(206 days)
System 100 is indicated for temorary (up to 8 hours) ultrafiltration treatment of patients with fluid overload.
System 100 consists of the:
• S-100 console
• UF 500 set
• Venous access catheters
• Catheter extension set
• Needless flushing port
• Catheter insertion kit
The provided text describes the "System 100" device, a high-permeability hemodialysis system, and its FDA 510(k) clearance. However, it does not contain specific acceptance criteria, detailed study designs, or quantitative results that would allow for a complete description of the device's performance against predefined metrics.
The text primarily focuses on the regulatory submission process and the determination of substantial equivalence to a predicate device.
Here's an analysis based on the information available in the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria | Reported Device Performance |
|---|---|
| Not specified | Not specified |
Explanation: The document states that "CHF Solutions, Inc. performed non-clinical testing on System 100 to demonstrate that the device met its functional and performance specification." and "Clinical data confirm that the device is safe and effective for its intended use." However, it does not explicitly define these "functional and performance specifications" as acceptance criteria, nor does it provide quantitative results or metrics against which performance was measured.
2. Sample Size Used for the Test Set and Data Provenance
| Sample Size (Test Set) | Data Provenance |
|---|---|
| Not specified | Not specified |
Explanation: The document mentions "Clinical data confirm that the device is safe and effective." However, it does not provide any details about the sample size of the clinical study, whether it was prospective or retrospective, or the country of origin of the data.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
| Number of Experts | Qualifications of Experts |
|---|---|
| Not applicable | Not applicable |
Explanation: This type of information is typically relevant for interpretative diagnostic devices where human experts establish ground truth for testing AI algorithms. The System 100 is a medical device for ultrafiltration, not an AI-powered diagnostic tool, so this concept does not directly apply.
4. Adjudication Method for the Test Set
| Adjudication Method |
|---|
| Not applicable |
Explanation: As with the previous point, adjudication methods are typically used for establishing ground truth from multiple expert interpretations, which is not relevant for this type of medical device's performance testing.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was Done
| MRMC Study Conducted | Effect Size (Human readers improved with AI vs. without AI) |
|---|---|
| No | Not applicable |
Explanation: An MRMC comparative effectiveness study is specific to evaluating the impact of AI assistance on human reader performance, usually in image-based diagnostics. The System 100 is a physical medical device, not an AI system, so this type of study would not be applicable.
6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) was Done
| Standalone Study Conducted |
|---|
| Not applicable |
Explanation: "Standalone" performance refers to an algorithm's performance without human intervention, again, relevant for AI diagnostic systems. This device is not an AI algorithm.
7. The Type of Ground Truth Used
| Type of Ground Truth |
|---|
| Not specified |
Explanation: While "Clinical data confirm that the device is safe and effective," the specific type of ground truth (e.g., patient outcomes, physiological measurements, laboratory results) used in these clinical studies to evaluate safety and effectiveness is not detailed. For a device like this, ground truth would likely involve measurements of fluid removal, patient vital signs, and adverse event reporting.
8. The Sample Size for the Training Set
| Sample Size (Training Set) |
|---|
| Not applicable |
Explanation: The concept of a "training set" is typically associated with machine learning or AI models. The System 100 is a physical medical device, not an AI algorithm, so it does not have a training set in this context.
9. How the Ground Truth for the Training Set Was Established
| How Ground Truth was Established (Training Set) |
|---|
| Not applicable |
Explanation: As stated above, there is no training set for this type of device.
In summary: The provided 510(k) summary focuses on the regulatory aspects of substantial equivalence. It confirms that non-clinical and clinical data were generated to demonstrate safety and effectiveness but does not provide the granular details requested regarding specific acceptance criteria, study methodologies, or quantitative performance metrics. Such details would typically be found in more comprehensive study reports or validation documentation, which are not part of this 510(k) summary.
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JUN 0 3 2002
510(k) Summary for CHF Solutions' System 100
.
,
| 510(k) Summary | This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of 21 C.F.R. § 807.92. |
|---|---|
| Submitter | CHF Solutions, Inc. |
| Contact Person | Dianna ThomsenKing & Spalding1730 Pennsylvannia Ave.Washington, D.C. 20006Telephone: 202-626-5594FAX: 202-626-3737 |
| Date Prepared | November 9, 2001 |
| Name | System 100 |
| Classification Name | High permeability hemodialysis system |
| Device Classification | Classification: Class IIClassification Panel: Gastroenterology DevicesRegulation Number: 21 C.F.R. §876.5680 |
| Predicate Devices | PRISMA Continuous Fluid Management System (K981681; cleared 1998)PRISMA M60 Set |
| Performance Standards | Performance standards have not been established by the FDA under section 514 of the Federal, Food, Drug and Cosmetic Act. |
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510(k) Summary for CHF Solutions' System 100
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| Device Description | System 100 consists of the:• S-100 console• UF 500 set• Venous access catheters• Catheter extension set• Needless flushing port• Catheter insertion kit |
|---|---|
| Indications for Use | System 100 is indicated for temorary (up to 8 hours) ultrafiltrationtreatment of patients with fluid overload. |
| TechnologicalCharacteristics | System 100 contains features and functions that were previously-clearedin PRISMA's device. Minor modifications were made to System 100because the device is designed to only remove fluids (the predicatedevice removes fluids and solutes) and to incorporate current technology. |
| Non-clinical andClinicalPerformance Data | CHF Solutions, Inc. performed non-clinical testing on System 100 todemonstrate that the device met its functional and performancespecification. System 100 was subjected to extensive safety, software,and performance testing. Clinical data confirm that the device is safe andeffective for its intended use. |
| Conclusion | System 100 is substantially equivalent to the currently cleared andmarketed PRISMA system. |
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/2/Picture/2 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized image of a bird-like figure, possibly representing a human profile, with three wavy lines extending from it.
3 2002 JUN
Food and Drug Administration . 9200 Corporate Boulevard Rockville MD 20850
CHF Solutions. Inc. c/o Ms. Dianna Thomsen King and Spalding 1730 Pennsylvania Avenue, N.W. WASHINGTON DC 20006-4706
Re: K013733
Trade/Device Name: System 100 with UF 500 Set, Venous Access Catheters, Catheter Extension Set, and Catheter Insertion Kit Regulation Number: 21 CFR 876.5860 Regulation Name: High permeability hemodialysis system Regulatory Class: II Product Code: 78 KDI Dated: March 5, 2002 Received: March 5, 2002
Dear Ms. Thomsen:
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 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). You may, therefore, market the device, subject to the general controls provisions of Act. However, you are responsible to determine that the medical devices you use as components in your catheter insetion kit have either been determined as substantially equivalent under the premarket notification process (Section 510(k) of the act), or were on the market prior to May 28, 1976, the enactment date of the Medical Device Amendments. 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.
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.
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); good manufacturing practice requirements as set
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Page 2 – Ms.. Dianna Thomsen
forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
In addition, we have determined that your device kit contains povidone iodine swabsticks, which are subject to regulation as drugs.
Our substantially equivalent determination does not apply to the drug components of your device. We recommend you first contact the Center for Drug Evaluation and Research before marketing your device with these drug components. For information on applicable Agency requirements for marketing these drugs, we suggest you contact:
Director, Division of Drug Labeling Compliance (HFD-310) Center for Drug Evaluation and Research Food and Drug Administration 5600 Fishers Lane Rockville, Maryland 20857 (301) 594-0101
This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market. If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and additionally Part 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4616. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification''(21 CFR Part 807.97). Other general information on your responsibilities under the Act, may be obtained from the Division of Small Manufacturers, International and Consumer Assistance at its toll free number (800) 638-2041 or (301) 443-6597, or at its Internet address http://www.fda.gov/cdrh.dsma/dsmamain.html.
Sincerely yours.
Daniel A. Bergman
Nancy C. Brogdon Director, Division of Reproductive, Abdominal, and Radiological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Indications for Use Statement
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Page 1 of 1
510(k) Number: K013733
Device Name: System 100
Indications for Use:
System 100 is indicated for temporary (up to 8 hours) ultrafiltration treatment of patients with fluid overload.
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Prescription Use
(Division Sign-Off)
Division of Reproductive, Abdominal,
and Radiological Devices
510(k) Number K013733
§ 876.5860 High permeability hemodialysis system.
(a)
Identification. A high permeability hemodialysis system is a device intended for use as an artificial kidney system for the treatment of patients with renal failure, fluid overload, or toxemic conditions by performing such therapies as hemodialysis, hemofiltration, hemoconcentration, and hemodiafiltration. Using a hemodialyzer with a semipermeable membrane that is more permeable to water than the semipermeable membrane of the conventional hemodialysis system (§ 876.5820), the high permeability hemodialysis system removes toxins or excess fluid from the patient's blood using the principles of convection (via a high ultrafiltration rate) and/or diffusion (via a concentration gradient in dialysate). During treatment, blood is circulated from the patient through the hemodialyzer's blood compartment, while the dialysate solution flows countercurrent through the dialysate compartment. In this process, toxins and/or fluid are transferred across the membrane from the blood to the dialysate compartment. The hemodialysis delivery machine controls and monitors the parameters related to this processing, including the rate at which blood and dialysate are pumped through the system, and the rate at which fluid is removed from the patient. The high permeability hemodialysis system consists of the following devices:(1) The hemodialyzer consists of a semipermeable membrane with an in vitro ultrafiltration coefficient (K
uf ) greater than 8 milliliters per hour per conventional millimeter of mercury, as measured with bovine or expired human blood, and is used with either an automated ultrafiltration controller or anther method of ultrafiltration control to prevent fluid imbalance.(2) The hemodialysis delivery machine is similar to the extracorporeal blood system and dialysate delivery system of the hemodialysis system and accessories (§ 876.5820), with the addition of an ultrafiltration controller and mechanisms that monitor and/or control such parameters as fluid balance, dialysate composition, and patient treatment parameters (e.g., blood pressure, hematocrit, urea, etc.).
(3) The high permeability hemodialysis system accessories include, but are not limited to, tubing lines and various treatment related monitors (e.g., dialysate pH, blood pressure, hematocrit, and blood recirculation monitors).
(b)
Classification. Class II. The special controls for this device are FDA's:(1) “Use of International Standard ISO 10993 ‘Biological Evaluation of Medical Device—Part I: Evaluation and Testing,’ ”
(2) “Guidance for the Content of 510(k)s for Conventional and High Permeability Hemodialyzers,”
(3) “Guidance for Industry and CDRH Reviewers on the Content of Premarket Notifications for Hemodialysis Delivery Systems,”
(4) “Guidance for the Content of Premarket Notifications for Water Purification Components and Systems for Hemodialysis,” and
(5) “Guidance for Hemodialyzer Reuse Labeling.”