Kangaroo Enteral Feeding Tube Extension Set with ENFit Small Bore Connectors
Applicant
Covidien
Product Code
PIF · Gastroenterology, Urology
Decision Date
Apr 2, 2015
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 876.5980
Device Class
Class 2
Attributes
Therapeutic, Pediatric
Indications for Use
The Kangaroo™ Feeding Tube Extension Sets with ENFit small bore connectors are intended for enteral feeding, on the order of a physician, to provide a means of delivering enteral nutrition or medication from an enteral feeding syringe through to any feeding tube which will accept a connector for enteral applications. The device is intended for neonates and infants who require enteral feeding.
Device Story
Sterile, disposable single-lumen microbore PVC extension tube; acts as conduit between enteral feeding syringe and patient feeding tube; provides additional length for feeding delivery. Used for neonates and infants unable to swallow or requiring nutritional supplementation. Operated by clinicians in clinical settings. Features ENFit small-bore connectors at both ends to prevent misconnections; compliant with ISO 80369-3. Includes options for medication port and slide clamps. Output is delivery of nutrition/medication to patient. Benefits include safe, standardized connection to enteral feeding systems and extended reach for feeding administration.
Clinical Evidence
No clinical data. Substantial equivalence determined via bench testing, including biocompatibility, stability, dimensional analysis, and mechanical performance testing per ISO 80369-3 and ISO 80369-20. Human factors validation and risk assessment for ENFit connectors provided in Master File 2258.
Technological Characteristics
Single-lumen microbore PVC tubing; ENFit small-bore connectors (ISO 80369-3 compliant); includes slide clamps and optional medication port. Sterile, disposable. Mechanical connection principle. No energy source or software.
Indications for Use
Indicated for neonates and infants requiring enteral feeding or medication delivery via enteral feeding syringe and feeding tube.
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.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
April 2, 2015
Covidien Wei Zhao, M.D. Senior Director, Regulatory Affairs 15 Hampshire Street Mansfeild, MA 02048
Re: K143018
> Trade/Device Name: Kangaroo™ Feeding Tube Extension Sets with ENFit Small Bore Connectors Regulation Number: 21 CFR§ 876.5980 Regulation Name: Gastrointestinal tube and accessories Regulatory Class: II Product Code: PIF Dated: March 3, 2015 Received: March 6, 2015
Dear Wei Zhao,
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.
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Page 2 - Wei Zhao, M.D.
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 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.
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 vours.
Herbert P. Lerner -S
for
Benjamin R. Fisher, Ph.D. Director Division of Reproductive, Gastro-Renal, and Urological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
#### 510(k) Number (if known) K143018
Device Name
Kangaroo™ Feeding Tube Extension Sets with ENFit Small Bore Connectors.
#### Indications for Use (Describe)
The Kangaroo™ Feeding Tube Extension Sets with ENFit small bore connectors are intended for enteral feeding, on the order of a physician, to provide a means of delivering enteral nutrition or medication from an enteral feeding syringe through to any feeding tube which will accept a connector for enteral applications.
The device is intended for neonates and infants who require enteral feeding.
Type of Use (Select one or both, as applicable)
| <span style="font-size: 12px;"> <svg height="15" width="15"> <path d="M2 2 L13 13 M2 13 L13 2" stroke="black" stroke-width="2"></path> </svg> Prescription Use (Part 21 CFR 801 Subpart D) </span> |
|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| <span style="font-size: 12px;"> <svg height="15" width="15"> <rect fill="white" height="15" stroke="black" stroke-width="1" width="15"></rect> </svg> Over-The-Counter Use (21 CFR 801 Subpart C) </span> |
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## 2.0 510(k) Summary
Kangaroo™ Feeding Tube Extension Sets with ENFit Small Bore Connectors
In accordance with section 513(i) of the SMDA and as defined in 21CFR Part 807.92 this summary is submitted by:
Covidien 15 Hampshire Street Mansfield, MA 02048 Date Prepared: October 17, 2014
## a. Contact Person
Wei Zhao, M.D. Senior Director, Regulatory Affairs Covidien Telephone: (508) 261-8404 Fax: (508) 261-8461
- b. Name of Medical Device
Common Name: tube, feeding
U.S. FDA Classification Product Code: PIF
- U.S. Regulation Description: Gastrointestinal tube and accessories, 21 CFR 876.5980
Proprietary / Trade Name: Kangaroo™ Feeding Tube Extension Sets with ENFit Small Bore Connectors
## c. Identification of Legally Marketed Device(s)
Covidien KangarooTM Enteral Feeding Extension Sets, K973409
## d. Device Brief Description
The Kangaroo™ Feeding Tube Extension Sets with ENFit small bore connectors are sterile, disposable medical devices designed to deliver nutrition to patients who cannot obtain nutrition or liquid by mouth, are unable to swallow safely, or need nutritional supplementation. The proposed set is intended as a conduit between the enteral feeding formula container (mostly enteral feeding syringe) and feeding tube. The device is designed with a single lumen microbore PVC tube with ENFit small bore connectors at both ends. During enteral feeding therapy, mainly for neonates and infants, there are situations when the feeding tube extension set is required to connect the syringe to patient feeding tube when the
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distance between the patient and the source of enteral feeding demands additional length of tube.
## Device Intended Use
The Kangaroo™ Feeding Tube Extension Sets with ENFit small bore connectors are intended for enteral feeding, on the order of a physician, to provide a means of delivering enteral nutrition or medication from an enteral feeding syringe through to any feeding tube which will accept an ENFit small bore connector for enteral applications.
The device is intended for neonates and infants who require enteral feeding.
#### Product Comparison Summary e.
The proposed and predicate enteral feeding devices are all intended for patients who cannot obtain nutrition by mouth, are unable to swallow safely, or need nutritional supplementation. These products have the same intended use, the same function, and the same general technological characteristics. Both the predicate and proposed products are designed with the single lumen microbore PVA tubing. They both are intended for connection with a syringe operated with syringe pump at proximal end and an enteral feeding tube at the distal end. The majority of the parts for both the proposed and predicate sets are made with the same material. The variation of the materials for certain components has been proven biocompatible and effective. The major technological enhancement is the incorporation of new ENFit connectors which are compliant to ISO 80369-3, into the proposed Kangaroo™ Feeding Tube Extension Sets. The ENFit connectors are part of an industry wide effort to address misconnections by adopting a uniform connector that has been engineered to meet the objective of ISO 80369-1, small-bore connectors for liquids and gases in healthcare applications - part 1: general requirements. At the proximal end of the device, a female syringe luer lock connector is designed for the predicate extension set. A male ENFit connector is offered for the proposed extension set. At the distal end of the product, the connection design for the predicate extension set is a non-IV compatible stepped connector. For the proposed extension design is a female ENFit connector. Other additions to the proposed products include two lengths, option of a medication port with male ENFit connector, and slide clamps to the tubing. These variations do not alter the intended use of the device, nor impact the safety and effectiveness of the product.
#### f. Nonclinical testing
- Biocompatibility testing has demonstrated the biological safety of parts of the ● proposed extension sets which may indirectly contact the patient.
- Stability testing evaluated the properties of the Kangaroo™ Feeding Tube Extension ● Sets after accelerated aging in support of the product expiration date.
- Dimensional analysis was conducted for critical dimensions of the KangarooTM ● Feeding Tube Extension Sets, in accordance with ISO 80369-3, Small-bore
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connectors for liquids and gases in healthcare applications – Part 3: Connectors for enteral applications. The testing demonstrates the proposed devices conform to the criteria in Table B.2 of ISO 80963-3.
- Study performed on the Kangaroo™ Feeding Tube Extension Sets with ENFit . Connectors included the tests listed below, in accordance with ISO 80369-3, Smallbore connectors for liguids and gases in healthcare applications - Part 3: Connectors for enteral applications, using the test methods provided in ISO 80369-20, Small-bore connectors for liquids and gases in healthcare applications - Part 20: Common test methods. The testing demonstrates the proposed devices conform to the requirements of ISO 80963-3.
| Individual Test Defined<br>in ISO 80369-3 | Requirement Defined<br>in ISO80369-3 | Test Method Defined<br>in ISO 80369-20 |
|---------------------------------------------|--------------------------------------|----------------------------------------|
| Fluid Leakage | Clause 6.2 | Annex C |
| Stress Cracking | Clause 6.3 | Annex E |
| Resistance to separation<br>from axial load | Clause 6.4 | Annex F |
| Resistance to separation<br>from unscrewing | Clause 6.5 | Annex G |
| Resistance to overriding | Clause 6.6 | Annex H |
| Disconnection by<br>unscrewing | Clause 6.7 | Annex I |
- Flow testing was conducted and has demonstrated that the proposed extension sets are substantially equivalent to the performance of the predicate device.
- The risk associated the misconnection of the ENFit connector has been assessed at length and captured in the following documents, which are located in Master File 2258.
- PG Lock Misconnection Data with Failure Modes and Effects Analysis o (FMEA) 2014-01-9
- 3595-0501-04 Enteral Connector Misconnection Assessment o
- o Enteral Connection Risk Management Report Rev 2.0
- o PG Lock Misconnection Risk Assessment Report 041513
- . Usability and human factors testing was conducted as part of the design of the ENFit connector, and is captured in the following document, which is located in the Master File 2258.
- o Human Factors Validation Study Enteral Connectors Final Report
- g. Clinical testing
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Clinical evaluations were not relied upon for the determination of substantial equivalence to the predicate device based on the device classification, sufficient safety and functional performance information provided in the submission.
### h. Conclusions
The information provided within this pre-market notification demonstrates that the Kangaroo™ Feeding Tube Extension Sets with ENFit Small Bore Connectors have no difference that would affect the safety or effectiveness of the devices as compared to the predicate devices and provides reasonable assurance of the safety and effectiveness of the device to demonstrate substantial equivalence.
End of Summary
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Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
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.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
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.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
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.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
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.