SonoMSK

K243690 · PAJUNK GmbH Medizintechnologie · BSP · Jul 1, 2025 · Anesthesiology

Device Facts

Record IDK243690
Device NameSonoMSK
ApplicantPAJUNK GmbH Medizintechnologie
Product CodeBSP · Anesthesiology
Decision DateJul 1, 2025
DecisionSESE
Submission TypeTraditional
Regulation21 CFR 868.5150
Device ClassClass 2
AttributesTherapeutic

Intended Use

SonoMSK anesthesia conduction needles enhanced for ultrasound visibility are intended for the transient delivery of anesthetics to provide regional anesthesia and analgesia.

Device Story

Single-use anesthesia conduction needle; used for transient delivery of anesthetics to provide regional anesthesia and analgesia. Device features ultrasound-enhanced visibility via 'CornerStone' reflectors; includes injection tube with ISO 80369-7 compliant Luer connector. Operated by clinicians in clinical settings under ultrasound guidance. Needle facilitates precise positioning for nerve blocks; visibility enhancement aids clinician in real-time needle tracking. Benefits include improved accuracy in anesthetic delivery and reduced risk of tissue trauma. Device is supplied sterile (EtO) with 5-year shelf life.

Clinical Evidence

Bench testing only. Performance verified against ISO 7864 (hypodermic needles), ISO 9626 (tubing), and ISO 80369-7 (Luer connectors). Sterilization validated to SAL 10^-6 per ISO 11135. Biocompatibility confirmed per ISO 10993-1. No clinical data presented.

Technological Characteristics

Stainless steel 1.4301 needle tubing; Copolyester (Tritan MX731) hub; silicone coating. Ultrasound enhancement via CornerStone reflectors. Connectivity: ISO 80369-7 Luer. Sterilization: Ethylene Oxide (SAL 10^-6). Packaging: Tyvek/foil or medical paper/foil. Dimensions: 22G-27G, 25mm-150mm length.

Indications for Use

Indicated for patients requiring regional anesthesia and analgesia via transient delivery of anesthetics under ultrasound guidance. Not for intrathecal use.

Regulatory Classification

Identification

An anesthesia conduction needle is a device used to inject local anesthetics into a patient to provide regional anesthesia.

Predicate Devices

Reference Devices

Related Devices

Submission Summary (Full Text)

{0} FDA U.S. FOOD & DRUG ADMINISTRATION July 1, 2025 PAJUNK GmbH Medizintechnologie Christian Quaß Director Regulatory Affairs Karl-Hall-Str. 1 Pajunkstr. 1 Geisingen, BW 78187 Germany Re: K243690 Trade/Device Name: SonoMSK Regulation Number: 21 CFR 868.5150 Regulation Name: Anesthesia Conduction Needle Regulatory Class: Class II Product Code: BSP Dated: May 28, 2025 Received: May 28, 2025 Dear Christian Quaß: 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 (the 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 available 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. U.S. Food & Drug Administration 10903 New Hampshire Avenue Silver Spring, MD 20993 www.fda.gov {1} K243690 - Christian Quaß Page 2 Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download). Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30, Design controls; 21 CFR 820.90, Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181). 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-related adverse events) (21 CFR Part 803) for devices or postmarketing safety reporting (21 CFR Part 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reporting-combination-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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050. All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rule"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-devices/device-advice-comprehensive-regulatory-assistance/unique-device-identification-system-udi-system. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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-devices/medical-device-safety/medical-device-reporting-mdr-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/medical-devices/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-devices/device-advice-comprehensive-regulatory- {2} K243690 - Christian Quaß Page 3 assistance/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, TING SONG -S for Bradley Quinn Assistant Director DHT1C: Division of Anesthesia, Respiratory, and Sleep Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT, and Dental Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health Enclosure {3} DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration Indications for Use Form Approved: OMB No. 0910-0120 Expiration Date: 07/31/2026 See PRA Statement below. Submission Number (if known) K243690 Device Name SonoMSK Indications for Use (Describe) SonoMSK anaesthesia conduction needles enhanced for ultrasound visibility are intended for the transient delivery of anesthetics to provide regional anesthesia and analgesia. Type of Use (Select one or both, as applicable) ☑ Prescription Use (Part 21 CFR 801 Subpart D) ☐ Over-The-Counter Use (21 CFR 801 Subpart C) ## CONTINUE ON A SEPARATE PAGE IF NEEDED. This section applies only to requirements of the Paperwork Reduction Act of 1995. *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.* The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to: Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov “An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number.” {4} 510(k) Premarket Notification Submission PAJUNK® # USA # 08 510(k) Summary # Registrations USA 510(k) Summary as required by 21 CFR 807.92(c). Date of Preparation: 2025-05-22 Document Control Number: K243690 510(k) owner: PAJUNK® GmbH Medizintechnologie Karl-Hall-Str. 1/ Pajunkstr. 1 78187 Geisingen Baden-Wuerttemberg, Germany Fon: +49(0)7704-9291-586 Fax: +49(0)7704-9291-605 Establishment Registration Number: 9611612 Submitter Information/ production site: PAJUNK® GmbH Medizintechnologie Karl-Hall-Str. 1/ Pajunkstr. 1 78187 Geisingen Baden-Wuerttemberg, Germany Fon: +49(0)7704-9291-586 Fax: +49(0)7704-9291-605 Establishment Registration Number: 9611612 Manufacturer/ Submitter Contact: Christian G. H. Quass Director Regulatory Affairs, Safety Officer Fon: +49(0)7704-9291-586 Fax: +49(0)7704-9291-602 E-Mail: christian.quass@pajunk.com Alternative Manufacturer/ Submitter Contact: Chiara Meyer Regulatory Affairs Specialist Fon: +49(0)7704-9291-627 Fax: +49(0)7704-9291-602 E-Mail: chiara.meyer@pajunk.com 510(k) SonoMSK R&D Resp. ELC Regulatory Resp. CQ/ MCH {5} 510(k) PAJUNK® # Premarket Notification Submission USA Contact: PAJUNK MEDICAL SYSTEMS 4575 Marconi Dr. Alpharetta, GA 30005 Registration Number: 3004076349 FEI Number*: 3004076349 US-Official Correspondent Marco Wohnig President PAJUNK Medical Systems 4575 Marconi Dr. Alpharetta, GA 30005 Phone: 001-770-4936832 E-Mail: Marco.Wohnig@pajunk-usa.com Contract Sterilizer: Sterigenics Germany GmbH Kastelerstraße 45 65203 Wiesbaden Germany, Hessen Establishment Registration Number: 3002807090 2nd Contract Sterilizer: HA2 MEDIZINTECHNIK GMBH Am Bahndamm 11 Halberstadt Saxony-Anhalt, DE 38820 Registration Number: 3009039068 FEI Number*: 3009039068 # Device Name and Classification | Device Name: | SonoMSK | | --- | --- | | Premarket Notification Number: | K243690 | | Classification Name: | Anesthesia Conduction Needle | | Classification Reference: | 21 CFR § 868.5150 | | Product Code: | BSP | | Establishment Registration Number: | 9611612 | | Regulatory Class: | II | | Panel: | Anesthesiology | 510(k) SonoMSK R&D Resp. ELC Regulatory Resp. CQ/ MCH {6} 510(k) PAJUNK® # Premarket Notification Submission | Sterilization Method: | Ethylene Oxide disposable device, supplied sterile to the end user and non-sterile intended to be sterilized prior to use to re-packagers/ medical device manufacturers | | --- | --- | | Contract Sterilizer: | Sterigenics Germany GmbH Kasteler straße 45 65203 Wiesbaden Germany, Hessen Establishment Registration Number: 3002807090 | | Additional Contract Sterilizer: | HA2 MEDIZINTECHNIK GMBH Am Bahndamm 11 Halberstadt Saxony-Anhalt, DE 38820 Registration Number: 3009039068 FEI Number*: 3009039068 | # Changes to Device: Predicate Device | Device Name: | SonoTAP, Tuohy SONO | | --- | --- | | Premarket Notification Number: | K113207 | | Classification Name: | Anesthesia Conduction Needle | | Classification Reference: | 21 CFR § 868.5150 | | Product Code: | BSP | | Establishment Registration Number: | 9611612 | | Regulatory Class: | II | | Panel: | Anesthesiology | | Sterilization Method: | Ethylene Oxide disposable device, supplied sterile to the end user and non-sterile intended to be sterilized prior to use to re-packagers/ medical device manufacturers | 510(k) SonoMSK R&D Resp. ELC Regulatory Resp. CQ/ MCH {7} 510(k) PRAJUNK® # Premarket Notification Submission | Contract Sterilizer: | Sterigenics Germany GmbH Kastelerstraße 45 65203 Wiesbaden Germany, Hessen Establishment Registration Number: 3002807090 | | --- | --- | # Changes to Device: Reference Device | Device Name: | SonoBlock, SonoBlock II | | --- | --- | | Premarket Notification Number: | K241954 | | Classification Name: | Anesthesia Conduction Needle | | Classification Reference: | 21 CFR § 868.5150 | | Product Code: | BSP | | Establishment Registration Number: | 9611612 | | Regulatory Class: | II | | Panel: | Anesthesiology | | Sterilization Method: | Ethylene Oxide disposable device, supplied sterile to the end user and non-sterile intended to be sterilized prior to use to re-packagers/ medical device manufacturers | | Contract Sterilizer: | Sterigenics Germany GmbH Kastelerstraße 45 65203 Wiesbaden Germany, Hessen Establishment Registration Number: 3002807090 | | Additional Contract Sterilizer: | HA2 MEDIZINTECHNIK GMBH Am Bahndamm 11 Halberstadt Saxony-Anhalt, DE 38820 Registration Number: 3009039068 FEI Number*: 3009039068 | 510(k) SonoMSK R&D Resp. ELC Regulatory Resp. CQ/ MCH {8} 510(k) Premarket Notification Submission PAJUNK® # 1 Narrative Device Description The subject device, the SonoMSK needle is a single-use anesthesia conducting needle intended for the transient delivery of anesthetics to provide regional anesthesia and analgesia. The SonoMSK needle is intended for use under ultrasound guidance. Visibility under ultrasound is enhanced by CornerStone reflectors as cleared by FDA in several Premarket Notification Submissions. The SonoMSK needle is equipped with an injection tube. The distal connection of the tube is equipped with a LUER Connector according to ISO 80369-7. ![img-0.jpeg](img-0.jpeg) The device in focus is a single use device and has an intended time of use up to 24 hours acc. EO-residuals acc. DIN EN ISO 10993-7. The standard time of use is less than 60 minutes. The SonoMSK cannulas are not for intrathecal use. The SonoMSK cannulas are produced at PAJUNK® GmbH Medizintechnologie in Geisingen, Germany. # 2 Determination of Substantial Equivalence ## Intended Use Predicate Device (510(K) Predicate) The cannulas/ needles for anesthesia and analgesia enhanced for ultrasound visibility – Tuohy Sono, Sono TAP, Quincke Sono, Chiba Sono, SPROTTE® Sono and Crawford Sono – are intended for the transient delivery of anesthetics to provide regional anesthesia and analgesia or to facilitate placement of a catheter. ## Intended Use Subject Device SonoMSK anesthesia conduction needles enhanced for ultrasound visibility are intended for the transient delivery of anesthetics to provide regional anesthesia and analgesia. ## Discussion The Intended Use of the Predicate device and of the subject device is substantially equivalent. The Subject device and the predicate device both offer localization via ultrasound as it is state of the art and well established. 510(k) SonoMSK R&D Resp. ELC Regulatory Resp. CQ/ MCH {9} 510(k) Premarket Notification Submission PAJUNK® Conclusion: substantially equivalent # 3 Technical Description Substantial Equivalence: Tabulatory Outline | Characteristics | Subject Device SonoMSK Manufacturer: PAJUNK® GmbH Medizintechnologie, Geisingen | Predicate Device K113207 SonoTAP Manufacturer: PAJUNK® GmbH Medizintechnologie, Geisingen | | --- | --- | --- | | Picture | | | | Needle Tubing | Stainless Steel 1.4301 | Stainless Steel 1.4301 | | Tip | bevelled tip, bevelled tip with relief grind | Tuohy, Facet | | Hub | Copolyester (Tritan MX731) (Indirect Patient Contact) | Copolyester (Tritan MX731) (Indirect Patient Contact) | | Coating | Silicone (Dow Corning 360 Medical Fluid 12500 cSt), Silicone thinner (Dow Corning Q7-9180 Silicone Fluid 1.0 cSt) | Silicone (Dow Corning 360 Medical Fluid 12500 cSt), Silicone thinner (Dow Corning Q7-9180 Silicone Fluid 1.0 cSt) | | US-enhancement | Cornerstones | Cornerstone | | Graduation | Tampapur TPU | Tampapur TPU | | Bonding Technology Needle-to-Hub | glued | glued | | Glue | (Epoxy adhesive - Araldite 2011), alternatively: UV adhesive (Loctite AA 3921) | (Epoxy adhesive - Araldite 2011), alternatively: UV adhesive (Loctite AA 3921) | | Injection tube | PVC (MED7536), PC (HP4), MABS (Terlux 2802) | PVC (MED7536), PC (HP4), MABS (Terlux 2802) | | Diameter | 22G-27G | 18G - 24G | 510(k) SonoMSK R&D Resp. ELC Regulatory Resp. CQ/ MCH {10} 510(k) PAJUNK® Premarket Notification Submission | Characteristics | Subject Device SonoMSK Manufacturer: PAJUNK® GmbH Medizintechnologie, Geisingen | Predicate Device K113207 SonoTAP Manufacturer: PAJUNK® GmbH Medizintechnologie, Geisingen | | --- | --- | --- | | Length | 25mm-150mm | 40mm - 150 mm | | Connectivity | ISO 80369-7 (LUER) | ISO 80369-7 (LUER) | | Packaging | Tyvek, Foil, chromo-duplex board Alternatively: Paper, Foil | Tyvek, Foil, chromo-duplex board | | Biocompatibility | Complies with ISO10993-series as required by « Use of International Standard ISO 10993-1, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process" », Docket Number : FDA-2013-D-0350 | | | Sterilization Method | Ethyleneoxide | Ethyleneoxide | | Sterility Assurance Level | SAL=10^{-6} | SAL=10^{-6} | | Sterilization Service Provider | Sterigenics, Wiesbaden HA2 Medizintechnik, Halberstadt | Sterigenics, Wiesbaden | | Shelf Life | 60 month from sterilization | 60 month from sterilization | # 4 Substantial Equivalence Discussion The predicate device and the subject device have some characteristical differences: a) tip -> The modified tip of the SonoMSK is designed to enhance visibility under ultrasound and facilitate precise positioning without increasing tissue trauma. Bench testing (needle insertion force and tissue resistance) demonstrated equivalent or reduced insertion forces compared to the predicate. Moreover, the tip design remains within standard clinical geometries used in peripheral nerve block procedures and does not introduce any novel risks. Therefore, the modified tip does not adversely affect patient safety and maintains effectiveness in achieving targeted nerve access. b) diameter -> All offered diameters are within commonly used clinical ranges and comply with ISO 9626 510(k) SonoMSK R&D Resp. ELC Regulatory Resp. CQ/ MCH {11} 510(k) PAJUNK® # Premarket Notification Submission standards for stainless steel needles. The variation in diameter allows customization for specific anatomical approaches (e.g., superficial vs. deep nerves) but does not introduce new risks. c) length -> The availability of multiple needle lengths allows the clinician to select the appropriate configuration based on patient size, depth of target, and anatomical location. All lengths are within clinically accepted ranges for peripheral and musculoskeletal nerve access and follow design precedents established in similar legally marketed needles. The predicate devices, the SonoTAP needles, are packed with Tyvek and foil and sterilized with Ethyleneoxide at Sterigenics, Germany. The subject devices, the SonoMSK needles, are packed with Tyvek and foil as well as optionally with Medical Paper and foil. Furthermore, the subject devices are sterilized at Sterigenics in Wiesbaden as well as optionally at HA2 Medizintechnik in Halberstadt. The main differences which are subject to this premarket submission are a) the addition of a sterilization facility and b) the addition of an alternative packaging material. In order to verify substantial equivalence of the sterilization process a sterilization validation according ISO 11135 has been performed and successfully accomplished. The sterility assurance level of $10^{-6}$ has been successfully validated at both facilities: Sterigenics and HA2. In order to verify substantial equivalence of the packaging exhaustive packaging and shelf life tests have been performed. Both, medical paper and Tyvek have been validated and verified to allow sterilization using EtO and to maintain sterility after a shelf life of 60 month after sterilization. 510(k) SonoMSK R&D Resp. ELC Regulatory Resp. CQ/ MCH {12} 510(k) Premarket Notification Submission PAJUNK® # 5 Performance Testing The needles subject to this premarket submission are subject to performance testing prior to release as well as after shelf life scenario of 5 years. There is no impact of the change subject to this submission (additional optional sterilization provider, additional optional packaging) on the performance of the needle as defined in the user requirements specification. Especially the hub to needle bonding requirements remain unaffected. The processes are still valid and reliable. The test listed below are standard tests performed on a regular basis as well as type tests performed after design transfer. Tests are performed to comply with the international standards listed below in the respectively most current version: ISO 9626 Stainless steel needle tubing for manufacture of medical devices ISO 7864 Sterile hypodermic needles for single use - Requirements and test methods ISO 80369-7 Small-bore connectors for liquids and gases in healthcare applications - Part 7: Connectors for intravascular or hypodermic applications ISO 80369-20 Small-bore connectors for liquids and gases in healthcare applications - Part 20: Common test methods # 5.1 ISO 7864 The following sections have been tested: 510(k) SonoMSK R&D Resp. ELC Regulatory Resp. CQ/ MCH {13} 510(k) PFAJUNK® Premarket Notification Submission | section | Pass / Fail | | --- | --- | | 4.3 Cleanliness | Passed | | 4.4 Limits for acidity or alkalinity | Passed | | 4.5 Limits for extractable metals | Passed | | 4.10 Needle Tube | Passed | | 4.11 Needle point | Passed | | 4.12 Bond between hub and needle tube | Passed | | 4.13 Patency of lumen | Passed | ## 5.2 ISO 9626 The following sections have been tested: | section | Pass / Fail | | --- | --- | | 5.2 Surface finish and visual appearance | Passed | | 5.3 Cleanliness | Passed | | 5.4 Limits for acidity and alkalinity | Passed | | 5.5 Size designation | Passed | | 5.6 Dimensions | Passed | | 5.7 Sample size | Passed | | 5.8 Stiffness | Passed | | 5.9 Resistance to breakage | Passed | | 5.10 Resistance to corrosion | Passed | 510(k) SonoMSK R&D Resp. ELC Regulatory Resp. CQ/ MCH {14} 510(k) Premarket Notification Submission PAJUNK® # 5.3 ISO 80369 The following sections of the 80369-7 have been tested: | section | Pass / Fail | | --- | --- | | 7.1 Fluid Leakage | Passed | | 7.2 Air Leakage | Passed | | 7.3 Stress Cracking | Passed | | 7.4 Separation Axial Load | Passed | | 7.5 Unscrewing | Passed | | 7.6 Overriding | Passed | # 6 Sterilization The contract sterilizer and the sterilizing process are identical to the process and sterilizer used for all PAJUNK® - manufactured devices which are already cleared for market or exempt. Sterilization parameters are: | SAL | 10^{-6} | | --- | --- | | Type of gas | Ethylene Oxide 99,99% | Sterilization has been validated according to ISO 11135-1 Overkill Approach (1 sublethal cycle, 2 half cycle, 1 full cycle) Residuals of EO and ECH are in compliance with ISO 10993-7. Cleaning and Sterilization method, which ensures an SAL of $10^{-6}$ as well as compliance with limits for chemical burden, bioburden, pyroburden (i.e. LAL) and EtO-residuals as well as shelf life have been validated and are safe and effective. The limits listed below are met by each device: Limits for Residuals: 25ppm = 25μg/(g/device) of Ethyleneoxide (EO); 25ppm = 25μg/(g/device) Ethylene chlorhydrine 510(k) SonoMSK R&D Resp. ELC Regulatory Resp. CQ/ MCH {15} 510(k) Premarket Notification Submission PAJUNK® # 7 Shelf Life Efficacy of sterile product’s lifecycle has been validated using process most challenging worst case devices. Sterility tests have been performed using process most challenging worst case devices with similar characteristics made from the same material after 5 years. The devices were found to be sterile after 5 years, the sterile barrier system is efficient. Performance of the device (LUER connection, stability of bonding connections, needle’s bending rigidity) has been tested. There is no decrease in performance after 5 years. Shelf-life is set to 5 years. # 8 Biocompatibility All products comply with ISO 10993-1 and with FDA’s guidance Use of International Standard ISO 10993-1, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process". Therefore, based on sterilization validation and residuals validation the kits also are considered to be biocompatible. # 9 Technology Characteristics Both, the subject device and the predicate device, consist of identical components. # 10 Conclusion The comparison between the predicate device and the subject device of this submission focussed on the validated sterilization process and the shelf life testing demonstrates that the subject device can be optionally in addition packed using medical paper and can be optionally sterilized at the alternative sterilization service provider at an SAL of 10⁻⁶. The results demonstrate that the subject device is substantially equivalent and as safe, as effective, and performs as well as the predicate device. 510(k) SonoMSK R&D Resp. ELC Regulatory Resp. CQ/ MCH
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