(30 days)
To replace: Cracked or broken female luer lock connectors or repair damaged extension where there is a minimum of 4.5 cm of viable extension tubing on the following catheters: Soft-Cell* Long-Term Dual Lumen Catheter, Opti-Flow* Long-Term Dual Lumen Catheter, Slim-Cath* Short-Term Dual Lumen Catheter, Vaccess* Short-Term Single Lumen Catheter, HemoStar* Long-Term Dual Lumen Catheter, Flexxicon* Short-Term Dual Lumen Catheter, Niagara* Short-Term Dual Lumen Catheter, Flexxicon* II Short-Term Dual Lumen Catheter, HemoGlide* Long-Term Dual Lumen Catheter, and HemoSplit* Long-Term Hemodialysis Catheter.
The Catheter Repair Kit with Replacement Connector is exactly the same as the predicate device.
Here's an analysis of the provided text regarding the Catheter Repair Kit with Replacement Connector:
The provided document is a 510(k) summary for a medical device called the "Catheter Repair Kit with Replacement Connector." This type of submission aims to demonstrate that a new device is substantially equivalent to a previously cleared device (predicate device), rather than proving stand-alone safety and effectiveness through extensive clinical trials. Therefore, the information typically found in studies designed to "prove the device meets acceptance criteria" in the way one might expect for novel, high-risk devices or AI algorithms is not present here.
Instead, the "study" demonstrating that the device meets acceptance criteria primarily consists of non-clinical performance testing to show equivalence to the predicate device, especially in light of a minor material formulation change.
Here's a breakdown of the requested information based on the provided text:
-
Table of Acceptance Criteria and Reported Device Performance:
The document does not explicitly present a table of "acceptance criteria" and "reported device performance" in the typical format of sensitivities, specificities, or other statistical measures for a decision-making algorithm. Instead, the acceptance criteria implicitly relate to the device functioning in a manner equivalent to the predicate device after a material change. The "performance" is demonstrated through non-clinical testing.
Acceptance Criterion (Implicit) Reported Device Performance (Summary) Safety and Effectiveness not adversely affected by minor material change. FMEA conducted, no new safety/effectiveness questions raised. Performance data demonstrate equivalence. Maintain intended use and functional characteristics of predicate device. Testing based on FDA guidance and standards to evaluate performance. Performance data demonstrate equivalence. Compatibility with listed catheters for repair (cracked/broken luer lock, damaged extension). Assumed to be met through equivalence to predicate device and non-clinical testing. -
Sample Size used for the test set and the data provenance:
- Sample Size for Test Set: Not specified. The document refers to "testing" and "performance data" without detailing the number of units or test iterations.
- Data Provenance: Not applicable in the context of human data. The testing would be laboratory-based (in-vitro) on device components.
-
Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- This is not applicable as the study described is for a physical medical device (catheter repair kit) and not an AI/diagnostic algorithm where expert ground truth is typically established. The "ground truth" would be the engineering specifications and intended function of the device.
-
Adjudication method for the test set (e.g., 2+1, 3+1, none):
- Not applicable as this is not a study involving human readers or diagnostic interpretation. The "adjudication" of test results would be based on engineering and quality control standards.
-
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:
- No. This is not an AI device.
-
If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
- No. This is not an AI device.
-
The type of ground truth used (expert consensus, pathology, outcomes data, etc):
- For this type of device, the "ground truth" for performance testing (e.g., tensile strength, leak resistance, biocompatibility) would be defined by engineering specifications, recognized industry standards (e.g., ISO), and FDA guidance documents. The device must meet these predetermined physical and functional criteria.
-
The sample size for the training set:
- Not applicable. This is not a machine learning or AI device that requires a training set.
-
How the ground truth for the training set was established:
- Not applicable. As above, there is no training set for this type of device.
Summary of the "Study" from the document:
The "study" referenced in the 510(k) process for the Catheter Repair Kit with Replacement Connector is a non-clinical performance testing program. This program was undertaken because of a minor material formulation change in the new device compared to its predicate.
- Objective: To determine if the material change affects the safety or effectiveness of the device and to demonstrate substantial equivalence to the predicate device (K030442).
- Methodology:
- A Failure Modes and Effects Analysis (FMEA) was conducted in accordance with ISO 14971:2000 to identify potential risks.
- Performance testing was conducted based on FDA guidance documents and standards.
- Results/Conclusion:
- The FMEA did not raise any new types of safety or effectiveness questions.
- The performance data generated from the testing demonstrated equivalence to the predicate device.
This approach is standard for 510(k) submissions where changes to an existing device are minor and do not introduce new scientific or technological challenges. The "acceptance criteria" are intrinsically linked to demonstrating that the new device performs identically (or equivalently) to the already cleared predicate device, ensuring no new risks or diminished effectiveness due to the material change.
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Section 6
Catheter Repair Kit with Replacement Connector
510(k) Summary
DEC 1 5 2006
21 CFR 807.92
1. Submitter Information:
| Submitter Name: | Bard Access Systems, Inc.[Subsidiary of C. R. Bard, Inc.] |
|---|---|
| Address: | 5425 W. Amelia Earhart DriveSalt Lake City, UT 84116 |
| Telephone Number: | (801) 595-0700, Ext. 4903 |
| Fax Number: | (801) 595 5425 |
| Contact Person: | Peggy Keiffer |
| Date of Preparation: | November, 2006 |
2. Device Name:
| Device Name: | Catheter Repair Kit with Replacement Connector |
|---|---|
| Trade Name: | Catheter Repair Kit |
| Common/Usual Name: | Catheter Repair Kit |
| Classification Name: | 78 NFK Blood Access Device and Accessories |
| 21 CFR 876.5540, Class II | |
| Classification Panel: | Gastroenterology and Renal |
3. Predicate Device Name:
| Device Name: | Catheter Repair Kit with Replacement Connector |
|---|---|
| Trade Name: | Catheter Repair Kit |
| Common/Usual Name: | Catheter Repair Kit |
| Classification Name: | 78 NFK Blood Access Device and Accessories21 CFR 876.5540, Class II |
| Classification Panel: | Gastroenterology and Renal |
4. Device Description
The Catheter Repair Kit with Replacement Connector is exactly the same as the predicate device.
ട്. Intended Use
To replace: Cracked or broken female luer lock connectors or repair damaged extension where there is a minimum of 4.5 cm of viable extension tubing on the following catheters: Soft-Cell* Long-Term Dual Lumen Catheter, Opti-Flow* Long-Term Dual Lumen Catheter, Slim-Cath* Short-Term Dual Lumen Catheter, Vaccess* Short-Term Single Lumen Catheter, HemoStar* Long-Term Dual Lumen Catheter, Flexxicon* Short-Term Dual Lumen Catheter, Niagara* Short-Term Dual Lumen Catheter, Flexxicon* II Short-Term Dual Lumen Catheter, HemoGlide* Long-Term Dual Lumen Catheter, and HemoSplit* Long-Term Hemodialysis Catheter.
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6 Questions in the decision path and their answers follow:
Does the new device have the same indication statement?
Yes.
Does the new device have the same intended use and may be "substantially equivalent" ?
Yes.
Does the new device have the same technological characteristics, e.g. design, material, etc.?
Not in all regards. The material used in the Repair Kit has a minor material formulation change. The design is the same and has the same fundamental scientific technology.
Could the new characteristics affect safety or effectiveness?
Yes. The new characteristics could affect safety and effectiveness of the device.
Do the new characteristics raise new types of safety and effectiveness questions?
No. A failure modes and effects analysis (FMEA) of the subject device was conducted in accordance with an internal protocol based on ISO 14971:2000 Medical Devices – Application of Risk Management to Medical Devices, to assure that risks posed by the modified device are acceptable. The analysis did not raise any new types of safety or effectiveness questions.
Do accepted scientific methods exist for assessing effects of the new characteristics?
Yes. Testing was based on FDA guidance document and standards to evaluate the devices' performance.
Are Performance Data Available to assure effects of new Characteristics?
Y es
Do Performance Data Demonstrate Equivalence?
Yes
Conclusion:
Based on FDA's decision tree, the Catheter Repair Kit with Replacement Connector is substantially equivalent to the predicate device, Catheter Repair Kit with Replacement Connector, K030442, concurrence date July 21, 2003.
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Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo consists of a stylized graphic of three human profiles facing right, stacked on top of each other, with flowing lines beneath them. The graphic is encircled by the text "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" in a circular arrangement.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
DEC 1 5 2006
Ms. Peggy Keiffer Sr. Regulatory Affairs Manager Bard Access Systems, Inc. C. R. Bard. Inc. 5425 W. Amelia Earhart Drive SALT LAKE CITY UT 84116
Re: K063446
Trade/Device Name: Catheter Repair Kit with Replacement Connector Regulation Number: 21 CFR §876.5540 Regulation Name: Blood access device and accessories Regulatory Class: II Product Code: NFK Dated: November 14, 2006 Received: November 15, 2006
Dear Ms. Keiffer:
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). You may, therefore, market the device, subject to the general controls provisions of the Act. However, you are responsible to determine that the medical devices you use as components in the kit have either been determined as substantially equivalent under the premarket notification process (Section 510(k) of the act), or were legally on the market prior to May 28, 1976, the enactment date of the Medical Device Amendments. Please note: If you purchase your device components in bulk (i.e., unfinished) and further process (e.g., sterilize) you must submit a new 510(k) before including these components in your kit. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, and 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.
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Page 2 - Ms. Peggy Keiffer
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 (21 CFR Part 807); 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 your device on the labeling regulation, please contact the Office of Compliance at (240) 276-0115. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). 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) 443-6597, or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely vours.
Colin Pollard
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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Section 1.4
Catheter Repair Kit with Replacement Connector
510(k)
Indications for Use
510(k) Number (if known): Kole 3446
Device Name: Catheter Repair Kit with Replacement Connector
Indications for Use:
To replace: Cracked or broken female luer lock connectors or repair damaged extension where there is a minimum of 4.5 cm of viable extension tubing on the following catheters: Soft-Cell* Long-Term Dual Lumen Catheter, Opti-Flow* Long-Term Dual Lumen Catheter, Slim-Cath* Short-Term Dual Lumen Catheter, Vaccess* Short-Term Single Lumen Catheter, HemoStar* Long-Term Dual Lumen Catheter, Flexxicon* Short-Term Dual Lumen Catheter, Niagara* Short-Term Dual Lumen Catheter, Flexxicon* II Short-Term Dual Lumen Catheter, HemoGlide* Long-Term Dual Lumen Catheter, and HemoSplit* Long-Term Hemodialysis Catheter.
- Soft-Cell, Opti-Flow, Slim-Cath, Vaccess, HemoStar, Flexxicon, Niagara, Flexxicon II, HemoGlide, and HemoSplit are trademarks and/or registered trademarks of C. R. Bard Inc., or an affiliate.
Prescription Use (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Colm Poland
(Division Sign-Off) Division of Reproductive, Abdomina and Radiological Device 510(k) Number
000043
§ 876.5540 Blood access device and accessories.
(a)
Identification. A blood access device and accessories is a device intended to provide access to a patient's blood for hemodialysis or other chronic uses. When used in hemodialysis, it is part of an artificial kidney system for the treatment of patients with renal failure or toxemic conditions and provides access to a patient's blood for hemodialysis. The device includes implanted blood access devices, nonimplanted blood access devices, and accessories for both the implanted and nonimplanted blood access devices.(1) The implanted blood access device is a prescription device and consists of various flexible or rigid tubes, such as catheters, or cannulae, which are surgically implanted in appropriate blood vessels, may come through the skin, and are intended to remain in the body for 30 days or more. This generic type of device includes various catheters, shunts, and connectors specifically designed to provide access to blood. Examples include single and double lumen catheters with cuff(s), fully subcutaneous port-catheter systems, and A-V shunt cannulae (with vessel tips). The implanted blood access device may also contain coatings or additives which may provide additional functionality to the device.
(2) The nonimplanted blood access device consists of various flexible or rigid tubes, such as catheters, cannulae or hollow needles, which are inserted into appropriate blood vessels or a vascular graft prosthesis (§§ 870.3450 and 870.3460), and are intended to remain in the body for less than 30 days. This generic type of device includes fistula needles, the single needle dialysis set (coaxial flow needle), and the single needle dialysis set (alternating flow needle).
(3) Accessories common to either type include the shunt adaptor, cannula clamp, shunt connector, shunt stabilizer, vessel dilator, disconnect forceps, shunt guard, crimp plier, tube plier, crimp ring, joint ring, fistula adaptor, and declotting tray (including contents).
(b)
Classification. (1) Class II (special controls) for the implanted blood access device. The special controls for this device are:(i) Components of the device that come into human contact must be demonstrated to be biocompatible. Material names and specific designation numbers must be provided.
(ii) Performance data must demonstrate that the device performs as intended under anticipated conditions of use. The following performance characteristics must be tested:
(A) Pressure versus flow rates for both arterial and venous lumens, from the minimum flow rate to the maximum flow rate in 100 milliliter per minute increments, must be established. The fluid and its viscosity used during testing must be stated.
(B) Recirculation rates for both forward and reverse flow configurations must be established, along with the protocol used to perform the assay, which must be provided.
(C) Priming volumes must be established.
(D) Tensile testing of joints and materials must be conducted. The minimum acceptance criteria must be adequate for its intended use.
(E) Air leakage testing and liquid leakage testing must be conducted.
(F) Testing of the repeated clamping of the extensions of the catheter that simulates use over the life of the device must be conducted, and retested for leakage.
(G) Mechanical hemolysis testing must be conducted for new or altered device designs that affect the blood flow pattern.
(H) Chemical tolerance of the device to repeated exposure to commonly used disinfection agents must be established.
(iii) Performance data must demonstrate the sterility of the device.
(iv) Performance data must support the shelf life of the device for continued sterility, package integrity, and functionality over the requested shelf life that must include tensile, repeated clamping, and leakage testing.
(v) Labeling of implanted blood access devices for hemodialysis must include the following:
(A) Labeling must provide arterial and venous pressure versus flow rates, either in tabular or graphical format. The fluid and its viscosity used during testing must be stated.
(B) Labeling must specify the forward and reverse recirculation rates.
(C) Labeling must provide the arterial and venous priming volumes.
(D) Labeling must specify an expiration date.
(E) Labeling must identify any disinfecting agents that cannot be used to clean any components of the device.
(F) Any contraindicated disinfecting agents due to material incompatibility must be identified by printing a warning on the catheter. Alternatively, contraindicated disinfecting agents must be identified by a label affixed to the patient's medical record and with written instructions provided directly to the patient.
(G) Labeling must include a patient implant card.
(H) The labeling must contain comprehensive instructions for the following:
(
1 ) Preparation and insertion of the device, including recommended site of insertion, method of insertion, and a reference on the proper location for tip placement;(
2 ) Proper care and maintenance of the device and device exit site;(
3 ) Removal of the device;(
4 ) Anticoagulation;(
5 ) Management of obstruction and thrombus formation; and(
6 ) Qualifications for clinical providers performing the insertion, maintenance, and removal of the devices.(vi) In addition to Special Controls in paragraphs (b)(1)(i) through (v) of this section, implanted blood access devices that include subcutaneous ports must include the following:
(A) Labeling must include the recommended type of needle for access as well as detailed instructions for care and maintenance of the port, subcutaneous pocket, and skin overlying the port.
(B) Performance testing must include results on repeated use of the ports that simulates use over the intended life of the device.
(C) Clinical performance testing must demonstrate safe and effective use and capture any adverse events observed during clinical use.
(vii) In addition to Special Controls in paragraphs (b)(1)(i) through (v) of this section, implanted blood access devices with coatings or additives must include the following:
(A) A description and material characterization of the coating or additive material, the purpose of the coating or additive, duration of effectiveness, and how and where the coating is applied.
(B) An identification in the labeling of any coatings or additives and a summary of the results of performance testing for any coating or material with special characteristics, such as decreased thrombus formation or antimicrobial properties.
(C) A Warning Statement in the labeling for potential allergic reactions including anaphylaxis if the coating or additive contains known allergens.
(D) Performance data must demonstrate efficacy of the coating or additive and the duration of effectiveness.
(viii) The following must be included for A-V shunt cannulae (with vessel tips):
(A) The device must comply with Special Controls in paragraphs (b)(1)(i) through (v) of this section with the exception of paragraphs (b)(1)(ii)(B), (b)(1)(ii)(C), (b)(1)(v)(B), and (b)(1)(v)(C), which do not apply.
(B) Labeling must include Warning Statements to address the potential for vascular access steal syndrome, arterial stenosis, arterial thrombosis, and hemorrhage including exsanguination given that the device accesses the arterial circulation.
(C) Clinical performance testing must demonstrate safe and effective use and capture any adverse events observed during clinical use.
(2) Class II (performance standards) for the nonimplanted blood access device.
(3) Class II (performance standards) for accessories for both the implanted and the nonimplanted blood access devices not listed in paragraph (b)(4) of this section.
(4) Class I for the cannula clamp, disconnect forceps, crimp plier, tube plier, crimp ring, and joint ring, accessories for both the implanted and nonimplanted blood access device. The devices subject to this paragraph (b)(4) are exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.