The US Food and Drug Administration (FDA) has issued an umbrella
emergency use authorization (EUA) that sanctions the use of certain surgical
masks in healthcare settings. The EUA was issued in response to concerns over
the lack of disposable single-use surgical masks for healthcare professionals
during the COVID-19 pandemic.
The EUA contains labeling and performance requirements to reduce the
risk of unauthorized surgical masks being used.
Key labelling requirements include:
- Description
of the product as a disposable, single-use surgical mask. The labeling
must include a list of the body contacting materials (which does not
include any drugs, biologics, nanoparticles, or antimicrobial/antiviral
agents) - State that
the product is not intended to replace the need for FDA-cleared surgical
masks or FDA-cleared or authorized respirators - State that
surgical masks are not intended to provide protection against pathogenic
biological airborne particulates and are not recommended for use in
aerosol generating procedures and any clinical conditions where there is
significant risk of infection through inhalation exposure - Not
include
statements that would misrepresent the product or create an undue risk considering
the public health emergency. For example, the labeling must not include
any express or implied claims for: (1) reuse, (2) antimicrobial or
antiviral protection or related uses, (3) infection prevention, infection
reduction, or related uses, or (4) viral filtration efficiency
These products must also be accompanied by a fact sheet when being used
by a healthcare professional.
Specific performance requirements include:
- Fluid resistance
requirements (liquid barrier performance) consistent with ASTM F1862: Standard
Test Method for Resistance of Medical Face Masks to Penetration by
Synthetic Blood (Horizontal Projection of Fixed Volume at a Known
Velocity) - Flammability
performance consistent with the definition of either a Class 1 or Class 2
textile in 16 CFR Part 1610 - Particulate filtration
efficiency requirements consistent with ASTM F2100: Standard
Specification for Performance of Materials Used in Medical Face Masks - Air flow resistance
(i.e. breathability) requirements with an acceptance criterion of <6 mm
H2O/cm2 for differential pressure (delta P) testing consistent with ASTM
F2100: Standard Specification for Performance of Materials Used in
Medical Face Masks for those masks composed of 4 or more layers - Materials of
manufacture must conform to either of these requirements:- Non-cytotoxic,
non-irritating and non-sensitizing consistent with the recommendations in
the 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’” - Following
biocompatibility standards:- ISO 10993-1: Biological
evaluation of medical devices – Part 1: Evaluation and testing within a
risk management process - ISO 10993-5: Biological
evaluation of medical devices – Part 5: Tests for in vitro cytotoxicity - ISO 10993-10: Biological
evaluation of medical devices – Part 10: Tests for irritation and skin
sensitization
- ISO 10993-1: Biological
- Non-cytotoxic,
Not included under the scope of the EUA are surgical masks that are:
- FDA-cleared
- Manufactured
in China - Include
drugs, biologics, nanoparticles, or antimicrobial/antiviral agents
EUA can be issued by the FDA during a public health emergency. This EUA
was issued on August 5, 2020. To learn more about it, read the original SafeGuard 123/20.
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