K Number
K170150

Validate with FDA (Live)

Manufacturer
Date Cleared
2017-10-20

(276 days)

Product Code
Regulation Number
876.5880
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Servator H SALF solution is indicated for perfusion and flushing donor kidneys, liver, pancreas, and heart prior to removal from the donor or immediately after removal from the donor. The solution is left in the organ vasculature during hypothermic storage and transportation (not for continuous perfusion) to the recipient.

Device Description

The Servator H SALF solution is intended for perfusion and flushing donor kidneys, liver, pancreas, and heart prior to removal form the donor or immediately after removal from the donor. The solutions is left in the organ vasculature during hypotermic storage and transportation (not for continuous perfusion) to the recipient. Servator H SALF solution is based on the principle of inactivating organ function by withdrawal of extracellular sodium and calcium, together with intensive duffering of the extrcellular space by means of histidine/histidine HCI, so as to prolong the period for which organs will tolerate interruption of blood and oxygen supply. Only a small portion of the osmolality of the Servator H SALF solution is due to the sodium and potassium. The composition of the Servator H SALF is similar to that of extracellular fluid. All of the components of the Servator H SALF solution occur naturally in the body.

AI/ML Overview

The provided document is a 510(k) summary for the Servator H SALF Solution, which is an organ perfusion and preservation solution. It primarily focuses on demonstrating substantial equivalence to a predicate device (Custodiol HTK) rather than presenting a standalone study with specific acceptance criteria and detailed performance metrics of the device as an AI or diagnostic tool.

Therefore, many of the requested details about acceptance criteria, study design, ground truth establishment, sample sizes for training/test sets, expert involvement, and MRMC studies are not applicable or not explicitly detailed in this type of regulatory submission.

However, based on the non-clinical performance data section, we can infer some "acceptance criteria" through the tests conducted.

Here's a breakdown of the information that can be extracted or inferred:

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

Since this is a substantial equivalence claim for a physical solution and not an AI/diagnostic device, acceptance criteria are generally related to safety, sterility, biocompatibility, and chemical composition matching the predicate.

Acceptance Criteria CategorySpecific Test/CharacteristicReported Device Performance (Servator H SALF)Conclusion against Predicate
BiocompatibilityCytotoxicityPassed Biocompatibility Test StandardsEquivalent to predicate (implied)
IrritationPassed Biocompatibility Test StandardsEquivalent to predicate (implied)
System ToxicityPassed Biocompatibility Test StandardsEquivalent to predicate (implied)
HaemocompatibilityPassed Biocompatibility Test StandardsEquivalent to predicate (implied)
Sterilization & Shelf LifeValidation of SterilityPassed all test standardsSame as predicate (Steam Sterilization)
Validation Method LAL TurbidimetricPassed all test standardsSame as predicate (implied)
StabilityPassed all test standardsShelf life of 12 months (same as predicate)
Physical PropertiespH (at 25°C)7.02 - 7.20Same as predicate
pH (at 4°C)7.40 - 7.45Same as predicate
Osmolality310 mOsm/KgSame as predicate
Chemical Analysis(Between subject and predicate device)Proved to be substantially equivalentSubstantially Equivalent
Safety and EffectivenessNew Questions of Safety and EffectivenessDoes not raise any new questionsEquivalent to predicate

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

This information is not provided in the document. The document refers to "performance data" and "test standards" but does not detail sample sizes for any specific tests or the provenance of the data beyond the manufacturer being S.A.L.F. S.p.A. (Italy).

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)

This information is not applicable as the device is a chemical solution for organ preservation, not a diagnostic device requiring expert interpretation for ground truth.

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

This information is not applicable for the same reason as above.

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 information is not applicable as the device is not an AI-assisted diagnostic tool or an imaging device.

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

This information is not applicable as the device is a chemical solution, not an algorithm.

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

For this type of device (organ preservation solution), "ground truth" is established through:

  • Chemical composition analysis: Comparing the exact chemical constituents and their concentrations to the predicate device.
  • Biocompatibility testing: Standardized in-vitro and in-vivo tests to assess toxicity, irritation, etc.
  • Sterility testing: Confirmation of absence of microbial contamination.
  • Stability testing: Confirmation that the solution maintains its properties over its shelf life.

The document states that a "direct comparison between the subject and predicate device" was completed for performance testing including chemical analysis, and that "performance reports are included in the submission." This implies that the ground truth for chemical and physical properties was the established characteristics of the predicate device.

8. The sample size for the training set

This information is not applicable as the device is a chemical solution, not an AI/ML algorithm that requires a training set.

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

This information is not applicable for the same reason as above.

{0}------------------------------------------------

Image /page/0/Picture/0 description: The image shows the logos of the Department of Health & Human Services and the Food and Drug Administration (FDA). The Department of Health & Human Services logo is on the left, and the FDA logo is on the right. The FDA logo includes the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.

October 20, 2017

S.A.L.F. S.p.A. % Joyce St. Germain Regulatory Department Manager 510k FDA Consulting Denterprise International, Inc. 100 East Granada Blvd., Suite 219 Ormond Beach, Florida 32176

Re: K170150

Trade/Device Name: Servator H SALF Solution Regulation Number: 21 CFR 876.5880 Regulation Name: Isolated Kidney Perfusion and Transport System and Accessories Regulatory Class: Class II Product Code: KDL, MSB Dated: September 7, 2017 Received: September 19, 2017

Dear Joyce St. Germain:

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.

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 of medical device-related adverse events) (21 CFR 803); good

{1}------------------------------------------------

manufacturing practice requirements as set forth in the quality systems (OS) 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 contact the Division of Industry and Consumer Education (DICE) at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevicesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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 Industry and Consumer Education (DICE) at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

for

Sincerely, Joyce M. Whang -S

Benjamin R. Fisher, Ph.D. Director Division of Reproductive, Gastro-Renal, and Urological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

{2}------------------------------------------------

Indications for Use

510(k) Number (if known) K170150

Device Name Servator H SALF Solution

Indications for Use (Describe)

The Servator H SALF solution is indicated for perfusion and flushing donor kidneys, liver, pancreas, and heart prior to removal from the donor or immediately after removal from the donor. The solution is left in the organ vasculature during hypothermic storage and transportation (not for continuous perfusion) to the recipient.

Type of Use (Select one or both, as applicable)
[X] Prescription Use (Part 21 CFR 801 Subpart D)[ ] Over-The-Counter Use (21 CFR 801 Subpart C)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

{3}------------------------------------------------

Image /page/3/Picture/1 description: The image shows a stylized black and white drawing of a bird with a large wing. The wing is prominently displayed, taking up a significant portion of the image. The bird's head is small and simple, with a curved beak, and the body is suggested by a curved line that connects to the wing.

510k FDA Consulting

Medical Device Clearance

100 East Granada Blvd., Suite 219

Ormond Beach, FL 32176

386-506-8711

510(k) Summary - K170150

Submitter/Applicant

S.A.L.F. S.p.A Via Marconi, 2, Cenate Sotto, BG, Italy Phone: +39-035-940097 Contact: Dr. Carmelo Gagliano (Quality Manager) carmelo.gagliano@salfspa.it

Date Prepared: October 17, 2017

Preparer/Consultant

Denterprise International, Inc. 100 East Granada Blvd., Suite 219 Ormond Beach, FL 32176

Phone: 386-506-8711 Fax: 855-235-7902 Contact: Joyce St. Germain, Regulatory Dept. Mgr (Joyce@510kfda.com) Secondary Contact: Claude Berthoin, President (Claude@denterpriseintl.com)

Device Classification

Trade/Model Names:Servator H SALF Solution
Common Name:Organ perfusion and preservation solution
Classification Name:Isolated kidney perfusion and transport system and accessories
Regulation Number:21 CFR 876.5880
Product Code:KDL, MSB
Regulatory Class:2
Medical Specialty:Gastroenterology/Urology Panel

{4}------------------------------------------------

Predicate Device

The subject device claims equivalence to the following legally marketed predicate:

510(k) Number:K043461
Date ClearedFebruary 28, 2005
Trade Name:Custodiol HTK
Common Name:Organ perfusion and preservation solution
Classification Name:Isolated kidney perfusion and transport system and accessories
Regulation Number:21 CFR 876.5880
Product Code:KDL, MSB
Regulatory Class:2
Medical Specialty:Gastroenterology/Urology Panel

Indications for Use

The Servator H SALF solution is indicated for perfusion and flushing donor kidneys, liver, pancreas, and heart prior to removal from the donor or immediately after removal from the donor. The solution is left in the organ vasculature during hypothermic storage and transportation (not for continuous perfusion) to the recipient.

Intended Use

The Servator H SALF Solution is intended for perfusion and flushing donor kidneys, liver, pancreas, and heart prior to removal from the donor or immediately after removal from the donor. The solution is for single use, is sterile (by steam sterilization) and nonpyrogenic.

Device Description

The Servator H SALF solution is intended for perfusion and flushing donor kidneys, liver, pancreas, and heart prior to removal form the donor or immediately after removal from the donor. The solutions is left in the organ vasculature during hypotermic storage and transportation (not for continuous perfusion) to the recipient. Servator H SALF solution is based on the principle of inactivating organ function by withdrawal of extracellular sodium and calcium, together with intensive duffering of the extrcellular space by means of histidine/histidine HCI, so as to prolong the period for which organs will tolerate interruption of blood and oxygen supply. Only a small portion of the osmolality of the Servator H SALF solution is due to the sodium and potassium. The composition of the Servator H SALF is similar to that of extracellular fluid. All of the components of the Servator H SALF solution occur naturally in the body.

{5}------------------------------------------------

The Servator H SALF solution is relatively low in postassium concentrations so that residual solution in the transplanted organ poses no danger to the recipient. This is particularyly important in organs that take up relatively large amounts of the perfusate, which may find its way into the recipient's circulation.

Comparison of Technological Characteristics with Predicate

The indications for use of the subject and predicate devices are identical and the technologies are substantially equivalent.

The following table compares technological and other characteristics of the subject and predicate device.

Table of Comparison

Table 12.1 -- Technological Comparison

Subject DevicePredicate DeviceComparison
DeviceServator H SALFCustodiol HTKNA
510k NumberK170150K043461
ManufacturerS.A.L.F. S.p.A.(Italy)Dr. Franz KohlerChemi GmbH(Germany)NA
Classification &Product Code876.5880;KDL, MSB876.5880;KDL,MSBSame
ClassificationNameIsolated kidneyperfusion andtransport systemand accessoriesIsolated kidneyperfusion andtransport systemand accessoriesSame
Device DescriptionSet, Perfusion,Kidney, DisposableSet, Perfusion,Kidney, DisposableSame
Common NameOrgan perfusion andpreservation solutionOrgan perfusion andpreservation solutionSame
Indications for UseThe Servator HSALF solution isindicated forperfusion andflushing donorkidneys, liver,pancreas, and heartprior to removalThe Custodiol HTKsolution is indicatedfor perfusion andflushing donorkidneys, liver,pancreas, and heartprior to removalfrom the donor orSame
from the donor orimmediately afterremoval from thedonor. The solutionis left in the organvasculature duringhypothermic storageand transportation(not for continuousperfusion) to therecipient.immediately afterremoval from thedonor. The solutionis left in the organvasculature duringhypothermic storageand transportation(not for continuousperfusion) to therecipient.
Intended for UseThe Servator HSALF Solution isintended forperfusion andflushing donorkidneys, liver,pancreas, and heartprior to removalfrom the donor orimmediately afterremoval from thedonor. The solutionis for single use, issterile (by steamsterilization) andnon-pyrogenic.The Custodiol HTKSolution is intendedfor perfusion andflushing donorkidneys, liver,pancreas, and heartprior to removalfrom the donor orimmediately afterremoval from thedonor.Same
Meets UNOS PolicyYESYESSame
Container/BagPVC free bagsPVC free bagsEquivalent
ProtectingOverwrap BagYESYESSame
Single Use OnlyYESYESSame
Bag Connections1 flip off, 1 needlepoint1 flip off, 1 needlepointSame
Used for OrganTransplants ofUsed for kidneys,liver, heart andpancreasUsed for kidneys,liver, heart andpancreasSame
Product StateLiquid - SolutionLiquid - SolutionSame
Model NumbersServator H SALF,1000ml /SERVH10DMAServator H SALF,2000ml /SERVH20DMBag, 1000 ml /25767-735-45Bag, 2000ml /25767-735-49Bag, 5000ml /25767-735-46Different ModelNumbers - due todifferentmanufactures
ConfigurationsBox containing 10bags of 1000mlPVC free.Box containing 5bags of 2000mlPVC free.Bags 1000 ml,2000 ml and5000 ml.EquivalentPredicate devicedifferentpackagingavailable
SterilizationMethodSteamSteamSame
Physical PropertiespH: 7.02 - 7.20 at25° C;7.40 - 7.45 at 4° COsmolality: 310mOsm/KgpH: 7.02 - 7.20 at25° C;7.40 - 7.45 at 4° COsmolality: 310mOsm/KgSame
ManufactureStandards ofConformityISO 9001:2008ISO 13485:2003GMP CertificationUnknownSubject meetscurrent standards
Shelf Life12 Months12 MonthsSame
Device Standards ofConformitySubject devicepassed accordingto ISO standardsUnknownSubject devicepassed accordingto ISO standards

{6}------------------------------------------------

{7}------------------------------------------------

The above comparison shows the subject and predicate devices are substantially equivalent in technology characteristics. The differences are highlighted and those differences do not make the subject device any less safe and effective as the predicate device. The differences are due to different manufacturers with different model numbers and the predicate has additional sizes of bags and a bottle package.

{8}------------------------------------------------

Non-Clinical Performance Data

The following performance data is provided in support of the substantial equivalence determination. All tests performed are included in this submission.

Biocompatibility testing was required for this device. The Cytotoxicity, Irritation, System Toxicity and Haemocompatibility tests were all performed. The subject device passed all biocompatibility test standards.

Sterilization and Shelf Life testing and evaluation was required for the subject device. The Validation of Sterility, Validation Method LAL Turbidimetric and Stability were all performed and the results passed the device on all test standards performed. Steam sterilization and storage conditions are the same. Shelf life for the subject and predicate device are 12 months.

Electrical Safety and EMC testing was not applicable for this device.

Performance Testing including but not limited to chemical analysis was completed as a direct comparison between the subject and predicate device. The subject device proved to be substantially equivalent to the predicate. The comparison chart is shown in this summary and performance reports are included in the submission.

Conclusion

The subject and predicate devices have the same intended use and are substantially equivalent in technological characteristics and performance (since they have, in fact, the same composition). The Servator H SALF does not raise any questions regarding new questions of safety and effectiveness and is equivalent to the predicate device. The nonclinical data supports and demonstrates the safety of the device.

The conclusion is that Servator H SALF warrants a finding of substantial equivalence to the legally marketed original Custodiol HTK Solution, and therefore, should have clearance for premarket activities in the United States.

§ 876.5880 Isolated kidney perfusion and transport system and accessories.

(a)
Identification. An isolated kidney perfusion and transport system and accessories is a device that is used to support a donated or a cadaver kidney and to maintain the organ in a near-normal physiologic state until it is transplanted into a recipient patient. This generic type of device may include tubing, catheters, connectors, an ice storage or freezing container with or without bag or preservatives, pulsatile or nonpulsatile hypothermic isolated organ perfusion apparatus with or without oxygenator, and disposable perfusion set.(b)
Classification. Class II (performance standards).