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510(k) Data Aggregation

    K Number
    K160098

    Validate with FDA (Live)

    Date Cleared
    2016-03-22

    (63 days)

    Product Code
    Regulation Number
    876.1075
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    This instrument has been designed to be used with ultrasound guided fine needle aspiration (FNA) of submucosal and extramural lesions of the tracheobronchial tree and the gastrointestinal tract.

    Device Description

    The single use aspiration needle NA-U401SX (aka ViziShot 2) is intended to be used in conjunction with Olympus ultrasound endoscopes for ultrasound guided fine needle aspiration (FNA). It consists of a handle section and insertion. The handle section is connected to the endoscope's instrument channel port via the single use adapter biopsy valve (MAJ-1414). The insertion section is composed of the sheath, needle, and stylet. The needle is stored in the sheath and extended from the sheath to puncture the target tissue to collect specimen by moving the needle slider on the handle. A syringe is attached to the aspiration port on the handle section to aspirate the specimen that was punctured with the needle. The needle is dimpled for echo enhancement and also consists of an oval portion for better angulation.

    The subject device will be sold with or without medallion syringe manufactured by Merit Medical, which consists of VACLOK Syringe and Stopcock.

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for the "Single Use Aspiration Needle NA-U401SX" (aka ViziShot 2). This notification primarily focuses on demonstrating substantial equivalence to a predicate device, rather than detailed performance studies with acceptance criteria as one might find for more complex software or diagnostic devices.

    Therefore, much of the requested information regarding detailed acceptance criteria, specific study designs, sample sizes for test sets, expert involvement, and comparative effectiveness (MRMC or standalone AI performance) is not present in this document. This document details a medical device (a needle), and the "performance" here relates to its physical and functional attributes, not an algorithm's diagnostic capabilities.

    However, I can extract the information that is available regarding the "acceptance criteria" and the "study" that proves the device meets them, based on the provided text.


    1. Table of Acceptance Criteria and Reported Device Performance

    Performance ItemAcceptance CriteriaReported Device Performance
    Basic Performance ItemsEstablished in-house acceptance criteria based on risk analysis (ISO 14971:2007)Demonstrated the basic performance as intended for: - Inserting into endoscope- Flexibility of the insertion portion- Piercing- Ultrasound visibility- Needle extraction and retraction- Aspiration- Withdrawal from endoscope- Locking force of handle portion- Limitation of needle depth
    Biocompatibility TestingCompliance with FDA Guidance," Required Biocompatibility Training and Toxicology Profiles for Evaluation of Medical Devices, Blue Book Memo, G95-1" and relevant ISO standards (ISO 10993-1, -5, -10, -11).Performed in accordance with the specified FDA Guidance and ISO standards.
    SterilizationCompliance with ISO 11135 (Sterilization of health care products — Ethylene oxide — Requirements for the development, validation and routine control of a sterilization process for medical devices).Applied ISO 11135.
    Packaging/Shelf LifeCompliance with ASTM F-1980-07 (Standard Guide for Accelerated Aging of Sterile Medical Device Packages).Applied ASTM F-1980-07.
    Technological Characteristics (vs. predicate)Validation testing demonstrated that differences in needle tube shape on proximal side, sheath composition, and materials do not affect the safety or effectiveness of the subject devices. (Specifically, the oval portion of the needle tube and new patient contact materials, with sheath design similar to K904667).Validation testing demonstrated that these technological features do not affect the safety or effectiveness of the subject devices.

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

    • Sample Size: The document does not specify exact sample sizes (e.g., number of needles tested, number of in-vitro experiments). It refers to "testing" and "analysis" rather than specific numerical units of a test set. This is typical for a 510(k) for a physical device where tests are often on prototypes or manufacturing samples.
    • Data Provenance: The studies are non-clinical ("Summary of non-clinical testing") and were conducted in-house by the manufacturer (Olympus Medical Systems Corp. and Aomori Olympus Co., Ltd. in Japan). The specific country of origin for the data generation would therefore be Japan. The data is prospective in the sense that the testing was performed specifically to support this 510(k) submission for the new device.

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

    This section is not applicable as the device is a physical medical instrument (an aspiration needle) and not an AI or diagnostic algorithm that requires expert-established ground truth for performance evaluation in the context of diagnostic accuracy. The "ground truth" here is the physical and functional integrity and performance of the device against engineering and safety standards.


    4. Adjudication method for the test set

    This is not applicable. Adjudication methods like 2+1 or 3+1 are used for reconciling discordant expert opinions, typically in diagnostic studies or when establishing ground truth for AI model training/testing. This document describes non-clinical engineering and biocompatibility tests for a physical device.


    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

    This is not applicable. MRMC studies are specific to evaluating the clinical performance of diagnostic systems or AI tools with human readers. This submission is for a physical medical device (an aspiration needle), not an AI system.


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

    This is not applicable. This device is a physical medical instrument and does not involve an algorithm.


    7. The type of ground truth used

    The "ground truth" for this device's performance evaluation is established by:

    • Engineering specifications and design requirements: For items like flexibility, piercing ability, aspiration, locking force, and needle depth limitation.
    • Regulatory standards: Specifically, ISO 14971 (Risk Management), ISO 10993 series (Biocompatibility), ISO 11135 (Sterilization), and ASTM F-1980-07 (Packaging/Shelf Life Accelerated Aging).
    • Functional tests: Verification that the device performs its intended functions (e.g., "inserting into endoscope," "ultrasound visibility").

    8. The sample size for the training set

    This is not applicable. The device is a physical instrument, not an AI model that requires a training set.


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

    This is not applicable for the same reason as above; there is no training set for a physical device. Ground truth for the design and testing of the device is established by the engineering and regulatory standards listed in point 7.

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