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510(k) Data Aggregation

    K Number
    K180111

    Validate with FDA (Live)

    Date Cleared
    2018-05-25

    (129 days)

    Product Code
    Regulation Number
    876.5540
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    ClearGuard HD Antimicrobial Barrier Cap is indicated for use with hemodialysis catheter hubs.

    Using in vitro methods, the antimicrobial treatment on the ClearGuard HD Antimicrobial Barrier Cap has been shown to be effective at reducing microbial colonization in hemodialysis catheter hubs against the following microorganisms: Enterococcus faecium (VRE), Enterococus faecalis (VRE), Acinetobacter baumannii, Escherichia coli, Staphylococcus aureus (MRSA), Staphylococcus aureus, Staphylococcus epidermidis (MRSE), Pseudomonas aeruginosa, Candida albicans and Candida parapsilosis and has not been shown to be effective against Candida paratropicalis and Klebsiella pneumoniae.

    Using post-market clinical surveillance data, use of the ClearGuard HD Antimicrobial Barrier Cap has been shown to reduce the incidence of central-line associated bloodstream infections (CLABSI) in hemodialysis patients. Note: CLABSI was defined as a positive blood culture (PBC) not related to an alternative source of infection per the National Healthcare Safety Network (NHSN) surveillance definition. Alternative sources were excluded if dialysis sites attributed the PBC to vascular access on the dialysis event form. The actual reduction in CLABSI rates may be less substantial as the evaluation for alternative PBC sources was not pre-specified, nor standardized between pafients and clinical sites, and supplemental data evaluating for alternative sources were not available for review.

    The subject device is not intended to be used for the treatment of existing infections. The antimicrobial is only present within the hub of the catheter and does not migrate to distal portions of the catheter.

    Device Description

    The ClearGuard HD Antimicrobial Barrier Cap (hereinafter also referred to as the ClearGuard HD cap) is a single-use male luer lock cap that incorporates an antimicrobial treatment on its surfaces.

    The ClearGuard HD cap consists of 1) a polypropylene polymer plug, which has a rod extending from the luer region that is coated with the antimicrobial agent chlorhexidine acetate (CHA) and 2) a nylon lock ring with threads that are also coated with CHA. When a ClearGuard HD cap is inserted into a liquid-filled catheter, CHA elutes from the rod into the catheter lock solution. This CHA solution is designed to kill microorganisms in the hemodialysis catheter hub, which results in a reduction in Central Line-Associated Bloodstream Infection (CLABSI) rates.

    The catheter extension line pinch clamps are used to maintain the lock solution within the catheter lumens to minimize the risk of air embolism and maintain catheter patency. These clamps, which are closed when the catheter is not in use, mechanically confine the CHA and prevent diffusion of CHA toward the catheter tip and the patient's bloodstream.

    AI/ML Overview

    The ClearGuard HD Antimicrobial Barrier Cap is designed to reduce microbial colonization in hemodialysis catheter hubs and, based on clinical surveillance data, to reduce the incidence of Central-Line Associated Bloodstream Infections (CLABSI) in hemodialysis patients.

    Here's an analysis of the provided information:

    1. Table of acceptance criteria and the reported device performance

    Acceptance Criteria / Performance AspectReported Device Performance (ClearGuard HD)
    Antimicrobial Effectiveness (In Vitro)Shown to be effective at reducing microbial colonization in hemodialysis catheter hubs against: Enterococcus faecium (VRE), Enterococcus faecalis (VRE), Acinetobacter baumannii, Escherichia coli, Staphylococcus aureus (MRSA), Staphylococcus aureus, Staphylococcus epidermidis (MRSE), Pseudomonas aeruginosa, Candida albicans, and Candida parapsilosis. Not shown to be effective against Candida paratropicalis and Klebsiella pneumoniae. These results were consistent "initially, and after 3 years real time shelf life."
    BiocompatibilityNon-hemolytic, non-cytotoxic, non-irritating, non-sensitizing, non-mutagenic, non-toxic, and non-pyrogenic under intended use conditions.
    Device IntegrityMet requirements for liquid leakage, disassembly torque, plug, shield and pouch integrity, and for antimicrobial quantity, elution, and solubility.
    PBC Rate Reduction (Clinical)ClearGuard HD: 0.28 per 1,000 CVC-daysControl (Tego+Curos): 0.75 per 1,000 CVC-daysIncidence Rate Ratio (IRR): 0.37Reduction in PBC Rate: 63%P-value: 0.001 (statistically significant reduction)
    CLABSI Rate Reduction (Clinical)ClearGuard HD: 0.17 per 1,000 CVC-daysControl (Tego+Curos): 0.50 per 1,000 CVC-daysIncidence Rate Ratio (IRR): 0.34Reduction in CLABSI Rate: 66% (This was an exploratory ad-hoc analysis, not a pre-specified primary endpoint, and has limitations as noted in the document.)
    SafetyNo device-associated adverse events reported during the clinical study or a previous study via the FDA's medical device reporting (MDR) system.

    2. Sample size used for the test set and the data provenance

    • Test Set Sample Size: For the clinical study, 1,671 subjects participated in the primary and exploratory analyses, accruing approximately 183,000 CVC-days in the primary analysis.
      • ClearGuard HD Arm: 826 subjects
      • Control Arm (Tego® Connector with Curos™ Disinfecting Cap): 845 subjects
    • Data Provenance: The clinical study was a prospective, cluster-randomized, multi-arm, unblinded clinical study conducted at 40 dialysis facilities throughout the United States only.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    The document does not explicitly state the number or qualifications of experts used to establish the ground truth for the clinical study's test set. However, it notes that:

    • "As is standard policy at the participating facilities, blood culture results were reported into the electronic health record in automated fashion and to the National Healthcare Safety Network (NHSN) Dialysis Event (DE) Form, from which they were abstracted for analysis."
    • CLABSI was defined per the National Healthcare Safety Network (NHSN) surveillance definition.
    • "All cultures were processed by a single clinical laboratory."

    This suggests that the ground truth for PBCs and CLABSIs was established through standard clinical laboratory procedures and adherence to NHSN surveillance definitions, rather than through a panel of independent experts reviewing cases.

    4. Adjudication method for the test set

    The document does not describe a formal adjudication method (e.g., 2+1, 3+1) for the clinical study's test set. The determination of Positive Blood Cultures (PBCs) and CLABSIs appears to be based on laboratory results and the NHSN surveillance definition, with physicians at the dialysis sites making preliminary attributions of the PBC source on the Dialysis Event form.

    5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

    A Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. The device is an antimicrobial barrier cap, not an AI software intended for human interpretation improvement. The clinical study directly compared the effectiveness of two devices (ClearGuard HD vs. Tego+Curos) in reducing infection rates.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    This question is not applicable as the ClearGuard HD Antimicrobial Barrier Cap is a physical medical device, not an algorithm or AI system.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    • For antimicrobial effectiveness (in vitro tests): The ground truth was based on microbiological assays, specifically measuring reduction in microbial colonization.
    • For biocompatibility: Ground truth was established through standardized biological evaluation tests (e.g., cytotoxicity, irritation, sensitization, toxicity, pyrogenicity).
    • For clinical efficacy (PBC and CLABSI rates): The ground truth was based on outcomes data (positive blood cultures and CLABSI events) derived from patient medical records, laboratory results, and reported according to the National Healthcare Safety Network (NHSN) surveillance definition. Physicians at varying clinical sites attributed the PBC to a vascular access on the dialysis event form if no alternative source was identified. It is important to note the caveat regarding CLABSI: "The actual reduction in CLABSI rates may be less substantial as the evaluation for alternative PBC sources was not pre-specified, nor standardized between patients and clinical sites, and supplemental data evaluating for alternative sources were not available for review."

    8. The sample size for the training set

    This question is not applicable. The ClearGuard HD Antimicrobial Barrier Cap is a physical medical device and does not involve a "training set" in the context of machine learning or AI.

    9. How the ground truth for the training set was established

    This question is not applicable for the reasons stated above.

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    K Number
    K131060

    Validate with FDA (Live)

    Date Cleared
    2013-12-16

    (244 days)

    Product Code
    Regulation Number
    876.5540
    Reference & Predicate Devices
    N/A
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    ClearGuard HD is indicated for use as an end cap for use with hemodialysis catheter hubs.

    The antimicrobial treatment on the ClearGuard HD has been shown to be effective at reducing microbial colonization in hemodialysis catheter hubs against the following microorganisms: Enterococcus faecium (VRE), Enterococcus faecalis (VRE), Acinetobacter baumannii, Escherichia coli, Staphylococcus aureus (MRSA), Staphylococcus aureus, Staphylococcus epidermidis (MRSE), Pseudomonas aeruginosa, Candida albicans and Candida parapsilosis and has not been shown to be effective against Candida paratropicalis and Klebsiella pneumoniae.

    The antimicrobial effectiveness was evaluated using in vitro methods and correlation between in vitro antibacterial activity and any clinical effectiveness has not been tested. It is not intended to be used for the treatment of existing infections. The antimicrobial is only effective within the hub of the catheter, and does not migrate to distal portions of the catheter.

    Device Description

    The ClearGuard HD end cap is male lucr lock end cap that incorporates an antimicrobial treatment on its surfaces. It is designed to reduce microbial colonization within a hemodialysis catheter hub.

    The ClearGuard HD end cap consists of 1) a copolyester polymer plug, which has a rod extending from the luer region that is coated with the antimicrobial agent chlorhexidine actate (CHA) and 2) a nylon lock ring with threads that are also coated with CHA. When a ClearGuard HD end cap is inserted into a liquid-filled catheter, CHA clutes into the catheter lock solution. This CHA solution is designed to reduce the number of microorganisms in the hemodialysis catheter hub.

    The catheter extension line pinch clamps are used to maintain the lock solution within the catheter lumens and minimize the risk of air embolism. These clamps, which are closed when the catheter is not in use, mechanically confine the CHA and prevent diffusion of CHA toward the catheter tip and the patient's bloodstream.

    AI/ML Overview

    This document describes the 510(k) summary for the Pursuit Vascular, Inc. ClearGuard HD.

    The information provided within the input focuses on the submission for a medical device (ClearGuard HD End Cap) for 510(k) clearance based on substantial equivalence, primarily through non-clinical testing. Therefore, many of the typical acceptance criteria and study details for AI/software-based diagnostics (e.g., sample sizes for test sets, expert consensus, MRMC studies) are not applicable in this context.

    Here's an analysis of the provided information, addressing what is present and what is not applicable:

    1. A table of acceptance criteria and the reported device performance

    The document doesn't explicitly define "acceptance criteria" in a quantitative, pass/fail threshold manner for performance metrics like sensitivity or specificity, as one might find for a diagnostic algorithm. Instead, the "acceptance criteria" are implied by the requirements for demonstrating substantial equivalence to a predicate device.

    The reported device performance primarily relates to its antimicrobial effectiveness and safety.

    Acceptance Criteria (Implied by Substantial Equivalence and Device Claims)Reported Device Performance (Summary of Non-Clinical Testing)
    Intended Use Equivalence: Same intended use as predicate device.ClearGuard HD is indicated for use as an end cap for use with hemodialysis catheter hubs, equivalent to the end caps on the predicate (Boston Scientific Corporation Vaxcel™ Plus Chronic Dialysis Catheter).
    Antimicrobial Effectiveness: Ability to reduce microbial colonization.The antimicrobial treatment on the ClearGuard HD has been shown to be effective at reducing microbial colonization in hemodialysis catheter hubs against the following microorganisms (evaluated using in vitro methods): Enterococcus faecium (VRE), Enterococcus faecalis (VRE), Acinetobacter baumannii, Escherichia coli, Staphylococcus aureus (MRSA), Staphylococcus aureus, Staphylococcus epidermidis (MRSE), Pseudomonas aeruginosa, Candida albicans and Candida parapsilosis. (Note: Not effective against Candida paratropicalis and Klebsiella pneumoniae). The antimicrobial agent (chlorhexidine acetate) is the same as on a reference device (Arrow Antimicrobial Pressure Injectable PICC).
    Safety: Device is safe for use and introduces no new safety concerns.Results of design verification and validation testing demonstrate that the ClearGuard HD end cap is safe for use with hemodialysis catheters and reliably seals catheter hubs. It introduces no new or increased safety concerns compared to the predicate and reference devices. The risk assessment results confirm this.
    Reliable Seals: Ability to reliably seal catheter hubs.Results of design verification and validation testing demonstrate that the ClearGuard HD end cap reliably seals catheter hubs.
    Other: Hub compatibility, sterile, non-pyrogenic, single-use.The device meets these characteristics, making it substantially equivalent to the predicate device in these aspects.

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    • Not Applicable / Not Provided for Clinical Data: The submission explicitly states: "Not applicable - no clinical data was needed to demonstrate substantial equivalence to its predicate device."
    • For the non-clinical (in vitro) testing of antimicrobial effectiveness and safety, the specific "sample size" of individual tests (e.g., number of cultures, number of sealing integrity tests) is not detailed in this summary. The data provenance would be laboratory-based in vitro studies.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

    • Not Applicable: Given the absence of clinical data and the nature of the device (an end cap with antimicrobial properties), there was no "ground truth" to be established by clinical experts in the context of diagnostic accuracy. The effectiveness was assessed through in vitro microbiological methods.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    • Not Applicable: There was no clinical imagery or diagnostic interpretation requiring an adjudication method.

    5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

    • Not Applicable: This is a physical medical device (an end cap), not an AI diagnostic algorithm. Therefore, MRMC studies and AI assistance are irrelevant to this submission.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    • Not Applicable: This is a physical medical device.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    • Not Applicable / In Vitro Results: For the antimicrobial effectiveness, the "ground truth" was established by in vitro microbiological culture results (i.e., quantifying microbial colonization reduction in laboratory settings). For safety and sealing, it was established by engineering and design verification/validation testing.

    8. The sample size for the training set

    • Not Applicable: As this is not an AI/machine learning device, there is no concept of a "training set."

    9. How the ground truth for the training set was established

    • Not Applicable: There is no training set for this type of device.
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