Who is the manufacturer of PICO?

Smith & Nephew, Inc. filed the 510(k) submission for PICO (K111170).

What is the FDA product code for PICO?

OMP. It is classified under 21 CFR 878.4780 as a Class 2 device in the General, Plastic Surgery panel.

What is the regulatory pathway for PICO?

510(k) clearance (submission type: Traditional).

What are the predicate devices for PICO?

NPD 1000 Negative Pressure Wound Therapy System (K080275); Renasys Go (K083375); Prevena Incision Management System (K100821).

Who can help prepare an FDA 510(k) submission like PICO?

Innolitics — a medical-device software consultancy — provides regulatory and engineering support for FDA 510(k) submissions. See https://innolitics.com/services/510ks/ or contact https://innolitics.com/contact.

PICO

K111170 · Smith & Nephew, Inc. · OMP · Dec 15, 2011 · General, Plastic Surgery

Device Facts

Record ID	K111170
Device Name	PICO
Applicant	Smith & Nephew, Inc.
Product Code	OMP · General, Plastic Surgery
Decision Date	Dec 15, 2011
Decision	SESE
Submission Type	Traditional
Regulation	21 CFR 878.4780
Device Class	Class 2
Attributes	Therapeutic

Intended Use

PICO is indicated for patients who would benefit from a suction device (negative pressure wound therapy) as it may promote wound healing via removal of low to moderate levels of exudate and infectious materials. Product Codes: 66800862, 66800863, 66800865 and 66800866 are indicated for use on low and moderately exuding wounds. Examples of appropriate wound types include: Chronic . Acute . Traumatic . Subacute and dehisced wounds . Partial-thickness burns . Ulcers (such as diabetic or pressure) . Flaps and grafts . Closed surgical incisions . PICO Single Use Negative Pressure Wound Therapy System is suitable for use in both a hospital and homecare setting. PICO is indicated for patients who would benefit from a suction device (negative pressure wound therapy) as it may promote wound healing via removal of low levels of exudate and infectious materials. Product Codes: 66800864, 66800867, 66800868 and 66800869 are indicated for use on low exuding wounds, Examples of appropriate wound types include: Chronic . Acute . Traumatic . Subacute and dehisced wounds . Partial-thickness burns . Ulcers (such as diabetic or pressure) . Flaps and grafts . Closed surgical incisions . PICO Single Use Negative Pressure Wound Therapy System is suitable for use in both a hospital and homecare setting.

Device Story

PICO is a portable, single-use negative pressure wound therapy (NPWT) system. It consists of an electric motor-driven, twin-diaphragm vacuum pump connected to a super-absorbent, adhesive dressing. The pump is battery-operated (two AA lithium batteries) and provides up to 168 hours (7 days) of therapy. Operation involves applying the dressing to the wound, securing it with fixation strips, and activating the pump to create negative pressure, which draws excess fluid into the dressing. The device is designed to automatically stop after 168 hours and will not restart. Used in hospital and homecare settings by clinicians or patients. The system provides a non-invasive method to manage wound exudate, potentially promoting healing. Healthcare providers monitor the wound and dressing status to inform clinical decisions.

Clinical Evidence

Bench testing only. Biocompatibility testing (cytotoxicity, sensitization, irritation) performed per ISO 10993-5 and ISO 10993-10. Electrical safety and electromagnetic compatibility testing performed per IEC 60601-1 and IEC 60601-1-2. Software validation performed per IEC 62304. Wound healing study referenced for the wound contact layer (ALLEVYN Gentle Border).

Technological Characteristics

Portable, battery-operated (2x AA lithium) twin-diaphragm vacuum pump. System includes super-absorbent adhesive dressing and secondary fixation strips. Materials assessed for biocompatibility per ISO 10993. Complies with IEC 60601-1 (electrical safety) and IEC 60601-1-2 (EMC). Single-use, non-sterile pump; sterile dressing/strips. Software validated per IEC 62304.

Indications for Use

Indicated for patients requiring negative pressure wound therapy to promote healing via removal of low to moderate exudate and infectious materials. Applicable to chronic, acute, traumatic, subacute, dehisced wounds, partial-thickness burns, ulcers (diabetic/pressure), flaps, grafts, and closed surgical incisions. Suitable for hospital and homecare settings.

Regulatory Classification

Identification

A powered suction pump is a portable, AC-powered or compressed air-powered device intended to be used to remove infectious materials from wounds or fluids from a patient's airway or respiratory support system. The device may be used during surgery in the operating room or at the patient's bedside. The device may include a microbial filter.

Predicate Devices

NPD 1000 Negative Pressure Wound Therapy System (K080275)
Renasys Go (K083375)
Prevena Incision Management System (K100821)

Related Devices

K112127 — PICO SINGLE USE NEGATIVE PRESSURE WOUND THERAPY SYSTEM · Smith & Nephew, Inc. · May 16, 2012
K163387 — PICO Single Use Negative Pressure Wound Therapy System · Smith & Nephew Medical Limited · Apr 18, 2017
K151436 — PICO Single Use Negative Pressure Wound Therapy System · Smith & Nephew Medical, Ltd. · Jan 28, 2016
K172519 — PICO Single Use Negative Pressure Wound Therapy System · Smith & Nephew Medical Limited · Sep 15, 2017
K172005 — PICO 7 Single Use Negative Pressure Wound Therapy System · Smith & Nephew Medical Limited · Feb 2, 2018

Submission Summary (Full Text)

{0}------------------------------------------------ K111170 DEC 1 5 2011 pg 10+6 ## 510(k) SUMMARY ### PICO Single Use Negative Pressure Wound Therapy System | 1. Submitter: | Smith & Nephew, Inc. | |---------------|------------------------------------| | | 970 Lake Carillon Drive, Suite 110 | | | St. Petersburg, FL 33716 | - 2. Contact: Terry McMahon Director of Regulatory Affairs & Quality, North America 727-399-3785 Email: terry.mcmahon@smith-nephew.com - 3. Device name: PICO Single Use Negative Pressure Wound Therapy System Common name: Negative Pressure Wound Therapy powered suction pump Classification name: Powered suction pump (21 CFR 878.4780) Product Classification/Code: Class II, OMP - 4. Date summary prepared: December 15, 2011 - 5. Predicate Device Information: NPD 1000 Negative Pressure Wound Therapy System (K080275) Kalypto Medical 6393 Oakgreen Avenue Hastings, MN 55033 Renasys Go (K083375) Smith & Nephew Inc, St. Petesburg, FL {1}------------------------------------------------ KIIII70 Prevena Incision Management System (K100821) KCI USA, INC. 6203 Farinon Dr. San Antonio, TX 78249 #### 6. Device Description: PICO Single Use Negative Pressure Wound Therapy System is a small, lightweight, portable suction device consisting of a electric motor driven, twindiaphraqm, vacuum pump connected to a super-absorbent, gentle adhesive dressing. The pump is supplied non-sterile and single use, the dressing and secondary fixations strips are supplied sterile and single use. The dressing is applied to the wound and secondary fixation strips are placed over the outside edges to help hold the dressing in place. When the suction pump is turned on, air is pulled out of the dressing creating negative pressure and drawing excess fluid from the wound into the dressing. The pump is battery operated and is supplied with two AA lithium batteries which provide up to 168 hours (7 days) of battery life depending upon leak rate. The batteries can be replaced if required. The pump is designed to stop working after 168 hours (7 days) of use and will not re-start after this time, even with new batteries. Negative pressure will not be applied at this point. PICO Single Use Negative Pressure Wound Therapy System is suitable for use in both a hospital and homecare setting. A carry bag is not provided with the system however will be available to order separately. {2}------------------------------------------------ KIIII70 pg 3 of fo ### 7. Intended Use # 7a. Low and moderately exuding wounds PICO is indicated for patients who would benefit from a suction device (negative pressure wound therapy) as it may promote wound healing via removal of low to moderate levels of exudate and infectious materials. Product Codes: 66800862, 66800863, 66800865 and 66800866 are indicated for use on low and moderately exuding wounds. Examples of appropriate wound types include: - Chronic . - Acute . - Traumatic . - Subacute and dehisced wounds . - Partial-thickness burns . - Ulcers (such as diabetic or pressure) . - Flaps and grafts . - Closed surgical incisions . PICO Single Use Negative Pressure Wound Therapy System is suitable for use in both a hospital and homecare setting. {3}------------------------------------------------ K111170 #### 7b. Low exuding wounds PICO is indicated for patients who would benefit from a suction device (negative pressure wound therapy) as it may promote wound healing via removal of low levels of exudate and infectious materials. Product Codes: 66800864, 66800867, 66800868 and 66800869 are indicated for use on low exuding wounds, Examples of appropriate wound types include: - Chronic . - Acute . - Traumatic . - Subacute and dehisced wounds . - Partial-thickness burns . � - Ulcers (such as diabetic or pressure) . - . Flaps and grafts - Closed surgical incisions . PICO Single Use Negative Pressure Wound Therapy System is suitable for use in both a hospital and homecare setting. #### 8. Summary of Non-Clinical Testing The biocompatibility of the PICO Single Use Negative Pressure Wound Therapy System has been demonstrated through assessment according to ISO 10993-1: 2003 and appropriate in vivo and in vitro tests have been conducted using product that has been packaged and sterilised. These tests include cytotoxicity, sensitization and irritation and cover the PICO dressing and secondary fixation strips. These studies indicated that the PICO Single Use Negative Pressure Wound Therapy System is safe for its intended use. {4}------------------------------------------------ KIIII70. pg 5 of 6 | Test | Description of Method | Result | |---------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------| | Cytotoxicity | PICO Dressing In order to determine the cytotoxic potential of the dressing, a Minimum Essential Medium (MEM) elution assay was conducted in accordance with ISO 10993-5. | N to 1:16, all non-cytotoxic (Grade 0) | | | Secondary Fixation Strips Cytotoxicity testing has been performed on the secondary fixation strips, tested in accordance with ISO 10993-5. The test article extract was diluted in supplemented EMEM 1X and placed onto triplicate confluent monolayers of L-929 mouse fibroblast cells at the 100%, 50%, 25% and 5% solutions (v/v). | N to 1:16, all non-cytotoxic (Grade 0) | | Sensitisation | PICO Dressing A Guinea Pig Maximisation Test was performed on the dressing in accordance with ISO 10993-10. | Non-sensitising | | | Secondary Fixation Strips A guinea pig maximisation test was performed on the secondary fixation strips in accordance with ISO 10993-10. | Non-sensitising | | Irritation | PICO Dressing The dressing was evaluated for irritation in accordance with ISO 10993-10. | PII SC = 0.0 PII SC = 0.1 Negligible irritant | | | Secondary Fixation Strips Irritation testing has been performed on the secondary fixation strips in accordance with ISO 10993-10. | 0.9% NaCl extract: Primary Irritation Index: 0.11 (Negligible) | {5}------------------------------------------------ Additionally, the effects of the dressing wound contact layer have been assessed during a wound healing study on ALLEVYN Gentle Border dressings, report reference which have the same wound contact layer as the dressing included in the PICO Single Use Negative Pressure Wound Therapy System. 604 6 ုးရှိ Testing has been completed in accordance with IEC / UL 60601-1; General Requirements for Safety of Electrical Medical Equipment and IEC 60601-1-2; Electromagnetic Safety Requirements For Electrical Medical Equipment. Software validation has been completed in accordance with IEC 62304 Software for Medical Devices. #### 9. Conclusions Drawn Based on results of testing performed the subject device is substantially equivalent to the predicate devices NPD 1000 Negative Pressure Wound Therapy System (K080275), Renasys Go (K083375) and Prevena Incision Management System (K100821). - PICO has similar design characteristics and provides similar functions to NPD 1000 Negative Pressure Wound Therapy System (K080275), Renasys Go (K083375) and Prevena Incision Management System (K100821). The intended use, indications and instructions for use for the subject and predicate devices are similar. PICO does not raise any new issues of safety and effectiveness. {6}------------------------------------------------ Image /page/6/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle with three stripes representing the three levels of government: federal, state, and local. The eagle is enclosed in a circle with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" around the perimeter. Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002 DEC 1 5 2011 Smith and Nephew, Inc. % Mr. Terry McMahon 970 Lake Carillon Drive, Suite 110 St. Petersburg, Florida 33716 Re: K111170 Trade/Device Name: PICO Single Use Negative Pressure Wound Therapy System Regulation Number: 21 CFR 878.4780 Regulation Name: Powered suction pump Regulatory Class: Class II Product Code: OMP Dated: December 12, 2011 Received: December 13, 2011 Dear Mr. McMahon: 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. Iisting 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 {7}------------------------------------------------ Page 2 - Mr. Terry McMahon 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 device-related 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. ff you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR 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 Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm. Sincerely yours. Sincerely yours, F-n Patinir C.C., A Mark N. Melkerson Director Division of Surgical, Orthopedic and Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health Enclosure {8}------------------------------------------------ ### INDICATIONS FOR USE STATEMENT 510(k) Number (if known): K111170 Device Name: PICO Single Use Negative Pressure Wound Therapy System Indications for Use: PICO is indicated for patients who would benefit from a suction device (negative pressure wound therapy) as it may promote wound healing via removal of low to moderate levels of exudate and infectious materials. Product Codes: 66800862, 66800863,66800865 and 66800866 are indicated for use on low and moderately exuding wounds. Examples of appropriate wound types include: - Chronic . - Acute . - Traumatic . - Subacute and dehisced wounds � - Partial-thickness burns . - Ulcers (such as diabetic or pressure) ● - Flaps and grafts . - Closed surqical incisions . PICO Single Use Negative Pressure Wound Therapy System is suitable for use in both a hospital and homecare setting. AND/OR Prescription Use X Over-The-Counter Use (Part 21 CFR 801 Subpart D) (21 CFR 801 Subpart C) (PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED) Concurrence of CDRH, Office of Device Evaluation (ODE) David Kane for MKM (Division Sign Off) Division of Surgical, Orthopedic, and Restorative Devices 510(k) Number K111170 {9}------------------------------------------------ # INDICATIONS FOR USE STATEMENT 510(k) Number (if known): K111170 Device Name: PICO Single Use Negative Pressure Wound Therapy System Indications for Use: PICO is indicated for patients who would benefit from a suction device (negative pressure wound therapy) as it may promote wound healing via removal of low levels of exudate and infectious materials. Product Codes: 66800864, 66800867,66800868 and 66800869 are indicated for use on low exuding wounds, Examples of appropriate wound types include: - Chronic . - Acute . - Traumatic . - Subacute and dehisced wounds . - Partial-thickness burns . - Ulcers (such as diabetic or pressure) . - Flaps and grafts . - Closed surgical incisions . PICO Single Use Negative Pressure Wound Therapy System is suitable for use in both a hospital and homecare setting. Prescription Use X AND/OR Over-The-Counter Use (21 CFR 801 Subpart C) (Part 21 CFR 801 Subpart D) (21 CFR 801 Subpart C) (PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED) Concurrence of CDRH, Office of Device Evaluation (ODE) Daniel Keane for MXM (Division Sign-On) Division of Surgical, Orthopedic, and Restorative Devices 510(k) Number K11170