(189 days)
The Dideco electa is indicated for intraoperative and postoperative recovery of blood, washing of the processed blood, and pre-operative sequestration (with indirect and direct patient connection). Typical clinical applications of autotransfusion include the following surgical specialties: Cardiovascular, Orthopedics, Thoracic, Transplant Surgery, Emergency (Trauma), Neurosurgery, Obstetrics and Gynecology, and Urology.
The Dideco electa consists of hardware and disposables. It is the next generation of the Dideco autotransfusion device family. The main elements of the hardware include the centrifuge, blood pump, automatic clamps, control and monitoring sensors, and a user interface (display panel and keyboard). The modifications to the disposables are the addition of a bar code to the addition of a tubing cassette to simplify disposables installation.
The provided submission for the Dideco electa autotransfusion device is a 510(k) summary, which focuses on demonstrating substantial equivalence to predicate devices rather than proving specific performance characteristics through detailed studies against acceptance criteria. Therefore, the document does not contain the specific information requested in the prompt regarding acceptance criteria, study design, sample sizes, ground truth establishment, or expert involvement in a multi-reader multi-case (MRMC) study.
The submission primarily relies on a side-by-side comparison of features and intended uses to establish equivalence.
Here's a breakdown of what the document does state in relation to your request, and where it falls short:
1. Table of Acceptance Criteria and Reported Device Performance:
The document does not present a table of quantitative acceptance criteria for the electa's performance (e.g., specific hematocrit recovery rates, wash efficiency, or red blood cell viability). Instead, it provides a "Side-by-Side Comparison of the electa and Predicate Devices" (Table I-1 in section 6 and continued in section 7). This table compares various characteristics such as:
- Intended Use: Identical to predicate devices (Pre-operative Sequestration, Intraoperative/Postoperative recovery, PPP, PRP, etc.)
- Typical Clinical Applications: Mostly identical, with some predicates "not specified" for certain surgical specialties where the electa is indicated.
- Operating Modes: All devices (electa and predicates) have Automatic, Semi-automatic, and Manual modes, and are pre-programmed and reprogrammable.
- Processing Phases: All devices perform Prime (Fill), Wash, Empty, Return, and Concentrate.
- Disposables: electa uses 55, 125, 175, and 225 mL bowl sizes, similar to Dideco ABMS, but different from COBE BRAT II (135, 250 mL). All are sterile, single-use, and disposable.
- Features: The electa has additional features compared to its direct predicate (Dideco ABMS) and some features not present in COBE BRAT II (e.g., Cardiotomy weighing system, Hematocrit sensor, Free hemoglobin sensor, Pressure occlusion sensor, Blood loss sensor, Bar code reader, Level sensor, Smart card, Continuous operation capability). It also shares features like Air bubble sensor, Buffy coat sensor, and Vacuum pump with some predicates.
- Operating Parameters:
- Centrifuge speeds (RPM): electa (1500-5600) is identical to Dideco ABMS, and wider than COBE BRAT II (4400).
- Pump speeds (mL/min): electa (25-1000) is identical to Dideco ABMS, and within the range of COBE BRAT II (25-1300).
- Blood source for PPP/PRP: All devices can use Patient or bag.
- PPP collection parameters: Similar to Dideco ABMS and COBE BRAT II (50 mL/min, 5600 RPM or 4400 RPM for COBE).
- PRP collection parameters: Similar to Dideco ABMS and COBE BRAT II (50 mL/min, 2400 RPM or 4400 RPM for COBE).
- Vacuum level: electa (0 to 300 mmHg) is comparable to COBE BRAT II (50-300 mmHg).
The document states, "Dideco S.p.A. believes that the electa is substantially equivalent to the Dideco ABMS, COBE Brat II, and other currently marketed automated autotransfusion devices, that any differences are minor, and raise no new issues of safety and effectiveness."
2. Sample size used for the test set and the data provenance:
- The document mentions "performance testing that demonstrate compliance with performance specifications" (Section 7). However, it does not provide any specific sample sizes for this testing, nor does it detail the nature of the "test set" (e.g., patient samples, simulated blood, etc.).
- There is no information on data provenance (e.g., country of origin, retrospective or prospective).
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- This information is not provided in the document. As performance data itself is not presented in detail, the method of establishing ground truth for such data (if any was used for comparison) is absent.
4. Adjudication method for the test set:
- This information is not provided in the document.
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 an autotransfusion device, not an AI diagnostic imaging or analysis tool. Therefore, an MRMC study and the concept of "human readers improving with AI assistance" are not applicable to this type of device and are not mentioned in the submission.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- As above, this is an autotransfusion device, not an AI algorithm. The concept of "standalone algorithm performance" is not applicable and not mentioned. The device's performance would be evaluated in the context of its function in processing blood, typically by comparing output parameters (like hematocrit) to established standards.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- The document does not specify the type of ground truth used for any performance testing. For an autotransfusion device, ground truth would typically refer to gold standard measurements of blood components (e.g., laboratory analysis of hematocrit, red blood cell count, hemolysis) of the processed blood, and possibly clinical outcomes related to re-infusion. This level of detail is absent.
8. The sample size for the training set:
- As this is not an AI/ML device, the concept of a "training set" in that context is not applicable. The device's operation is based on established engineering principles and pre-programmed parameters, not a learned model from a training set.
9. How the ground truth for the training set was established:
- Again, not applicable as it's not an AI/ML device with a training set.
In summary:
The provided 510(k) summary for the Dideco electa focuses on demonstrating substantial equivalence to predicate devices based on design characteristics and intended use, rather than presenting detailed performance study results against specific acceptance criteria. Consequently, most of the specific questions about study design, sample sizes, ground truth, and expert involvement for a performance study are not addressed in this document. The "testing" section (Section 7) is very brief, stating only that electrical testing, electromagnetic compatibility testing, and performance testing were supplied to demonstrate compliance with performance specifications, without providing specifics of those tests or their results.
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510(k) Summary Dideco S.p.A. electa (per 21 CFR 807.92)
1. SPONSOR/APPLICANT
| Contact: | Mr. Luigi Vecchi |
|---|---|
| Dideco, S.p.A. | |
| via Statale 12 Nord, 86 | |
| I-41037 Mirandola (MO) | |
| Italy | |
| Telephone: | 011 39 535 298 11 |
| Facsimile: | 011 39 535 252 29 |
2. DEVICE NAME
| Proprietary Name: | electa |
|---|---|
| Common/Usual Name: | Autotransfusion Device |
| Classification Names: | Autotransfusion Apparatus |
3. PREDICATE DEVICES
- Cobe Brat II K991986 �
4. INTENDED USE
The Dideco electa is indicated for intraoperative and postoperative recovery of blood, washing of the processed blood, and pre-operative sequestration (with indirect and direct patient connection). Typical clinical applications of autotransfusion include the following surgical specialties: Cardiovascular, Orthopedics, Thoracic, Transplant Surgery, Emergency (Trauma), Neurosurgery, Obstetrics and Gynecology, and Urology.
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5. DEVICE DESCRIPTION
The Dideco electa consists of hardware and disposables. It is the next generation of the Dideco autotransfusion device family. The main elements of the hardware include the centrifuge, blood pump, automatic clamps, control and monitoring sensors, and a user interface (display panel and keyboard). The modifications to the disposables are the addition of a bar code to the addition of a tubing cassette to simplify disposables installation.
BASIS FOR DETERMINATION OF EQUIVALENCE 6.
Dideco makes the claim of substantial equivalence to cited predicates based on intended use, Indications for Use, technological characteristics, and operational characteristics. A side-by-side comparison of the Dideco electa with cited predicates is provided in Table I-1 below.
| Characteristic | electa | Dideco ABMSK982650 | COBE BRAT IIwith CRIT-LINEK991986 |
|---|---|---|---|
| Intended Use | |||
| Pre-operative Sequestration | Yes | Yes | Yes |
| Intraoperative recovery of shed blood | Yes | Yes | Yes |
| Postoperative collection of shed blood | Yes | Yes | Yes |
| PPP | Yes | Yes | Yes |
| PRP | Yes | Yes | Yes |
| Bag processing for PRP | Yes | Yes | Yes |
| Direct Draw processing for PRP | Yes | Yes | Yes |
| Typical Clinical Applications | |||
| Cardiovascular Surgery | Yes | Yes | Yes |
| Orthopedic Surgery | Yes | Yes | Not specified |
| Thoracic Surgery | Yes | Yes | Not specified |
| Transplant Surgery | Yes | Yes | Not specified |
| Emergency (Trauma) | Yes | Yes | Yes |
| Neurosurgery | Yes | Yes | Not specified |
| Obstetrics and Gynecologic Surgery | Yes | Yes | Not specified |
| Urologic Surgery | Yes | Yes | Not specified |
| Table I-1. Side-by-Side Comparison of the electa and Predicate Devices | ||||
|---|---|---|---|---|
| Dideco ABMS | COBE BRAT IIwith CRIT-LINE | |||
| Characteristic | electa | K982650 | K991986 | |
| Operating Modes | ||||
| Automatic | Yes | Yes | Yes | |
| Semi-automatic | Yes | Yes | Yes | |
| Manual | Yes | Yes | Yes | |
| Pre-programmed and reprogrammable | Yes | Yes | Yes | |
| Processing Phases | ||||
| Prime (Fill) | Yes | Yes | Yes | |
| Wash | Yes | Yes | Yes | |
| Empty | Yes | Yes | Yes | |
| Return | Yes | Yes | Yes | |
| Concentrate | Yes | Yes | Yes | |
| Disposables | ||||
| Bowl sizes | 55, 125, 175,and 225 | 55, 125, 175, and225 | 135, 250 | |
| Sterile, single use, and disposable | X | X | X | |
| Features | ||||
| Cardiotomy weighing system | Yes | No | No | |
| Hematocrit sensor | Yes | No | Yes | |
| Air bubble sensor | Yes | Yes | Yes | |
| Free hemoglobin sensor | Yes | No | No | |
| Pressure occlusion sensor | Yes | No | No | |
| Blood loss sensor | Yes | No | No | |
| Buffy coat sensor | Yes | Yes | Yes | |
| Bar code reader | Yes | No | No | |
| Level sensor | Yes | No | No | |
| Vacuum pump | Yes | No | Yes | |
| Smart card | Yes | No | RS232 Option | |
| Printer | Yes | No | Yes | |
| Continuous operation capability | Yes | No | Up to three cycles | |
| Better quality wash option | Yes | Yes | No | |
| Emergency wash option | Yes | Yes | No | |
| Characteristic | electa | Dideco ABMSK982650 | COBE BRAT IIwith CRIT-LINEK991986 | |
| Operating Parameters | ||||
| Centrifuge speeds (RPM) | 1500-5600 | 1500-5600 | 4400 | |
| Pump speeds (mL/min) | 25-1000 | 25-1000 | 25-1300 | |
| Blood source for PPP/PRP | Patient or bag | Patient or bag | Patient or bag | |
| PPP collection parameters | 50 mL/min5600 RPM | 50 mL/min5600 RPM | 50 mL4400 RPM | |
| PRP collection parameters | 50 mL/min2400 RPM | 50 mL/min2400 RPM | 50 mL4400 RPM | |
| Vacuum level | 0 to 300mmHg | NA | 50 – 300 mmHg |
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Table I-1. Side-by-Side Comparison of the electa and Predicate Devices (Continued)
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Table I-1. Side-by-Side Comparison of the electa and Predicate Devices (Continued)
Dideco S.p.A. believes that the electa is substantially equivalent to the Dideco ABMS, COBE Brat II, and other currently marketed automated autotransfusion devices, that any differences are minor, and raise no new issues of safety and effectiveness.
7. TESTING
Testing supplied in the 510(k) premarket notification for the Dideco electa includes electrical testing, electromagnetic compatibility testing, and performance testing that demonstrate compliance with performance specifications.
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Public Health Service
Image /page/4/Picture/2 description: The image shows the logo for the Department of Health & Human Services - USA. The logo is a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is an abstract symbol that resembles a stylized caduceus, with three parallel lines that curve and merge to form a shape suggestive of a human profile.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
5 2002 SEP
Dideco S.p.A. electa Ms. Rosina Robinson c/o Medical Device Consultants, Inc. 49 Plain Street North Attleboro, MA 02760
Re: K020647
Dideco electa Regulation Number: 868.5830 Regulation Name: Autotransfusion Apparatus Regulatory Class: Class II (two) Product Code: CAC Dated: June 24, 2002 Received: June 25, 2002
Dear Ms. Robinson:
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.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such 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 - Ms. Rosina Robinson
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 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.
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 vour device on our labeling regulation (21 CFR Part 801 and additionally 21 CFR Part 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4646. 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" (21CFR 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,
Bram D. Zuckerman, M.D.
ickerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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510(k) Number (if known):
Device Name: Dideco electa
Indications for Use:
The Dideco electais indicated for intraoperative recovery of blood, washing of blood collected in the post-operative period, and pre-operative sequestration ( with indirect and direct patient connection). Typical clinical applications of autotransfusion include the following surgical specialties:
- Cardiovascular
- Orthopedics
-
Thoracic
- Transplant Surgery
- Emergency (Trauma)
- Neurosurgery
-
Obstetrics and gynecology
- Urology
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NECESSARY)
Concurrence of CDRH, Office of Device Evaluation (ODE)
OR
Division of Carliovascular & Respiratory Devices
510(k) Number K020647
Prescription Use
(Per 21 CFR 801.109)
:
Over-The-Counter Use __
§ 868.5830 Autotransfusion apparatus.
(a)
Identification. An autotransfusion apparatus is a device used to collect and reinfuse the blood lost by a patient due to surgery or trauma.(b)
Classification. Class II (performance standards).