Contains Nonbinding Recommendations

Enforcement Policy for Sterilizers,

Disinfectant Devices, and Air Purifiers
During the Coronavirus Disease 2019
(COVID-19) Public Health Emergency
Guidance for Industry and
Food and Drug Administration Staff
March 2020

U.S. Department of Health and Human Services

Food and Drug Administration
Center for Devices and Radiological Health
 Contains Nonbinding Recommendations

Preface
Public Comment
This guidance is being issued to address the Coronavirus Disease 2019 (COVID-19) public
health emergency. This guidance is being implemented without prior public comment because
the Food and Drug Administration (FDA or Agency) has determined that prior public
participation for this guidance is not feasible or appropriate (see section 701(h)(1)(C)(i) of the
Federal Food, Drug, and Cosmetic Act (FD&C Act) and 21 C.F.R. 10.115(g)(2)). This guidance
document is being implemented immediately, but it remains subject to comment in accordance
with the Agency’s good guidance practices.

Comments may be submitted at any time for Agency consideration. Submit written comments to
the Dockets Management Staff (HFA-305), Food and Drug Administration, 5630 Fishers Lane,
Rm. 1061, Rockville, MD 20852. Submit electronic comments to https://www.regulations.gov.
All comments should be identified with the docket number FDA-2020-D-1138 and complete
title of the guidance in the request.

Additional Copies
Additional copies are available from the FDA webpage titled “Coronavirus Disease 2019
(COVID-19),” available at COVID-19-Related Guidance Documents for Industry, FDA Staff,
and Other Stakeholders (https://www.fda.gov/emergency-preparedness-and-response/mcm-
issues/covid-19-related-guidance-documents-industry-fda-staff-and-other-stakeholders ) and the
FDA webpage titled “Search for FDA Guidance Documents” available at
https://www.fda.gov/regulatory-information/search-fda-guidance-documents. You may also send
an e-mail request to [email protected] to receive a copy of the guidance. Please
include the document number 20019 and complete title of the guidance in the request.

Questions
For questions about this document, contact 1-888-INFO-FDA or CDRH-COVID19-
[email protected].
 Contains Nonbinding Recommendations

Table of Contents

I. Introduction ................................................................................................................................. 4
II. Background ................................................................................................................................. 5
III. Scope ........................................................................................................................................... 5
A. Sterilizers.............................................................................................................................. 5
B. Disinfectant Devices ............................................................................................................ 6
(1) Chemical/Physical Disinfectant Devices .......................................................................... 6
(2) Ultraviolet (UV) Disinfecting Devices ............................................................................. 7
C. Air Purifiers .......................................................................................................................... 7
IV. Policy .......................................................................................................................................... 7
A. Performance ......................................................................................................................... 9
(1) Sterilizers ........................................................................................................................ 10
(2) Disinfectant devices........................................................................................................ 11
(3) Air Purifiers .................................................................................................................... 12
B. Labeling.............................................................................................................................. 13
C. Additional Helpful Resources ............................................................................................ 13
 Contains Nonbinding Recommendations

Enforcement Policy for Sterilizers,

Disinfectant Devices, and Air Purifiers
During the Coronavirus Disease 2019
(COVID-19) Public Health Emergency
Guidance for Industry and
Food and Drug Administration Staff
This guidance represents the current thinking of the Food and Drug Administration (FDA or Agency)
on this topic. It does not establish any rights for any person and is not binding on FDA or the public.
You can use an alternative approach if it satisfies the requirements of the applicable statutes and
regulations. To discuss an alternative approach, contact the FDA staff or Office responsible for this
guidance as listed on the title page.

I. Introduction
The Food and Drug Administration (FDA or Agency) plays a critical role in protecting the United
States from threats including emerging infectious diseases, including the Coronavirus Disease 2019
(COVID-19) pandemic. FDA is committed to providing timely guidance to support response efforts
to this pandemic.

FDA is issuing this guidance to provide a policy to help expand the availability and capability of
sterilizers, disinfectant devices, and air purifiers during this public health emergency.

This policy is intended to remain in effect only for the duration of the public health emergency
related to COVID-19 declared by the Department of Health and Human Services (HHS), including
any renewals made by the HHS Secretary in accordance with section 319(a)(2) of the Public Health
Service Act (PHS Act).

Given this public health emergency, and as discussed in the Notice in the Federal Register of March
25, 2020, titled “Process for Making Available Guidance Documents Related to Coronavirus Disease
2019,” available at https://www.govinfo.gov/content/pkg/FR-2020-03-25/pdf/2020-06222.pdf, this
guidance is being implemented without prior public comment because the FDA has determined that
prior public participation for this guidance is not feasible or appropriate (see section 701(h)(1)(C)(i)
of the Federal Food, Drug, and Cosmetic Act (FD&C Act) and 21 CFR 10.115(g)(2)). This guidance
document is being implemented immediately, but it remains subject to comment in accordance with
the Agency’s good guidance practices.
4
 Contains Nonbinding Recommendations

In general, FDA’s guidance documents, including this guidance, do not establish legally enforceable
responsibilities. Instead, guidances describe the Agency’s current thinking on a topic and should be
viewed only as recommendations, unless specific regulatory or statutory requirements are cited. The
use of the word should in Agency guidance means that something is suggested or recommended, but
not required.

II. Background
There is currently an outbreak of respiratory disease caused by a novel coronavirus. The virus has
been named “SARS-CoV-2” and the disease it causes has been named “Coronavirus Disease
2019” (COVID-19). On January 31, 2020, HHS issued a declaration of a public health emergency
related to COVID-19 and mobilized the Operating Divisions of HHS. 1 In addition, on March 13,
2020, the President declared a national emergency in response to COVID-19. 2

SARS-CoV-2 has demonstrated the capability to spread rapidly, leading to significant impacts on
health care systems and causing societal disruption. The potential public health threat posed by
COVID-19 is high, both globally and to the United States. To respond effectively to the COVID-19
outbreak, appropriate clinical management and infection control in conjunction with implementation
of community mitigation efforts are critical.

FDA believes the policy set forth in this guidance will help address these urgent public health
concerns by helping to increase the availability of sterilizers, disinfectant devices, and air purifiers
during this public health emergency. Increased access to these devices may facilitate rapid
turnaround of sterilized or disinfected medical equipment and reduce the risk of viral exposure for
patients and health care providers to SARS-CoV-2.

III. Scope
The enforcement policies described in this guidance apply to the following devices and their
accessories during the COVID-19 public health emergency. This enforcement policy applies to
devices that already have FDA marketing authorization, as well as devices that are not currently
marketed but would fall under one of the classification regulations set forth below.

A. Sterilizers
Sterilizers for use in a health care facility are medical devices that are regulated by FDA and are
intended to render medical devices sterile (i.e., free from viable microorganisms). Sterilizers vary in
both construction (ranging from small table-top sterilizers to large sterilizers intended for large loads)
and modality (e.g., steam, ethylene oxide, vaporized hydrogen peroxide, etc.). FDA evaluates and
authorizes sterilizers for marketing with specific cycle parameters intended for specific loads and
with their own sterilization accessories (e.g., biological indicators, chemical indicators, wraps, trays,

1
Secretary of Health and Human Services Alex M Azar, Determination that a Public Health Emergency Exists. (Jan. 31,
2020), available at https://www.phe.gov/emergency/news/healthactions/phe/Pages/2019-nCoV.aspx).
2
Proclamation on Declaring a National Emergency Concerning the Novel Coronavirus Disease (COVID-19) Outbreak
(Mar. 13, 2020), available at https://www.whitehouse.gov/presidential-actions/proclamation-declaring-national-
emergency-concerning-novel-coronavirus-disease-covid-19-outbreak/.
5
 Contains Nonbinding Recommendations

etc.). The classification regulations and associated product codes for sterilizers are listed in Table 1:

Table 1 – Sterilizers
Classification Regulation Device Type Product Device
Code 3 Classification
21 CFR 872.6730 Endodontic dry heat sterilizer KOK III
21 CFR 872.6730 Glass bead sterilizer ECC III
21 CFR 880.6100 Ethylene-oxide (EO) gas aerator FLI II
cabinet
21 CFR 880.6860 Chemical Sterilizer MLR II
21 CFR 880.6860 Two or more sterilant sterilizer PJJ II
21 CFR 880.6860 EO gas sterilizer FLF II
21 CFR 880.6870 Dry heat sterilizer KMH II
21 CFR 880.6880 Steam sterilizer FLE II
21 CFR 880.6880 Sterilizer automated loading system PEC II

B. Disinfectant Devices
Disinfectant devices are intended to kill pathogens and other kinds of microorganisms by chemical
means or physical means. Disinfectant devices can kill most recognized pathogenic microorganisms,
but not necessarily all microbial forms, such as bacterial spores. Disinfectant devices commonly used
in health care settings include chemical/physical disinfectant devices and ultraviolet (UV)
disinfectant devices.

(1) Chemical/Physical Disinfectant Devices

For the purposes of this guidance, FDA considers chemical/physical disinfectant devices to
encompass chemical disinfectant solutions used to disinfect medical devices, as well as medical
washer disinfectors or automated endoscope reprocessors (AERs) that utilize chemical disinfectant
solutions or physical (e.g., thermal) processes to reprocess 4 medical devices. The product codes and
classification regulations for chemical/physical disinfectant devices, to which the policy in this
guidance applies, are listed in Table 2:

Table 2 – Chemical/Physical Disinfectant Devices

Classification Device Type Product Device
Regulation Code Classification
21 CFR 876.1500 Cleaning accessories for endoscope FEB II
5
21 CFR 880.6885 Medical devices sterilant MED II

3
For more information see the Product Classification Database at
https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfPCD/classification.cfm.
4
The term “reprocess” refers to validated processes used to render a medical device, which has been previously used or
contaminated, fit for a subsequent single use. See FDA’s Guidance, “Reprocessing Medical Devices in Health Care
Settings: Validation Methods and Labeling,” available at https://www.fda.gov/regulatory-information/search-fda-
guidance-documents/reprocessing-medical-devices-health-care-settings-validation-methods-and-labeling.
5
Subject to special controls.
6
 Contains Nonbinding Recommendations

Classification Device Type Product Device

Regulation Code Classification
21 CFR 880.6992 6 Medical devices disinfectors MEC II (exempt
from
premarket
review unless
indicated for
high level
disinfection or
for use on
endoscopes
and
accessories)
21 CFR 880.6992 7 Medical devices cleaners MDZ II
21 CFR 892.1570 High level disinfection reprocessing OUJ II
instrument for ultrasonic transducers, mist
21 CFR 892.1570 High level disinfection reprocessing PSW II
instrument for ultrasonic transducers,
liquid

(2) Ultraviolet (UV) Disinfecting Devices

UV disinfecting devices are devices that use UVA or UVC light to produce a germicidal effect. They
are intended to augment disinfection of health care environmental surfaces after manual cleaning has
been performed. UV disinfecting devices include UV radiation chamber disinfection devices, which
are regulated as Class II devices under 21 CFR 880.6600 (product code OSZ). 8

C. Air Purifiers
Air purifying devices are intended for medical purposes to kill pathogens/microorganisms in the air
by exposure to UV radiation or remove them through filtration. The classification regulations and
associated product codes for air purifying devices, to which the policy in this guidance applies, are
listed in Table 3:

Table 3 – Air Purifiers

Classification Device Type Product Device
Regulation Code Classification
21 CFR 880.5045 Medical recirculation air cleaner FRF II
21 CFR 880.6500 Medical UV air purifier FRA II

IV. Policy
In the context of the COVID-19 public health emergency, it is necessary to maintain an adequate

6
Subject to special controls.
7
Subject to special controls.
8
Subject to special controls.
7
 Contains Nonbinding Recommendations

supply of sterilizers, disinfectant devices, and air purifiers that can facilitate rapid turnaround of
sterilized or disinfected medical equipment and that help reduce the risk of viral exposure for patients
and health care providers to SARS-CoV-2. FDA believes that certain sterilizers, disinfectant devices,
and air purifiers falling within the scope of this guidance (see Section III) may help reduce this risk
of viral exposure based on our current understanding of these devices and SARS-CoV-2.

Coronaviruses are RNA viruses enveloped in a lipid bilayer. 9,10 SARS-CoV-2 is a type of
coronavirus. As depicted in Figure 1, lipid viruses are the least resistant microorganisms on the scale
of descending order of resistance to germicidal chemicals. 11 Because sterilization processes render
devices free from viable microorganisms including bacterial spores, and because disinfection kills
most recognized pathogenic microorganisms, it can generally be inferred that sterilization and
disinfection should minimize the viability of SARS-CoV-2 (as one of the least resistant
microorganisms) on surfaces and in the air in confined spaces. Moreover, air purifiers can be
designed to filter out virus-sized particles.

Figure 1. Descending Order of Resistance of Microorganisms to Germicidal Chemicals.

In general, manufacturers of sterilizers, disinfectant devices, and air purifiers are required to submit a
marketing application to FDA when seeking to market these devices. When these devices are
previously approved or cleared, modifications to the indications or functionality of the devices would
also generally require premarket authorization. However, to help ensure the availability of equipment
that might offer some benefit to health care providers and the general public during the COVID-19

9
Beniac, D., Andonov, A., Grudeski, E. et al. Architecture of the SARS coronavirus prefusion spike. Nat Struct Mol Biol
13, 751–752 (2006).
10
Fehr AR, Perlman S. Coronaviruses: an overview of their replication and pathogenesis. Methods Mol Biol. 1282:1–23
(2015).
11
Please see FDA’s Guidance, “Reprocessing Medical Devices in Health Care Settings: Validation Methods and
Labeling,” available at https://www.fda.gov/regulatory-information/search-fda-guidance-documents/reprocessing-
medical-devices-health-care-settings-validation-methods-and-labeling.
8
 Contains Nonbinding Recommendations

outbreak, during the declared public health emergency, FDA does not intend to object to limited
modifications to the indications or functionality of FDA-cleared or FDA-approved sterilizers,
disinfectant devices and air purifiers pertaining to a device’s virucidal effectiveness against SARS-
CoV-2, without compliance with the following regulatory requirements where such devices do not
create an undue risk in light of the public health emergency: prior submission of a premarket
notification under section 510(k) of the FD&C Act and 21 CFR 807.81 12 or submission of a
Premarket Approval Application (PMA) Supplement under section 515 of the FD&C Act and 21
CFR 814.39 13, Registration and Listing requirements in 21 CFR 807, and Unique Device
Identification requirements in 21 CFR 830 and 21 CFR 801.20. FDA believes such devices will not
create such an undue risk where the performance and labeling elements in Sections IV.A and IV.B,
respectively, are met. As an example, this would apply to a manufacturer that previously received
510(k) clearance for a steam sterilizer that is intended for sterilization of medical devices in health
care settings, where the manufacturer would like to include a statement in the labeling that the device
is effective in killing SARS-CoV-2 when used in accordance with the validated sterilization
processes identified in the labeling.

In addition, during the declared public health emergency, FDA does not intend to object to the
distribution and use of sterilizers, disinfectant devices, and air purifiers that are intended to be
effective at killing the SARS-CoV-2 virus but do not already have FDA marketing authorization,
without compliance with the following regulatory requirements where such devices do not create an
undue risk in light of the public health emergency: prior submission of a premarket notification under
section 510(k) of the FD&C Act and 21 CFR 807.81 or submission of a PMA Supplement under
section 515 of the FD&C Act and 21 CFR 814.39, Registration and Listing requirements in 21 CFR
807, and Unique Device Identification requirements in 21 CFR 830 and 21 CFR 801.20. FDA
believes such devices will not create such an undue risk where the performance and labeling
elements in Sections IV.A and IV.B, respectively, are met. As an example, this would apply to a
manufacturer of a new medical air purifier that has not been approved or cleared and that is effective
in filtering out dust particles and bacteria, where the manufacturer would like to modify the filter
mesh size in order to filter out viruses, including the SARS-CoV-2 virus.

The enforcement policies set forth in this guidance do not apply to sterilizers, disinfectant devices,
and air purifiers that are intended to prevent or reduce the risks of hospital acquired infections (HAI)
or COVID-19.

A. Performance
This section gives recommendations regarding design, evaluation, and validation of performance
relevant to the enforcement policies set forth above. FDA encourages firms to discuss any
alternatives to these recommendations with FDA.

12
For further guidance on modifications that trigger the requirement that a manufacturer submit a new premarket
notification (510(k)) to FDA, refer to “Deciding When to Submit a 510(k) for a Change to an Existing Device: Guidance
for Industry and Food and Drug Administration Staff,” available at https://www.fda.gov/regulatory-information/search-
fda-guidance-documents/deciding-when-submit-510k-change-existing-device.
13
For further guidance on modifications that trigger the requirement that a manufacturer submit a PMA supplement to
FDA, refer to “Modifications to Devices Subject to Premarket Approval (PMA) – The PMA Supplement Decision-
Making Process,” available at https://www.fda.gov/regulatory-information/search-fda-guidance-
documents/modifications-devices-subject-premarket-approval-pma-pma-supplement-decision-making-process.
9
 Contains Nonbinding Recommendations

For the current edition of the FDA-recognized standard(s) referenced in this document, see the FDA
Recognized Consensus Standards Database. 14 For more information regarding use of consensus
standards in regulatory submissions, refer to FDA guidance titled “Appropriate Use of Voluntary
Consensus Standards in Premarket Submissions for Medical Devices.” 15

(1) Sterilizers

For the purposes of this guidance, FDA recommends any modifications, including changes to the
indications or functionality, to sterilizers and their accessories be designed, evaluated and validated
in accordance with FDA-recognized 16 standards, including (as applicable):

• Steam Sterilizers
• ANSI/AAMI ST8:2013 Hospital Steam Sterilizers
• ANSI/AAMI ST55:2016 Table-Top Steam Sterilizers
• ANSI/AAMI ST79:2019 Comprehensive Guide to Steam Sterilization and Sterility
Assurance in Health Care Facilities.

• Dry Heat Sterilizers

• AAMI ST50:2004 (R2018) Dry Heat (Heated Air) Sterilizers
• ANSI/AAMI ST40:2004m (R2018) Table-Top Dry Heat (Heated Air) Sterilization
and Sterility Assurance in Health Care Facilities

• Ethylene Oxide Sterilizers

• ANSI/AAMI ST24:1999 (R2018) Automatic, General Purpose Ethylene Oxide
Sterilizers and Ethylene Oxide Sterilant Sources Intended for Use in Health Care
Facilities, 3ed.
• ANSI/AAMI ST41:2008 (R2018) Ethylene Oxide Sterilization in Health Care
Facilities: Safety and Effectiveness

• Other Sterilizers
• ANSI/AAMI/ISO 14937 Sterilization of Health Care Products — General
Requirements for Characterization of a Sterilizing Agent and the Development,
Validation and Routine Control of a Sterilization Process for Medical Devices

• Chemical Indicators
• ANSI/AAMI/ISO 11140 – 1 Sterilization of Health Care Products—Chemical
Indicators—Part 1: General Requirements

• Sterile Packaging
• ANSI/AAMI/ISO 11607-1 Packaging for Terminally Sterilized Medical Devices –
Part 1: Requirements for Materials, Sterile Barrier Systems and Packaging Systems
• ANSI/AAMI/ISO 11607-2 Packaging for Terminally Sterilized Medical Devices –
Part 2: Validation Requirements for Forming, Sealing and Assembly Processes

14
https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfStandards/search.cfm.
15
https://www.fda.gov/regulatory-information/search-fda-guidance-documents/appropriate-use-voluntary-consensus-
standards-premarket-submissions-medical-devices.
16
For the current edition of the FDA-recognized standard(s) referenced in this document, see the FDA Recognized
Consensus Standards Database (https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfStandards/search.cfm).
10
 Contains Nonbinding Recommendations

• Rigid Sterilization Containers

• ANSI/AAMI/ISO ST77:2013 Containment Devices for Reusable Medical Device
Sterilization

• Biological Indicators
• ANSI/AAMI/ISO 11138 Sterilization of Health Care Products—Biological Indicators
Series
• ANSI/AAMI/ISO 14161 Sterilization of Health Care Products — Biological
Indicators — Guidance for the Selection, Use and Interpretation of Results

Manufacturers must document changes to their device in their device master record and change
control records and make this information available to FDA, if requested, consistent with 21 CFR
820.30 and 21 CFR 820.180.

(2) Disinfectant devices

For the purposes of this guidance, FDA recommends any modifications to disinfectant devices be
designed, evaluated and validated in accordance with FDA-recognized standards, including (as
applicable):

• AAMI ST58:2013 (R2018) Chemical Sterilization and High-Level Disinfection in Health

Care Facilities
• Association of Official Analytical Chemists (AOAC) 6.3.05:2013 Official Method 966.04
Sporicidal Activity of Disinfectants
• AOAC 6.3.06:2012 Official Method 965.12 Tuberculocidal Activity of Disinfectants
• AOAC 6.3.02:2006 Official Method 955.17 Fungicidal activity of Disinfectants Using
Trichophyton Mentagrophytes
• AOAC 6.2.01:2013 Official Method 955.14, Testing Disinfectants Against Salmonella
Choleraesuis, Use-Dilution Method
• AOAC 6.2.04:2013 Official Method 955.15, Testing Disinfectants Against Staphylococcus
Aureus, Use-Dilution Method
• AOAC 6.2.06:2013 Official Method 964.02, Testing Disinfectants Against Pseudomonas
Aeruginosa, Use-Dilution Method

In addition, for the purposes of this guidance, FDA recommends that manufacturers of disinfectant
devices evaluate whether the product meets the level of disinfection consistent with its intended use
and labeling, when combined with typical cleaning/reprocessing practices. 17 In doing so, FDA
recommends the following, which are commonly used as part of the clearance or approval of
disinfecting devices:

a) For Low Level Disinfection:

• Definition: A lethal process utilizing an agent that kills vegetative forms of
bacteria, some fungi, and lipid viruses.

17
See FDA’s Guidance “Reprocessing Medical Devices in Health Care Settings: Validation Methods and Labeling”
available at https://www.fda.gov/regulatory-information/search-fda-guidance-documents/reprocessing-medical-devices-
health-care-settings-validation-methods-and-labeling.
11
 Contains Nonbinding Recommendations

• Recommendation for Performance: Demonstrate a 6-log reduction of each of

the following typical vegetative organisms: Pseudomonas aeruginosa,
Staphylococcus aureus, Escherichia coli, and representatives of the Klebsiella
and Enterobacter genus
b) For Intermediate Level Disinfection:
• Definition: A lethal process utilizing an agent that kills viruses, mycobacteria,
fungi and vegetative bacteria, but no bacterial spores.
• Recommendation for Performance: Demonstrate a 6-log reduction of each of
the vegetative organisms and a 3-log reduction of an appropriate species of the
genus Mycobacterium.
c) For High Level Disinfection:
• Definition: A lethal process utilizing a sterilant under less than sterilizing
conditions. The process kills all forms of microbial life except for large
numbers of bacterial spores.
• Recommendation for Performance: Demonstrate a 6-log reduction of each of
the vegetative organisms and a 6-log reduction of an appropriate species of the
genus Mycobacterium. FDA recommends that performance also include
potency testing, simulated use testing, and in-use testing to support the
effectiveness of the device. 18

If the device includes a UV lamp, FDA recommends that the manufacturer evaluate whether the
product controls for time, UV radiation dose, and intensity of UV dose, and validates the cleaning
and disinfection procedures.

If the device generates ozone, FDA recommends that the manufacturer evaluate whether the product
is within the maximum acceptable level of ozone given in 21 CFR 801.415.

Manufacturers must document changes to their device in their device master record and change
control records and make this information available to FDA, if requested, consistent with 21 CFR
820.30 and 21 CFR 820.180.

(3) Air Purifiers

For the purposes of this guidance, FDA recommends that manufacturers of air purifiers evaluate or
perform the following:
1) Demonstration of a 4 log reduction (through a combination of capture or destruction) of
claimed particulates.
2) If intended for use against bacteria, effectiveness against representative gram positive and
gram negative species.
3) If intended for use related to SARS-CoV-2, effectiveness against a representative virus
4) If the device generates ozone, the maximum acceptable level of ozone per 21 CFR 801.415.
5) If intended for use in areas that have a sterile field or controlled air flow, a risk assessment to
address turbulent air flow and/or potential site contamination.

18
For information regarding these tests, please see FDA’s Guidance, “Content and Format of Premarket Notification
[510(k)] Submissions for Liquid Chemical Sterilants/High Level Disinfectants,” https://www.fda.gov/regulatory-
information/search-fda-guidance-documents/content-and-format-premarket-notification-510k-submissions-liquid-
chemical-sterilantshigh-level.
12
 Contains Nonbinding Recommendations

Manufacturers must document changes to their device in their device master record and change
control records and make this information available to FDA, if requested, consistent with 21 CFR
820.30 and 21 CFR 820.180.

B. Labeling
In addition, FDA recommends that the devices described above include labeling that helps users
better understand the device modifications, such as: 19

1) A clear description of the available data on the device’s new indications or functions related
to SARS-CoV-2 or co-existing conditions, such as:
a) Device performance; and
b) Potential risks (e.g., risk of UV exposure)
2) A clear distinction delineating FDA-cleared or FDA-approved indications from those that are
not FDA-cleared or FDA-approved. In addition, FDA recommends the labeling include a
general statement about changes that have not been cleared by FDA.
3) For all disinfectant devices, a clear statement of the level of disinfection.
4) For UV disinfecting devices:
a) A caution that UV disinfection will reduce the number of pathogens on the device, but it
will not eliminate them completely.
b) A statement that the device is an adjunct to currently existing reprocessing practices and
not a replacement or modification to such practices.
c) A statement regarding the time, distance, and maximum area over which the device has
been evaluated for effectiveness.
d) An appropriate UV hazard warning label.
e) Identification of the expected UV lamp operational life and instructions for procedures on
replacement of the UV lamp when needed.
f) Procedures to follow if the UV lamp malfunctions or fails.
g) Description of the preparation of equipment or the room for disinfection
h) A statement that the equipment intended to be disinfected is UV compatible.
i) Identification of the UV dose.

C. Additional Helpful Resources

The following online resources may be helpful regarding FDA’s policies on sterilization and
disinfection:

Sterilization
• Submission and Review of Sterility Information in Premarket Notification (510(k))
Submissions for Devices Labeled as Sterile Guidance for Industry and Food and Drug
Administration Staff 20
• Guidance on Premarket Notification 510(k) for Sterilizers Intended for Use in Health

19
For modifications to cleared devices that are subject to special controls relating to labeling, FDA believes that
manufacturers meeting those special controls would also be consistent with the recommended labeling elements in
Section IV.B.
20
https://www.fda.gov/regulatory-information/search-fda-guidance-documents/submission-and-review-sterility-
information-premarket-notification-510k-submissions-devices-labeled
13
 Contains Nonbinding Recommendations

Care Facilities 21
• Reprocessing Medical Devices in Health Care Settings: Validation Methods and Labeling
- Guidance for Industry and Food and Drug Administration Staff 22

Disinfection
• Medical Washers and Medical Washer-Disinfectors - Class II Special Controls Guidance
Document for the Medical Device Industry and FDA Review Staff 23
• Guidance on Premarket Notification [510(k)] Submissions for Automated Endoscope
Washers, Washer/Disinfectors, and Disinfectors Intended for Use in Health Care
Facilities 24
• Content and Format of Premarket Notification [510(k)] Submissions for Liquid Chemical
Sterilants/High Level Disinfectants - Guidance for Industry and FDA Reviewers 25
• Reprocessing Medical Devices in Health Care Settings: Validation Methods and Labeling
- Guidance for Industry and Food and Drug Administration Staff 26

21
https://www.fda.gov/regulatory-information/search-fda-guidance-documents/guidance-premarket-notification-510k-
sterilizers-intended-use-health-care-facilities
22
https://www.fda.gov/regulatory-information/search-fda-guidance-documents/reprocessing-medical-devices-health-
care-settings-validation-methods-and-labeling
23
https://www.fda.gov/medical-devices/guidance-documents-medical-devices-and-radiation-emitting-products/medical-
washers-and-medical-washer-disinfectors-class-ii-special-controls-guidance-document-medical
24
https://www.fda.gov/regulatory-information/search-fda-guidance-documents/guidance-premarket-notification-510k-
submissions-automated-endoscope-washers-washerdisinfectors-and
25
https://www.fda.gov/regulatory-information/search-fda-guidance-documents/content-and-format-premarket-
notification-510k-submissions-liquid-chemical-sterilantshigh-level
26
https://www.fda.gov/regulatory-information/search-fda-guidance-documents/reprocessing-medical-devices-health-
care-settings-validation-methods-and-labeling
14