materials -
- ISO 10993-1 would consider the materials in the gas pathway as - Externally communicating, Tissue / Dentin / Bone contact, Permanent Duration.
- The materials were evaluated per CGA E-4 for ignition and for biocompatibility via VOC and . PM23.5 The testing demonstrated that the materials were biocompatible for their intended use.
- Discussion – The materials were found to be compatible for their intended use and identical to the reference.
#### Animal Testing:
There was no animal testing.
#### Clinical Testing:
There was no clinical testing.
#### Substantial Equivalence Conclusion:
The sponsor has demonstrated through performance testing and non-clinical testing that the proposed device is substantially equivalent to the predicate and reference devices.
