K202354 · Hunan Heng Chang Pharmaceutical Co., Ltd. · FXX · Sep 8, 2020 · General, Plastic Surgery
Device Facts
Record ID
K202354
Device Name
Surgical Mask-Model Number CW01
Applicant
Hunan Heng Chang Pharmaceutical Co., Ltd.
Product Code
FXX · General, Plastic Surgery
Decision Date
Sep 8, 2020
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 878.4040
Device Class
Class 2
Indications for Use
The Surgical Masks are intended to be worn to protect both the patient and healthcare personnel from transfer of microorganisms, body fluids and particulate material. These face masks are intended for use in infection control practices to reduce the potential exposure to blood and body fluids. This is a single use, disposable device(s), provided non-sterile/sterile.
Device Story
Flat-pleated surgical mask; 3-layer construction; outer layer spun-bonded polypropylene; middle layer melt-blown polypropylene filter; inner layer polypropylene fabric; ear loops (spandex/polyester); malleable polyethylene nose piece. Single-use, disposable; provided non-sterile or sterile (EO). Worn by healthcare personnel and patients to provide barrier protection against microorganisms, body fluids, and particulates. Used in clinical infection control practices.
Clinical Evidence
No clinical data. Bench testing only. Performance verified against ASTM F1862 (fluid resistance), ASTM F2299 (particulate filtration efficiency 95.8-96.8%), ASTM F2101 (bacterial filtration efficiency 98.3-99.2%), EN 14683 (differential pressure 3.7-3.8 mmH2O/cm²), and 16 CFR 1610 (flammability). Biocompatibility confirmed per ISO 10993-5 and 10993-10.
Technological Characteristics
3-layer flat-pleated mask. Materials: Spun-bonded polypropylene (outer/inner), melt-blown polypropylene (filter). Ear loops: Spandex/Polyester. Nose piece: Malleable polyethylene. Dimensions: 17.5cm x 9.5cm. Sterilization: EO. Biocompatibility: ISO 10993 series. Performance: ASTM F2100 Level 1.
Indications for Use
Indicated for use by healthcare personnel and patients to reduce exposure to microorganisms, body fluids, and particulate material in infection control settings.
Regulatory Classification
Identification
Surgical apparel are devices that are intended to be worn by operating room personnel during surgical procedures to protect both the surgical patient and the operating room personnel from transfer of microorganisms, body fluids, and particulate material. Examples include surgical caps, hoods, masks, gowns, operating room shoes and shoe covers, and isolation masks and gowns. Surgical suits and dresses, commonly known as scrub suits, are excluded.
Special Controls
*Classification.* (1) Class II (special controls) for surgical gowns and surgical masks. A surgical N95 respirator or N95 filtering facepiece respirator is not exempt if it is intended to prevent specific diseases or infections, or it is labeled or otherwise represented as filtering surgical smoke or plumes, filtering specific amounts of viruses or bacteria, reducing the amount of and/or killing viruses, bacteria, or fungi, or affecting allergenicity, or it contains coating technologies unrelated to filtration (e.g., to reduce and or kill microorganisms). Surgical N95 respirators and N95 filtering facepiece respirators are exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to § 878.9, and the following conditions for exemption:(i) The user contacting components of the device must be demonstrated to be biocompatible.
(ii) Analysis and nonclinical testing must:
(A) Characterize flammability and be demonstrated to be appropriate for the intended environment of use; and
(B) Demonstrate the ability of the device to resist penetration by fluids, such as blood and body fluids, at a velocity consistent with the intended use of the device.
(iii) NIOSH approved under its regulation.
(2) Class I (general controls) for surgical apparel other than surgical gowns and surgical masks. The class I device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to § 878.9.
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September 8, 2020 Hunan Heng Chang Pharmaceutical Co., Ltd. % Shelley Li Director Shanghai Landlink Medical Information Technology Co., Ltd. Room 703, 705, Baohua International Plaza, West Guangzhong Road 555, Jingan Shanghai. 200071 China
Re: K202354
Trade/Device Name: Surgical Mask-Model Number CW01 Regulation Number: 21 CFR 878.4040 Regulation Name: Surgical apparel Regulatory Class: Class II Product Code: FXX Dated: August 13, 2020 Received: August 19, 2020
Dear Shelley Li:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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
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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 of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
For CAPT Elizabeth Claverie, M.S. DHT4B: Division of Infection Control and Plastic Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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#### Indications for Use
510(k) Number (if known) K202354
Device Name Surgical Mask
Indications for Use (Describe)
The Surgical Masks are intended to be worn to protect both the patient and healthcare personnel from transfer of microorganisms, body fluids and particulate material. These face masks are intended for use in infection control practices to reduce the potential exposure to blood and body fluids. This is a single use, disposable device(s), provided non-sterile/ sterile.
Type of Use (Select one or both, as applicable)
| <input type="checkbox"/> Registration Use (Part 21 CFR 201.2 Subject to Review) | <input checked="" type="checkbox"/> Over-The-Counter Use (21 CFR 201.2 Subject to Review) |
|---------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------|
|---------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------|
_ | Prescription Use (Part 21 CFR 801 Subpart D)
|X | Over-The-Counter Use (21 CFR 801 Subpart C)
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# 510(k) Summary: K202354
#### I Submitter
Hunan Heng Chang Pharmaceutical Co., Ltd.
Floor 2, 3, 102 of Building 16, Standard Plant of Shanhe Pharmaceutical and Health Industrial Park, No. 1048, Zhongqing Road, Kaifu District, Changsha 410000, China
Contact person: Tao Jingfeng Position: QC Manager Tel.: ++86-18774961605 E-mail: taojingfeng@hcyy.com
Preparation date: Aug. 27, 2020
### II Proposed Device
| Trade Name of Device: | Surgical Mask |
|-----------------------|------------------|
| Common name: | Surgical Mask |
| Regulation Number: | 21 CFR 878.4040 |
| Regulatory Class: | Class II |
| Product code: | FXX |
| Review Panel: | General Hospital |
| 510(k) Number: | K202354 |
### III Predicate Devices
| 510(k) Number: | K153496 |
|-----------------|-----------------------------------------|
| Trade name: | Disposable Surgical Face Mask |
| Common name: | Surgical Mask |
| Classification: | Class II |
| Product Code: | FXX |
| Manufacturer | Xiantao Rayxin Medical Product Co., Ltd |
### IV Device description
The Surgical Masks are Flat Pleated type mask, utilizing Ear Loops way for wearing, and they all have Nose Piece design for fitting the face mask around the nose. The Face Masks are manufactured with three layers. The outer layer is made of spunbonded polypropylene (PP) non-woven fabric. The middle layer with filtration function is made of melt blown polypropylene (PP) non-woven fabric. The inner layer
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contact with face is made of polypropylene (PP) fabric.
The Surgical Masks are single use, disposable device, provided non-sterile/sterile.
## V Indication for use
The Surgical Masks are intended to be worn to protect both the patient and healthcare personnel from transfer of microorganisms, body fluids and particulate material. These face masks are intended for use in infection control practices to reduce the potential exposure to blood and body fluids. This is a single use, disposable device(s), provided non-sterile/sterile.
| Item | Proposed device<br>(K202354) | Predicate device<br>(K153496) |
|--------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Product name | Surgical Mask | Disposable Surgical Face<br>Mask |
| Product Code | FXX | FXX |
| Regulation No. | 21 CFR 878.4040 | 21 CFR 878.4040 |
| Class | Class II | Class II |
| Mask style | Flat-pleated, ear loop, 3<br>layers | Flat-pleated, ear loop, tie-on,<br>3 layers |
| Indication for use | The Surgical Masks are<br>intended to be worn to<br>protect both the patient and<br>healthcare personnel from<br>transfer of microorganisms,<br>body fluids and particulate<br>material. These face masks<br>are intended for use in<br>infection control practices to<br>reduce the potential<br>exposure to blood and body<br>fluids. This is a single use,<br>disposable device(s),<br>provided non-sterile/ sterile. | The Disposable Surgical<br>Face Masks are intended to<br>be worn to protect both the<br>Patient and healthcare<br>personnel from transfer of<br>microorganisms, body fluids<br>and particulate material.<br>These face masks are<br>intended for use in infection<br>control practices to reduce<br>the potential exposure to<br>blood and body fluids. This is<br>a single use, disposable<br>device(s), provided non-<br>sterile. |
| Material | Inner<br>Spun-bond polypropylene | Spun-bond polypropylene |
#### VI Comparison of technological characteristics with the predicate devices
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| | layer | | |
|----------------------|--------------|-----------------------------------------------------------|-----------------------------------------------------------|
| | Middle layer | Melt blown polypropylene filter | Melt blown polypropylene filter |
| | Outer layer | Spun-bond polypropylene | Spun-bond polypropylene |
| | Ear loop | Spandex + Polyester | Polyester |
| | Nose piece | malleable polyethylene | Malleable aluminum wire |
| Color | | Blue | blue |
| Length | | $17.5 cm±5%$ | $17.5±1cm$ |
| Width | | $9.5 cm±5%$ | $9.5±1cm$ |
| OTC use | | Yes | Yes |
| sterile | | Non-sterile, sterile | Non-sterile |
| Sterilization method | | EO | / |
| Single for use | | Yes | Yes |
| ASTM F2100 Level | | Level 1 | Level 2 |
| Biocompatibility | | Confirm to the requirements of ISO 10993 series standards | Confirm to the requirements of ISO 10993 series standards |
# VII Summary of Non-Clinical Testing
Non clinical performance tests were conducted to verify that the proposed device met all design specifications. The below table shows the test results of test article, which demonstrated that the proposed device complies with the following standards:
| Methodology | Purpose | Acceptance Criteria | Results |
|--------------------|--------------------------------------|---------------------------------|---------------------------------|
| ASTM F1862M-<br>17 | Fluid Resistance<br>Performance | 29 out of 32 pass<br>at 120mmHg | 32 out of 32 pass<br>at 120mmHg |
| ASTM F2299 | Particulate Filtration<br>Efficiency | ≥95% | 95.8~96.8% |
| ASTM F2101-19 | Bacterial Filtration<br>Efficiency | ≥95% | 98.3~99.2% |
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| EN 14683:2019<br>Annex C | Differential<br>Pressure | < 5.0mmH2O/cm² | 3.7~3.8<br>mmH2O/cm² |
|--------------------------|--------------------------|-----------------------|----------------------|
| 16 CFR 1610 | Flammability | Class I non flammable | non flammable |
- ISO 10993-5: 2009 Biological Evaluation Of Medical Devices -- Part 5: Tests For ● In Vitro Cvtotoxicity
- ISO 10993-10: 2010 Biological Evaluation Of Medical Devices Part 10: Tests For . Irritation And Skin Sensitization.
- ASTM F2100-19, Standard Specification for Performance of Materials Used In . Medical Face Masks.
- ASTM F1862M-17, Standard Test Method For Resistance Of Medical Face Masks . To Penetration By Synthetic Blood (Horizontal Projection Of Fixed Volume At A Known Velocity)
- EN 14683:2019, Medical Face Mask-Test-Requirements and TestMethods; ●
- ASTM F2101-19, Standard Test Method For Evaluating The Bacterial Filtration ● Efficiency (BFE) Of Medical Face Mask Materials, Using A Biological Aerosol Of Staphylococcus Aureus;
- ASTM F2299-03, Stand test method for determining the initial efficiency of . materials used in medical face masks to penetration by particulates using latex spheres:
- 16 CFR 1610, Standard for the Flammability of clothing textiles; ●
# VIII Summary of Clinical Testing
No clinical study is included in this submission.
### IX Conclusion
The conclusion drawn from the non-clinical performance testing data demonstrates that the subject device is as safe, as effective, and performs as well as or better than the predicate device, Disposable Surgical Face Mask (K153496).
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