(179 days)
The SMDIA-1000 MDI adaptor is intended to be used with an MDI for intermittent delivery of prescribed aerosol medications dispensed in MDIs. It is intended for use only when connected to ventilator tubing or tracheal tubes.
The SMDIA-1000 MDI adaptor is single patient use, disposable.
The Southmedic SMDIA-1000 is an adaptor which acts as an actuator for intermittent delivery of prescribed aerosol medications dispensed by meter dose inhalers (MDI). The SMDIA-1000 is connected to ventilator tubing and the MDI connected when drug delivery into the circuit is required. The SMDIA-1000 adaptor may also be connected to the endotracheal tube.
This document describes the regulatory submission for the Southmedic SMDIA-1000, an adaptor for intermittent delivery of aerosol medications from Metered Dose Inhalers (MDIs) when connected to ventilator or tracheal tubes. The submission aims to demonstrate substantial equivalence to predicate devices, not an AI device. As such, information regarding AI-specific criteria, such as "multi-reader multi-case (MRMC) comparative effectiveness study," "standalone (i.e., algorithm only without human-in-the-loop performance)," and sample sizes/ground truth for training/test sets, is not applicable or present in this document.
Here's the breakdown of the provided information relevant to acceptance criteria and performance:
1. Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria are primarily established through comparative performance testing against predicate devices and adherence to internal pass/fail criteria for various engineering tests.
| Acceptance Criteria (What was tested) | Reported Device Performance (Southmedic SMDIA-1000) |
|---|---|
| Indications for Use | The SMDIA-1000 MDI adaptor is intended to be used with an MDI for intermittent delivery of prescribed aerosol medications dispensed in MDIs. They are intended for use only when connected to ventilator tubing or tracheal tubes. (Identical to predicate K091111 - RTC-24V) |
| Technology / Design | Tee design with a port which is capped when not in use. (Identical to predicate K091111 - RTC-24V) |
| Materials (specifically those in gas or fluid pathway) | Materials in the gas or fluid pathway have been tested per ISO 10993 for Cytotoxicity, Irritation, and Sensitization. (Implies meeting safety standards) |
| Environment of Use | Expected clinical environment is critical care and / or long or short term ventilation, which can occur in hospitals, ICU, sub-acute centers, and home settings. (Substantially equivalent to predicate K091111 - RTC-24V) |
| Comparative Particle Characterization via Cascade Impactor | 3 samples with 3 different drugs MDI burst. Demonstrated that the performance of the proposed device and the predicate were equivalent. (Predicate: 3 drug types, 1 sample each, implying comparable results were expected and achieved) |
| Simulated Life Cycle Testing | Same sample testing for intra-sample variability. (Details not explicitly provided, but stated that the proposed device met its pass/fail criteria or was found substantially equivalent to the predicate). |
| Environmental Testing | Performed. (Details not explicitly provided, but stated that the proposed device met its pass/fail criteria or was found substantially equivalent to the predicate). |
| Operational Testing | Performed. (Details not explicitly provided, but stated that the proposed device met its pass/fail criteria or was found substantially equivalent to the predicate). |
| Drop Testing | Performed. (Details not explicitly provided, but stated that the proposed device met its pass/fail criteria or was found substantially equivalent to the predicate). |
| Canister Activation Testing | Performed. (Details not explicitly provided, but stated that the proposed device met its pass/fail criteria or was found substantially equivalent to the predicate). |
| Connection Trial Testing | Performed. (Details not explicitly provided, but stated that the proposed device met its pass/fail criteria or was found substantially equivalent to the predicate). |
| Inter- and Intra-sample Variability Testing | Performed. (Details not explicitly provided, but stated that the proposed device met its pass/fail criteria or was found substantially equivalent to the predicate). |
| Biocompatibility Testing (Cytotoxicity, Irritation, Sensitization) | Tested per ISO 10993. (Implies acceptable results were achieved for these safety parameters). |
| Other Design Features (e.g., Placed in breathing circuit) | Yes (Identical to predicate). |
| May attach to a tracheal tube | Yes (Identical to predicate). |
| Tee with standard 15 mm / 22 mm fittings | Yes (Identical to predicate). |
| Fitting for adaption to MDI | Yes (Identical to predicate). |
| Cap when not in use | Yes (Identical to predicate). |
| Single patient use, disposable | Yes (Identical to predicate). |
2. Sample Size Used for the Test Set and Data Provenance
- Particle Characterization via Cascade Impactor: 3 samples with 3 different drugs were tested for the proposed device (SMDIA-1000). The predicate used 3 drug types, 1 sample each.
- Other Performance Testing (Simulated life cycle, environmental, operational, drop, canister activation, connection trial, inter- and intra-sample variability): Not explicitly stated, but the document mentions "same sample testing for intra-sample variability" for simulated life cycle, implying repeated tests on the same units. The exact number of units or test cycles for these other tests is not provided.
- Data Provenance: The document does not specify the country of origin for the data or whether the studies were retrospective or prospective. Given the nature of a 510(k) submission for a physical medical device, these tests would typically be laboratory-based prospective engineering/performance studies rather than clinical studies with patient data.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of Experts
Not applicable. This is a submission for a physical medical device (an MDI adaptor), not an AI device or diagnostic tool that relies on expert interpretation for ground truth. The "ground truth" for this device's performance is objective measurements (e.g., particle size distribution, durability under stress, material biocompatibility) and comparison to established predicate device functionality, not expert consensus on diagnostic images or patient outcomes.
4. Adjudication Method for the Test Set
Not applicable. There is no mention of adjudication, as the tests are objective engineering and performance evaluations.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No, a MRMC comparative effectiveness study was not done. This type of study is relevant for diagnostic AI tools where human readers are interpreting images or data. This document pertains to a physical medical device where effectiveness is demonstrated through engineering performance and substantial equivalence to a predicate.
6. If a Standalone (i.e., Algorithm Only Without Human-in-the-Loop Performance) Was Done
Not applicable. This is not an algorithm or AI device.
7. The Type of Ground Truth Used
The "ground truth" used for evaluating the SMDIA-1000 appears to be:
- Objective Engineering Measurements: Particle size distribution (via Cascade Impactor), durability (simulated life cycle, drop tests), functional integrity (operational, canister activation, connection trials).
- Biocompatibility Testing: Adherence to ISO 10993 standards for cytotoxicity, irritation, and sensitization.
- Predicate Device Performance: The performance of the predicate devices (K991355 - RTC-22-D and K091111 - RTC-24V) served as the benchmark for demonstrating substantial equivalence. The predicate performance would also have been established through similar objective engineering and biocompatibility tests.
8. The Sample Size for the Training Set
Not applicable, as this is not an AI/machine learning device requiring a training set.
9. How the Ground Truth for the Training Set Was Established
Not applicable, as this is not an AI/machine learning device.
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K101953
JAN - 7 2011
| Southmedic, Inc.50 Alliance Blvd.Barrie, ONT | Tel – (705) 720-1902 x 342Fax – (705) 728-9537 |
|---|---|
| Official Contact: | Tish Anger - VP Quality & Regulatory Assurance |
| Proprietary or Trade Name: | SMDIA-1000 |
| Common/Usual Name: | Accessory to a nebulizer |
| Classification Name/Code: | CAF – nebulizerCFR 868.5630 |
| Device: | Southmedic SMDIA 1000 |
| Predicate Devices: | Instrumentation IndustriesK991355 - RTC-22-DK091111 - RTC-24V |
Device Description:
The Southmedic SMDIA-1000 is an adaptor which acts as an actuator for intermittent delivery of prescribed aerosol medications dispensed by meter dose inhalers (MDI). The SMDIA-1000 is connected to ventilator tubing and the MDI connected when drug delivery into the circuit is required. The SMDIA-1000 adaptor may also be connected to the endotracheal tube.
Indications for Use:
The SMDIA-1000 MDI adaptor is intended to be used with an MDI for intermittent delivery of prescribed aerosol medications dispensed in MDI's. They are intended for use only when connected to ventilator tubing or tracheal tubes.
Environment of Use:
The expected clinical environment is critical care and / or long or short term ventilation, which can occur in hospitals, ICU, sub-acute centers, and home settings.
Patient Population:
The SMDIA-1000 is intended to be prescribed for any patient who is ventilator dependent and to whom a MDI has been prescribed.
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| 510(k) SummaryPage 2 of 324-Dec-10 | PredicateK991355 - R |
|---|---|
| A-1000 |
| Summary of substantial equivalence | Southmedic SMDIA-1000 | Predicate - Instrumentation IndustriesK991355-RTC-22-D & K091111 - RTC-24V |
|---|---|---|
| Indications for Use | The SMDIA-1000 MDI adaptor is intended to be used with anMDI for intermittent delivery of prescribed aerosolmedications dispensed in MDIs. They are intended for useonly when connected to ventilator tubing or tracheal tubes. | The RTC series MDI adapters are actuators for intermittentdelivery of prescribed aerosol medications dispensed in meterdose inhalers. The RTC series MDI adapters are intended foruse only when connected to ventilator tubing or tracheal tubes. |
| Environment of use | The expected clinical environment is critical care and /or long or short term ventilation, which can occur inhospitals, ICU, sub-acute centers, and home settings. | The expected clinical environment is critical care and /or long or short term ventilation. |
| Patient Population | For any patient who is ventilator dependent and towhom a MDI has been prescribed. | For any patient who is ventilator dependent and to whoma MDI has been prescribed. |
| Prescriptive | Yes | Yes |
| Design | ||
| Placed in the breathing circuit | Yes | Yes |
| May attach to a tracheal tube | Yes | Yes |
| Tee with standard 15 mm / 22mm fittings | Yes | Yes |
| Fitting for adaption to MDI | Yes | Yes |
| Cap when not in use | Yes | Yes |
| Single patient use, disposable | Yes | Yes |
| Performance Testing | ||
| Particle characterization viaCascade Impactor | 3 samples with 3 different drugsMDI burst | 3 drug types1 sample each |
| Simulated life cycle and | Same sample testing for intra-sample variabilityEnvironment, operational, drop, canister activation and | Not listed |
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510(k) Summary Page 3 of 3 24-Dec-10
In summarizing the above comparative table the SMDIA-1000 is viewed as substantially equivalent to the predicate devices because:
Indications -
- Intended to be used with an MDI for intermittent delivery of prescribed aerosol medications . dispensed in MDIs. They are intended for use only when connected to ventilator tubing or tracheal tubes. These indications for use are identical to the predicate - K091111 - RTC-24V
Technology -
- The tee design with a port which is capped when not in used is identical to the predicate -. K091111 - RTC-24V
Materials -
- . The materials in the gas or fluid pathway have been tested per ISO 10993 for Cytotoxicity, Irritation, and Sensitization
Environment of Use -
- The expected clinical environment is critical care and / or long or short term ventilation, � which can occur in hospitals, ICU, sub-acute centers, and home settings in substantially equivalent to the predicate - K091111 -- RTC-24V
Comparative Performance -
- . Comparative Particle characterization testing via Cascade Impactor demonstrated that the performance of the proposed device and the predicate were equivalent
- Additional performance testing included Simulated life cycle, environmental, operational, . drop, canister activation and connection trial testing, inter- and intra-sample testing for variability. For which the proposed device met its pass / fail criteria or was found substantially equivalent to the predicate.
Differences -
There are no significant differences between the proposed device and the predicate device.
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Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo is a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is an abstract image of an eagle.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring. MID 20993-0002
Southmedic, Incorporated C/O Mr. Paul E. Dryden President Promedic, Incorporated 24301 Woodsage Drive Bonita Springs, Florida 34134
JAN - 7 2011
Re: K101953
Trade/Device Name: SMDIA-1000 Regulation Number: 21 CFR 868.5630 Regulation Name: Nebulizer Regulatory Class: II Product Code: CAF Dated: December 24, 2010 Received: December 27, 2010
Dear Mr. Dryden:
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 (for the indications for use stated in the enclosure) 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 (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. 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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
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. .
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Page 2- Mr. Dryden
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); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set 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.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/ CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely yours.
Nh for
Anthony D. Watson, B.S., M.S., M.B.A. Director Division of Anesthesiology, General Hospital, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
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JAN - 7 2011
Indications for Use Statement
Page 1 of 1
510(k) Number: K101953
Device Name: SMDIA - 1000
Indications for Use:
The SMDIA-1000 MDI adaptor is intended to be used with an MDI for intermittent delivery of prescribed aerosol medications dispensed in MDIs. It is intended for use only when connected to ventilator tubing or tracheal tubes.
The SMDIA-1000 MDI adaptor is single patient use, disposable.
Prescription Use XX (Part 21 CFR 801 Subpart D)
or
Over-the-counter use (21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
L. Schultheis
(Division Sign-Off) Division of Anesthesiology, General Hospital Infection Control, Dental Devices
510(k) Number: K101953
§ 868.5630 Nebulizer.
(a)
Identification. A nebulizer is a device intended to spray liquids in aerosol form into gases that are delivered directly to the patient for breathing. Heated, ultrasonic, gas, venturi, and refillable nebulizers are included in this generic type of device.(b)
Classification. Class II (performance standards).