Demand Nasal Oxygen Cannula, Modified Demand Nasal Oxygen Cannula

K151506 · Salter Labs · NFB · Mar 11, 2016 · Anesthesiology

Device Facts

• Record ID: K151506
• Device Name: Demand Nasal Oxygen Cannula, Modified Demand Nasal Oxygen Cannula
• Applicant: Salter Labs
• Product Code: NFB · Anesthesiology
• Decision Date: Mar 11, 2016
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 868.5905
• Device Class: Class 2
• Attributes: Therapeutic, Pediatric

Intended Use

The intended use is to deliver oxygen to the patient nasally, controlled by a demand system

Device Story

The NOP Demand and Modified Demand Nasal Oxygen Cannulas are dual-port devices designed for use with oxygen conservation delivery systems. One tube delivers oxygen to the patient, while the second tube senses inspiratory/expiratory effort. The device is intended for use by adult and pediatric patients. It functions as a passive interface between the patient and an external demand-based oxygen delivery system. Healthcare providers or patients use the cannula to facilitate oxygen therapy; the output is the delivery of oxygen triggered by the patient's respiratory effort, which can improve oxygen conservation and patient comfort. The device is constructed from PVC with DINCH or DOTP plasticizers.

Clinical Evidence

Bench testing only. Testing verified performance characteristics including back pressure (max < 2 psi), tubing bond strength (all samples > 2 lbs), and environmental storage/transport stability (-29°C to 50°C). Biocompatibility testing confirmed the materials passed irritation, sensitization, cytotoxicity, particulate, and volatile organic compound requirements. Sample size (n=29) supported a 95% confidence level at 91% reliability.

Technological Characteristics

Dual-port nasal cannula; materials: PVC with DINCH or DOTP plasticizers. Sensing/actuation: passive dual-lumen tubing for oxygen delivery and respiratory effort sensing. Dimensions/form factor: standard nasal cannula interface. Connectivity: none (passive). Sterilization: not specified. Software: none.

Indications for Use

Indicated for adult and pediatric patients requiring nasal oxygen delivery controlled by a demand system.

Regulatory Classification

Identification

A noncontinuous ventilator (intermittent positive pressure breathing-IPPB) is a device intended to deliver intermittently an aerosol to a patient's lungs or to assist a patient's breathing.

Predicate Devices

• Demand Nasal Oxygen Cannula (K890298)
• Modified Demand Nasal Oxygen Cannula (K892407)

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 11, 2016

Salter Labs Margaret Caler Regulatory Associate 2365 Camino Vida Robles Carlsbad, California 92011

Re: K151506

Trade/Device Name: NOP Demand Nasal Oxygen Cannula, Models 4804, 4805, 4807, 4824. & 4827 and NOP Modified Demand Nasal Oxygen Cannula, Models 4904, 4905, & 4907 Regulation Number: 21 CFR 868.5905 Regulation Name: Noncontinuous Ventilator (IPPB) Regulatory Class: Class II Product Code: NFB Dated: February 5, 2016 Received: February 11, 2016

Dear Ms. Caler:

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 device

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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 [phone] or [phone] 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 [phone] or [phone] 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

Erin I. Keith, M.S. 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) K151506

### Device Name

NOP Demand Nasal Oxygen Cannula, Models 4804, 4807, 4824, & 4827 and NOP Modified Demand Nasal Oxygen Cannula, Models 4904, 4905, & 4907.

Indications for Use (Describe)

The intended use is to deliver oxygen to the patient nasally, controlled by a demand system

| Type of Use (Select one or both, as applicable) | |
|-----------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------|
| <span> <span style="font-size: 16px;">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) </span> | <span> <span style="font-size: 16px;">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) </span> |

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## Section 9.0: 510 (k) Summary

In accordance with the Safe Medical Devices Act (SMDA) of 1990 and Title 21 of the Code of Federal Regulations Part 807 (21 CFR §807), a the following summary information is provided:

### 510 (k) Summary

#### A. Submitter:

Salter Labs 2365 Camino Vida Robles Carlsbad, CA 92011 Telephone: [phone] Fax: [phone]

Contact Person: Mara Caler Director, Regulatory Affairs

Date Prepared: 11 March 2016

#### B. Device Names:

| Trade Name | Common Name |
|----------------------------------------------------------------------------|------------------------------------------|
| NOP Demand Nasal Oxygen Cannula<br>models: 4804, 4805, 4807, 4824, & 4827. | NOP Demand Nasal Oxygen Cannula |
| NOP Modified Demand Nasal Oxygen<br>Cannula models: 4904, 4905, & 4907. | NOP Modified Demand Nasal Oxygen Cannula |

| Classification Name: | Conserver, Oxygen |
|-----------------------|-------------------|
| Product Code: | NFB |
| Regulation Number: | 868.5905 |
| Classification: | II |
| Classification Panel: | Anaesthesiology |

#### Predicate Devices: C.

This submission demonstrates substantial equivalence to the predicate devices:

K890298, Demand Nasal Oxygen Cannula

K892407, Modified Demand Nasal Oxygen Cannula

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#### D. Device Descriptions

The demand cannula is a special cannula designed to give adult and pediatric users of dual port oxygen conservation delivery system all the comfort and conveniences of a Salter-Style® cannula. Unique dual tubing delivers oxygen on demand through one tube while inspiratory / expiratory effort is also sensed through the other tube. Meets dual port device manufacturers' specifications.

#### Indications for Use E.

The intended use is to delivery oxygen to patient nasally, controlled by a demand system.

#### Comparison of Technological Characteristics with the Predicate Device F.

The proposed NOP Demand Nasal Oxygen Cannula and Modified NOP Demand Nasal Oxygen Cannula is substantially equivalent to the predicate device listed above in that the the indications for use, the intended use, and fundamental scientific technology remain unchanged.

The differences between the NOP Demand Nasal Oxygen Cannula and Modified NOP Demand Nasal Oxygen Cannula and the predicate device are:

| Features | Predicate Demand<br>Nasal Oxygen<br>Cannula | NOP Demand Oxygen<br>Cannula | Performance<br>Testing |
|-------------------------|---------------------------------------------|------------------------------|------------------------|
| Material<br>Formulation | PVC, DIDP | PVC, DINCH | Biocompatibility |
| | PVC, DEHP | PVC, DOTP | and Performance |

#### ﻦ Performance Data

The NOP Demand Nasal Oxygen Cannula and Modified NOP Demand Nasal Oxygen Cannula were tested to verify that the new material bond and performance characteristics of flow rate, back pressure, and tubing bond strength did not impact the strength or performa nce of the modified demand devices after the material change. Statistical methods were used to determine, the minimum required sample size was 29 to support a 95% confidence level at 91% reliability.

The test results demonstrate that the NOP Demand Nasal Oxygen Cannula and Modified NOP Demand Nasal Oxygen Cannula is substantially equivalent to the predicate devices.

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The tests performed are summarized below:

| Criteria | Results | Comments |
|-------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------|
| Shall not have a back<br>pressure that exceeds 3 psi at<br>a maximum flow rate in<br>ambient of 5°C, 20°C, and<br>40°C | The NOP Demand/Modified<br>Demand Nasal Oxygen<br>Cannula met the objective back<br>pressure requirements | Maximum back<br>pressure was<br>found to be less<br>than 2 psi. |
| The bonded components of<br>the set will have a bond<br>strength that is $≥$ 2 lbs. when<br>pulled at a rate of 5 inches<br>per minute. | The NOP Demand/Modified<br>Demand Nasal Oxygen<br>Cannula passed all bond strength<br>requirements. All test samples<br>measured above the bond interface<br>tensile load limit. | The worst case<br>cannula sample<br>was able<br>to achieve over<br>2 times the<br>minimum<br>allowable<br>value. |
| The cannula shall withstand<br>storage and transport<br>temperatures. A high<br>temperature limit of 50°C<br>and a low temperature limit<br>of -29°C. | The NOP Demand/Modified<br>Demand Nasal Oxygen<br>Cannula met the above<br>performance criteria after storage<br>and transport environmental<br>conditioning. | N/A |

The NOP Demand Nasal Oxygen Cannula and Modified NOP Demand Nasal Oxygen

Cannula meet established Salter Labs performance specifications.

#### Clinical / Non-Clinical H.

The following biocompatibility testing was performed. The materials passed all parameters:

- Irritation
- · Sensitization ·
- · Cytotoxicity
- Particulate
- Volatile organic compounds

#### I. Conclusions

The NOP Modified Demand and NOP Demand Nasal Oxygen Cannula data and test results demonstrate that the devices are substantially equivalent to the predicate devices