Citrasate Liquid Acid Concentrate, NaturaLyte Liquid Acid Concentrate

K192017 · Fresenius Medical Care Renal Therapies Group, LLC · KPO · Apr 24, 2020 · Gastroenterology, Urology

Device Facts

• Record ID: K192017
• Device Name: Citrasate Liquid Acid Concentrate, NaturaLyte Liquid Acid Concentrate
• Applicant: Fresenius Medical Care Renal Therapies Group, LLC
• Product Code: KPO · Gastroenterology, Urology
• Decision Date: Apr 24, 2020
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 876.5820
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

Citrasate® Liquid Acid Concentrate is indicated for use in patients undergoing extracorporeal bicarbonate hemodialysis for acute and chronic renal failure. Citrasate® Liquid Acid Concentrate is intended to be used as one component in the preparation of dialysate in a 3-stream proportioning hemodialysis machine to a physician's prescription. NaturaLyte® Liquid Acid Concentrate is indicated for use in patients undergoing extracorporeal bicarbonate hemodialysis for acute and chronic renal failure. NaturaLyte® Liquid Acid Concentrate to be used as one component in the preparation of dialysate in a 3-stream proportioning hemodialysis machine to a physician's prescription.

Device Story

Liquid acid concentrates (Citrasate and NaturaLyte) function as one of three components in 45X proportioning hemodialysis systems; mixed with bicarbonate and water to generate dialysate. Used in clinical settings for acute and chronic renal failure patients. Dialysate pumped through dialyzer; creates osmotic gradient across membrane to exchange solutes with blood. Healthcare providers prescribe specific formulations based on patient needs. Benefits include standardized electrolyte delivery for hemodialysis therapy.

Clinical Evidence

No clinical studies were performed. Evidence consists of bench testing, including stability evaluations, shipping verification per ASTM D4169-16, and biocompatibility testing (chemical characterization, cytotoxicity, sensitization, irritation, systemic toxicity, material-mediated pyrogenicity, and hemocompatibility).

Technological Characteristics

Single-use, non-sterile liquid concentrates containing electrolytes (chloride salts of Na, Mg, K), dextrose, and organic acid (citric or acetic). Citrasate includes sodium acetate. Packaged in high-density polyethylene (HDPE) bottles or drums. Formulated for 45X proportioning systems (1:1.72:42.28 ratio). Components are USP grade; water meets ISO 13959.

Indications for Use

Indicated for patients undergoing extracorporeal bicarbonate hemodialysis for acute and chronic renal failure.

Regulatory Classification

Identification

A hemodialysis system and accessories is a device that is used as an artificial kidney system for the treatment of patients with renal failure or toxemic conditions and that consists of an extracorporeal blood system, a conventional dialyzer, a dialysate delivery system, and accessories. Blood from a patient flows through the tubing of the extracorporeal blood system and accessories to the blood compartment of the dialyzer, then returns through further tubing of the extracorporeal blood system to the patient. The dialyzer has two compartments that are separated by a semipermeable membrane. While the blood is in the blood compartment, undesirable substances in the blood pass through the semipermeable membrane into the dialysate in the dialysate compartment. The dialysate delivery system controls and monitors the dialysate circulating through the dialysate compartment of the dialyzer.(1) The extracorporeal blood system and accessories consists of tubing, pumps, pressure monitors, air foam or bubble detectors, and alarms to keep blood moving safely from the blood access device and accessories for hemodialysis (§ 876.5540) to the blood compartment of the dialyzer and back to the patient. (2) The conventional dialyzer allows a transfer of water and solutes between the blood and the dialysate through the semipermeable membrane. The semipermeable membrane of the conventional dialyzer has a sufficiently low permeability to water that an ultrafiltration controller is not required to prevent excessive loss of water from the patient's blood. This conventional dialyzer does not include hemodialyzers with the disposable inserts (Kiil type) (§ 876.5830) or dialyzers of high permeability (§ 876.5860). (3) The dialysate delivery system consists of mechanisms that monitor and control the temperature, conductivity, flow rate, and pressure of the dialysate and circulates dialysate through the dialysate compartment of the dialyzer. The dialysate delivery system includes the dialysate concentrate for hemodialysis (liquid or powder) and alarms to indicate abnormal dialysate conditions. This dialysate delivery system does not include the sorbent regenerated dialysate delivery system for hemodialysis (§ 876.5600), the dialysate delivery system of the peritoneal dialysis system and accessories (§ 876.5630), or the controlled dialysate delivery system of the high permeability hemodialysis system § 876.5860). (4) Remote accessories to the hemodialysis system include the unpowered dialysis chair without a scale, the powered dialysis chair without a scale, the dialyzer holder set, dialysis tie gun and ties, and hemodialysis start/stop tray.

Predicate Devices

• Citrasate Dialysate Acid Concentrate Liquid (K000792)
• Dialysol Acid Concentrate Liquid (K981043)

Submission Summary (Full Text)

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April 24, 2020

Fresenius Medical Care Renal Therapies Group, LLC Denise Oppermann Senior Director, Regulatory Affairs 920 Winter Street Waltham, MA 02451

Re: K192017

Trade/Device Name: Citrasate Liquid Acid Concentrate NaturaLyte Liquid Acid Concentrate Regulation Number: 21 CFR 876.5820 Regulation Name: Hemodialysis System and Accessories Regulatory Class: II Product Code: KPO Dated: March 24, 2020 Received: March 25, 2020

Dear Denise Oppermann:

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 ([e-mail]) or phone [phone] or 301-796-7100).

Sincerely,

Carolyn Y. Neuland, Ph.D. Assistant Director DHT3A: Division of Renal, Gastrointestinal, Obesity and Transplant Devices OHT3: Office of GastroRenal, ObGyn, General Hospital and Urology 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) K192017

Device Name Citrasate® Liquid Acid Concentrate NaturaLyte® Liquid Acid Concentrate

# Indications for Use (Describe)

Citrasate® Liquid Acid Concentrate is indicated for use in patients undergoing extracorporeal bicarbonate hemodialysis for acute and chronic renal failure. Citrasate® Liquid Acid Concentrate is intended to be used as one component in the preparation of dialysate in a 3-stream proportioning hemodialysis machine to a physician's prescription.

NaturaLyte® Liquid Acid Concentrate is indicated for use in patients undergoing extracorporeal bicarbonate hemodialysis for acute and chronic renal failure. NaturaLyte® Liquid Acid Concentrate to be used as one component in the preparation of dialysate in a 3-stream proportioning hemodialysis machine to a physician's prescription.

X Prescription Use (Part 21 CFR 801 Subpart D)

Over-The-Counter Use (21 CFR 801 Subpart C)

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Image /page/3/Picture/0 description: The image shows the logo for Fresenius Medical Care. The logo consists of a blue symbol on the left and the text "FRESENIUS MEDICAL CARE" on the right. The symbol is made up of three downward-pointing chevrons stacked on top of each other. The text is in a bold, sans-serif font, with "FRESENIUS" on the top line and "MEDICAL CARE" on the bottom line.

# 5. 510(K) SUMMARY

This 510(k) Summary is in accordance with the requirements of the Safe Medical Device Act (SMDA) of 1990. The content of this 510(k) summary is provided in conformance with 21 CFR \$ 807.92.

# 5.1. Submitter's Information

| Name: | Fresenius Medical Care Renal Therapies Group, LLC |
|-------------------|-------------------------------------------------------------------|
| Address: | 920 Winter Street<br>Waltham, MA 02451-1457 |
| Phone: | [phone] |
| Fax: | [phone] |
| Contact Person: | Denise Oppermann, Senior Director<br>Regulatory Affairs – Devices |
| Preparation Date: | 26 July 2019 |

### 5.2. Device Name

| Trade Name: | Citrasate® Liquid Acid Concentrate<br>NaturaLyte® Liquid Acid Concentrate |
|-----------------------|---------------------------------------------------------------------------|
| Regulation Name: | Hemodialysis system and accessories |
| Regulatory Class: | Class II per 21 CFR § 876.5820 |
| Product Code: | KPO |
| Product Code Name: | Dialysate Concentrate for Hemodialysis (Liquid or Powder |
| Classification Panel: | Gastroenterology/Urology |

# 5.3. Legally Marketed Predicate Device

The legally marketed predicate device for the Citrasate Liquid Acid Concentrate is the Citrasate Dialysate Acid Concentrate Liquid cleared under K000792. The legally marketed predicate device for the NaturaLyte Liquid Acid Concentrate is the Dialysol Acid Concentrate Liquid cleared under K981043.

NaturaLyte Liquid Acid Concentrate is currently subject to an open recall (Z-2110-2018). Closure of this recall was requested to FDA on March 14, 2019.

In March 2012, a Class I recall was initiated for FMCRTG acid concentrate products regarding total buffer prescribing information. Concerns arose due to the contribution of acetate in acid concentrates in addition to the prescribed bicarbonate. This contribution was later determined to present a lower patient risk than initially understood. Through a series of Pre-Submission (Q131379) correspondence, FMCRTG and FDA came to an agreement on a final warning statement for acid concentrate labeling in June 2018.

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Image /page/4/Picture/0 description: The image shows the Fresenius Medical Care logo. The logo consists of a blue symbol on the left and the text "FRESENIUS MEDICAL CARE" on the right. The symbol is made up of three downward-pointing chevrons stacked on top of each other. The text is in a bold, sans-serif font, with "FRESENIUS" on the top line and "MEDICAL CARE" on the bottom line.

# 5.4. Device Description

#### 5.4.1. Device Identification- Citrasate

The Citrasate Liquid Acid Concentrate product line consists of three (3) formulations that differ in concentrations of potassium chloride. Each formulation is offered in two (2) presentations-a 1-gallon high density polyethylene bottle and a 55-gallon high density polyethylene drum-for a total of six (6) product codes. Descriptions of the available Citrasate Liquid Acid Concentrate products are provided in Table 1.

| Part Number | Part Number Description |
|-------------|--------------------------------------------------------------|
| 08-1251-CA | Citrasate Liquid Acid – 1.0 K, 2.5 Ca, 1.0 Mg – 1-gal bottle |
| 08-2251-CA | Citrasate Liquid Acid – 2.0 K, 2.5 Ca, 1.0 Mg – 1-gal bottle |
| 08-3251-CA | Citrasate Liquid Acid – 3.0 K, 2.5 Ca, 1.0 Mg – 1-gal bottle |
| 13-1251-CA | Citrasate Liquid Acid – 1.0 K, 2.5 Ca, 1.0 Mg – 55-gal drum |
| 13-2251-CA | Citrasate Liquid Acid – 2.0 K, 2.5 Ca, 1.0 Mg – 55-gal drum |
| 13-3251-CA | Citrasate Liquid Acid – 3.0 K, 2.5 Ca, 1.0 Mg – 55-gal drum |

Table 1: Citrasate Liquid Acid Concentrate Products

### Device Identification- NaturaLyte 5.4.2.

The NaturaLyte Liquid Acid Concentrate product line consists of 16 formulations that differ in concentrations of potassium chloride and calcium chloride. All formulations are offered in a onegallon high density polyethylene bottle and six (6) formulations are offered in a 55-gallon high density polyethylene drum, for a total of twenty-two (22) product codes. Descriptions of the available NaturaLyte Liquid Acid Concentrate products are provided in Table 2.

| Part Number | Part Number Description |
|-------------|----------------------------------------------------------------|
| 08-0231-4 | NaturaLyte Liquid Acid – 0.0 K, 2.25 Ca, 1.0 Mg – 1-gal bottle |
| 08-1001-0 | NaturaLyte Liquid Acid – 1.0 K, 0.0 Ca, 1.0 Mg – 1-gal bottle |
| 08-1201-8 | NaturaLyte Liquid Acid – 1.0 K, 2.0 Ca, 1.0 Mg – 1-gal bottle |
| 08-1231-3 | NaturaLyte Liquid Acid – 1.0 K, 2.25 Ca, 1.0 Mg – 1-gal bottle |
| 08-1251-1 | NaturaLyte Liquid Acid – 1.0 K, 2.5 Ca, 1.0 Mg – 1-gal bottle |
| 08-1301-4 | NaturaLyte Liquid Acid – 1.0 K, 3.0 Ca, 1.0 Mg – 1-gal bottle |
| 08-2201-5 | NaturaLyte Liquid Acid – 2.0 K, 2.0 Ca, 1.0 Mg – 1-gal bottle |
| 08-2231-2 | NaturaLyte Liquid Acid – 2.0 K, 2.25 Ca, 1.0 Mg – 1-gal bottle |

Table 2: NaturaLyte Liquid Acid Concentrate Products

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Image /page/5/Picture/0 description: The image contains the logo for Fresenius Medical Care. The logo consists of a blue symbol on the left and the text "FRESENIUS MEDICAL CARE" on the right. The symbol is made up of three downward-pointing chevrons stacked on top of each other. The text is in a bold, sans-serif font, with "FRESENIUS" on the top line and "MEDICAL CARE" on the bottom line.

| Part Number | Part Number Description |
|-------------|----------------------------------------------------------------|
| 08-2251-0 | NaturaLyte Liquid Acid – 2.0 K, 2.5 Ca, 1.0 Mg – 1-gal bottle |
| 08-2301-3 | NaturaLyte Liquid Acid – 2.0 K, 3.0 Ca, 1.0 Mg – 1-gal bottle |
| 08-2351-8 | NaturaLyte Liquid Acid – 2.0 K, 3.5 Ca, 1.0 Mg – 1-gal bottle |
| 08-3201-4 | NaturaLyte Liquid Acid – 3.0 K, 2.0 Ca, 1.0 Mg – 1-gal bottle |
| 08-3231-1 | NaturaLyte Liquid Acid – 3.0 K, 2.25 Ca, 1.0 Mg – 1-gal bottle |
| 08-3251-9 | NaturaLyte Liquid Acid – 3.0 K, 2.5 Ca, 1.0 Mg – 1-gal bottle |
| 08-3301-2 | NaturaLyte Liquid Acid – 3.0 K, 3.0 Ca, 1.0 Mg – 1-gal bottle |
| 08-4231-0 | NaturaLyte Liquid Acid – 4.0 K, 2.25 Ca, 1.0 Mg – 1-gal bottle |
| 13-1251-1 | NaturaLyte Liquid Acid – 1.0 K, 2.5 Ca, 1.0 Mg – 55-gal drum |
| 13-2201-5 | NaturaLyte Liquid Acid – 2.0 K, 2.0 Ca, 1.0 Mg – 55-gal drum |
| 13-2231-2 | NaturaLyte Liquid Acid – 2.0 K, 2.25 Ca, 1.0 Mg – 55-gal drum |
| 13-2251-0 | NaturaLyte Liquid Acid – 2.0 K, 2.5 Ca, 1.0 Mg – 55-gal drum |
| 13-3231-1 | NaturaLyte Liquid Acid – 3.0 K, 2.25 Ca, 1.0 Mg – 55-gal drum |
| 13-3251-9 | NaturaLyte Liquid Acid – 3.0 K, 2.5 Ca, 1.0 Mg – 55-gal drum |

#### Table 2: NaturaLyte Liquid Acid Concentrate Products (Continued)

#### 5.4.3. Device Characteristics

Citrasate Liquid Acid Concentrate and NaturaLyte Liquid Acid Concentrate products are singleuse, non-sterile devices intended for use in hemodialysis therapy for acute and chronic renal failure. Both products consist of electrolytes (chloride salts of sodium, magnesium, and potassium), dextrose, and an organic acid source (citric acid in Citrasate and acetic acid in NaturaLyte). Citrasate also contains sodium acetate as a secondary pH adjuster.

All formulation components are mixed in a single solution with dialysis quality water and provided to the customer ready for use.

#### 5.4.4. Environment of Use

Citrasate Liquid Acid Concentrate and NaturaLyte Liquid Acid Concentrate are used in environments where acute and chronic hemodialysis is performed.

#### 5.4.5. Brief Written Description of the Device

Citrasate Liquid Acid Concentrate and NaturaLyte Liquid Acid Concentrate are each intended to be used as one component in the preparation of dialysate in a 3-stream proportioning hemodialysis machine according to a physician's prescription. Both concentrates are formulated for use in 45X proportioning systems which proportion a nominal ratio of 1 : 1.72 : 42.28 (acid : bicarbonate : water) to generate dialysate. The dialysate is intended to be pumped through a

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Image /page/6/Picture/0 description: The image shows the Fresenius Medical Care logo. The logo consists of a blue symbol on the left and the text "FRESENIUS MEDICAL CARE" on the right. The symbol is made up of three downward-pointing chevrons stacked on top of each other. The text is in a bold, sans-serif font and is also blue.

dialyzer, creating an osmotic gradient across the dialyzer membrane to exchange solutes with blood during hemodialysis.

### 5.4.6. Materials of Use

Citrasate Liquid Acid Concentrate and NaturaLyte Liquid Acid Concentrate are classified as externally communicating, blood path indirect, prolonged contact (>24 hours to 30 days) duration. Class II (Category B) devices in accordance with FDA guidance document Use of International Standard ISO 10993-1, "Biological evaluation of medical devices-Part 1: Evaluation and testing within a risk management process" (16 June 2016). Packaging for the Citrasate Liquid Acid Concentrate and NaturaLyte Liquid Acid Concentrate consists of the following materials:

- 1-gallon bottle- high density polyethylene ●
- 55-gallon drum- high density polyethylene

Citrasate Liquid Acid Concentrate and NaturaLyte Liquid Acid Concentrate are composed of USP grade raw chemicals. Purified water meeting the requirements of ISO 13959 is used in the manufacture of Citrasate Liquid Acid Concentrate and NaturaLyte Liquid Acid Concentrate.

### 5.4.7. Key Performance Specifications/Characteristics

Citrasate Liquid Acid Concentrate and NaturaLyte Liquid Acid Concentrate are each used as a component of the dialysate for hemodialysis treatments. Both concentrates are intended to be used in 45X proportioning systems which proportion a nominal ratio of 1 : 1.72 : 42.28 (acid : bicarbonate : water) to generate dialysate. The water used for the final dialysate meets ISO 13959 or ANSI/AAMI RD62 requirements.

# Intended Use 5.5.

Citrasate Liquid Acid Concentrate and NaturaLyte Liquid Acid Concentrate are each intended for use in hemodialysis therapy for acute and chronic renal failure.

# 5.6. Indications for Use

Citrasate® Liquid Acid Concentrate is indicated for use in patients undergoing extracorporeal bicarbonate hemodialysis for acute and chronic renal failure. Citrasate® Liquid Acid Concentrate is intended to be used as one component in the preparation of dialysate in a 3-stream proportioning hemodialysis machine according to a physician's prescription.

NaturaLyte® Liquid Acid Concentrate is indicated for use in patients undergoing extracorporeal bicarbonate hemodialysis for acute and chronic renal failure. NaturaLyte® Liquid Acid Concentrate is intended to be used as one component in the preparation of dialysate in a 3-stream proportioning hemodialysis machine according to a physician's prescription.

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Image /page/7/Picture/0 description: The image shows the Fresenius Medical Care logo. The logo consists of a blue symbol on the left and the text "FRESENIUS MEDICAL CARE" on the right. The symbol is made up of three downward-pointing chevrons stacked on top of each other. The text is in a bold, sans-serif font, with "FRESENIUS" on the top line and "MEDICAL CARE" on the bottom line.

# Comparison of Technological Characteristics with the Predicate 5.7. Device

The Citrasate Liquid Acid Concentrate is substantially equivalent to the predicate Citrasate Dialysate Acid Concentrate Liquid (K000792), and the NaturaLyte Liquid Acid Concentrate is substantially equivalent to the predicate Dialysol Acid Concentrate Liquid (K981043) with regard to the following technological characteristics:

- Intended use
- Design
- Principle of operation ●
- Materials of construction
- Performance specifications ●

# 5.8. Performance Data

Performance testing was conducted for the Citrasate Liquid Acid Concentrate and NaturaLyte Liquid Acid Concentrate products. Results of performance testing support substantial equivalence, safety, and efficacy of the Citrasate Liquid Acid Concentrate and NaturaLyte Liquid Acid Concentrate.

### Stability Design Verification 5.8.1.

Stability evaluations were conducted for Citrasate Liquid Acid Concentrate and NaturaLyte Liquid Acid Concentrate to support the 24-month (2-year) shelf life. Stability is monitored as part of routine production testing. The 24-month shelf life is supported by real time stability evaluations.

### 5.8.2. Shipping Verification

Shipping and distribution verification testing was performed for the Citrasate Liquid Acid Concentrate and NaturaLyte Liquid Acid Concentrate products in accordance with ASTM D4169-16, Standard Practice for Performance Testing of Shipping Containers and Systems. Results support that the products' packaging is able to withstand the distribution environment.

### 5.8.3. Biocompatibility Testing

The following endpoints were assessed to support the biological safety of the Citrasate Liquid Acid Concentrate and NaturaLyte Liquid Acid Concentrate (bottles and drums):

- Chemical characterization
- Cytotoxicity
- Sensitization
- Irritation
- Systemic toxicity

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Image /page/8/Picture/0 description: The image contains the logo for Fresenius Medical Care. On the left side of the logo is a blue symbol that consists of three downward-pointing arrows stacked on top of each other. To the right of the symbol is the text "FRESENIUS MEDICAL CARE" in blue, with "FRESENIUS" on the top line and "MEDICAL CARE" on the bottom line.

- Material mediated pyrogenicity
- . Hemocompatibility

A toxicological risk assessment was also performed.

#### Human Factors Validation Testing 5.8.4.

The Citrasate Liquid Acid Concentrate and NaturaLyte Liquid Acid Concentrate were validated for their safe and effective use in accordance with FDA guidance document Applying Human Factors and Usability Engineering to Medical Devices (03 February 2016).

#### 5.8.5. Electrical Safety and Electromagnetic Compatibility

Not applicable. The Citrasate Liquid Acid Concentrate and NaturaLyte Liquid Acid Concentrate are not electrical mechanical devices.

#### Software Verification and Validation Testing 5.8.6.

Not applicable. The Citrasate Liquid Acid Concentrate and NaturaLyte Liquid Acid Concentrate do not contain software.

#### Animal Studies 5.8.7.

No animal studies were performed for Citrasate Liquid Acid Concentrate and NaturaLyte Liquid Acid Concentrate.

#### Clinical Studies 5.8.8.

No clinical studies were performed for Citrasate Liquid Acid Concentrate and NaturaLyte Liquid Acid Concentrate.

#### 5.9. Conclusions

The intended use, design, principle of operation, and materials of construction of the Citrasate Liquid Acid Concentrate and NaturaLyte Liquid Acid Concentrate are substantially equivalent to those of the predicate devices. Differences between the Citrasate Liquid Acid Concentrate and NaturaLyte Liquid Acid Concentrate and the predicates do not raise new concerns with regard to safety or efficacy. FMCRTG concludes that within the meaning of the Medical Device Amendments Act of 1976, Citrasate Liquid Acid Concentrate and NaturaLyte Liquid Acid Concentrate are safe and effective for their intended use.