(27 days)
The THERMOGARD can be used with any of the Alsius Catheters. The indications for use are specific to the catheter. Please refer to the Indications for Use statement in the catheter specific Instructions for Use.
The THERMOGARD/Alsius Catheter Thermal Regulation System, using either the Icy™ or Fortius™ model catheter, is indicated for use:
- In cardiac surgery patients to achieve and or maintain normothermia during surgery and recovery/intensive care, and
- To induce, maintain and reverse mild hypothermia in neurosurgery patients in surgery and recovery/intensive care.
The Alsius THERMOGARD™ and Cool Line™ Catheter Thermal Regulation System is indicated for use in fever reduction, as an adjunct to other antipyretic therapy, in patients with cerebral infarction and intracerebral hemorrhage who require access to the central venous circulation and who are intubated and sedated.
The THERMOGARD and Catheter Thermal Regulation System consists of the THERMOGARD, a disposable Start Up Kit used to interface between the cooling bath of the THERMOGARD and the intravascular Catheter. The THERMOGARD is an integrated electro-mechanical heater/cooler that consists of a temperature monitor, a temperature controller unit, a heat exchanger unit, and roller pump. It supplies temperature controlled sterile saline to the indwelling Catheter that is placed percutaneously in the patient.
The technical characteristics of the Catheter are identical to the predicate device with the exception of revisions to the software that controls the device.
All models of Alsius Intravascular catheters are available for use with the THERMOGARD.
The provided text describes a 510(k) summary for the ALSIUS CORPORATION'S THERMOGARD and Catheter Thermal Regulation System. This document focuses on demonstrating substantial equivalence to a predicate device rather than presenting acceptance criteria and a study proving a device meets those criteria for a novel technology.
However, the document does contain information about a clinical trial related to the device's use in fever reduction and outlines certain limitations on its use based on the trial results. This information can be re-purposed to infer a type of "acceptance criteria" based on the observed safety and effectiveness, and the study details are provided.
Here's an analysis based on the information available:
1. Table of Acceptance Criteria and Reported Device Performance
The document doesn't explicitly state "acceptance criteria" in the typical sense for a new device's performance metrics (e.g., sensitivity, specificity, accuracy thresholds). Instead, it presents mortality rates from a clinical trial that led to a warning and limitation on the device's indications for use.
The "acceptance criteria" here are effectively inferred limits on where the device's performance was considered safe and effective enough for its intended use, particularly for fever reduction, based on its performance relative to a control group. For the conditions where the device was not shown to be safe and effective, the mortality rates in the Cool Line group were not significantly better (and in some cases numerically worse) than the control group.
| Acceptance Criteria (Inferred from FDA Warning) | Reported Device Performance (Mortality % with Cool Line System) | Control Group Performance (Mortality % without Cool Line System) | p-value | Indication/Patient Cohort |
|---|---|---|---|---|
| Acceptable for Fever Reduction: Device demonstrated safety and effectiveness as an adjunct to other antipyretic therapy. (Implies non-inferiority or better outcomes compared to control, though not explicitly stated as a statistical threshold for improvement.) | CI: 18.8% (n=3/N=16) | CI: 21.4% (n=3/N=14) | 0.74 | Cerebral Infarction (CI) |
| ICH: 24.2% (n=8/N=33) | ICH: 25.9% (n=7/N=27) | 1.00 | Intracerebral Hemorrhage (ICH) | |
| NOT Acceptable for Fever Reduction: Safety and effectiveness not demonstrated in these populations, leading to a warning. (Implies outcomes were not sufficiently better or were worse than control, or demonstrated a safety concern.) | PTBI: 22.7% (n=10/N=44) | PTBI: 10.5% (n=4/N=38) | 0.24 | Primary Traumatic Brain Injury (PTBI) |
| SAH: 21.3% (n=13/N=61) | SAH: 11.1% (n=7/N=63) | 0.15 | Subarachnoid Hemorrhage (SAH) |
Note: The p-values indicate a lack of statistically significant difference between the Cool Line and Control groups in mortality for all cohorts in this specific trial. However, for PTBI and SAH, the Cool Line group numerically had higher mortality, which contributed to the FDA's warning about lack of demonstrated safety and effectiveness for those indications for fever reduction.
2. Sample Size Used for the Test Set and Data Provenance
- Test Set Sample Size: A randomized controlled trial of 296 patients was conducted.
- Cool Line group: (16 CI + 33 ICH + 44 PTBI + 61 SAH) = 154 patients
- Control group: (14 CI + 27 ICH + 38 PTBI + 63 SAH) = 142 patients
- Data Provenance: The document does not explicitly state the country of origin. It is a prospective randomized controlled trial.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
This type of information is generally not applicable to a clinical trial involving patient outcomes like mortality. The "ground truth" here is the actual patient outcome (mortality), which is a definitive clinical event, not an expert interpretation of an image or a condition. Therefore, no experts were "establishing ground truth" in that sense.
4. Adjudication Method for the Test Set
Not applicable in the context of a clinical trial where the primary endpoint is mortality. Mortality is typically recorded as a factual event, not subject to adjudication in the same way, for example, an imaging diagnosis or a pathological finding might be.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- No, this was not an MRMC study. An MRMC study typically involves multiple human readers interpreting cases (e.g., medical images) to assess diagnostic performance, often with and without AI assistance, and then analyzing the variability and agreement among readers. This study was a randomized controlled trial comparing a medical device with an active control group based on patient survival outcomes.
- Effect size of human readers improvement with AI vs without AI assistance: Not applicable, as this was not an imaging diagnostic study involving human readers and AI assistance.
6. Standalone (i.e., algorithm only without human-in-the-loop performance) Study
- No, this was a study of a medical device (THERMOGARD Thermal Regulation System) used in patients, with human medical staff operating and managing the system. It is not an algorithm designed for diagnostic or predictive tasks that could operate "standalone" in the medical sense of an AI model only.
7. Type of Ground Truth Used (Expert Consensus, Pathology, Outcomes Data, etc.)
- Outcomes Data: The ground truth was mortality, which is a definitive clinical outcome.
8. Sample Size for the Training Set
The document describes a clinical trial (a "test set" or pivotal study) evaluating the device in humans. It does not mention a "training set" in the context of machine learning or AI model development. The device itself is electro-mechanical, not an AI algorithm that would typically require a training set in that sense.
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there is no mention of a machine learning "training set" for an AI algorithm.
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Image /page/0/Picture/1 description: The image shows the word "ALSIUS" in a bold, serif font. Below the word "ALSIUS" is the word "CORPORATION" in a smaller, sans-serif font. To the right of the word "ALSIUS" is the letter "C".
Company Confidential
K063829
510(k) Summary or 510(k) Statement 6
510(k) SUMMARY FOR ALSIUS CORPORTATION'S THERMOGARD AND CATHETER THERMAL REGULATION SYSTEM
Submitter's Name, Address, Telephone Number, and Contact Person
ALSIUS CORPORATION 15770 Laguna Canyon Road, Suite 150 Irvine, CA 92618
JAN 2 2 2007
| Contact: | Ken Collins |
|---|---|
| Phone: | (949)-453-0150 |
| Fax: | (949)-453-0250 |
| Email: | kcollins@alsius.com |
Name of Device
The THERMOGARD and Catheter Thermal Requlation System.
Common or Usual Name
Central Venous Catheter (short term) and Thermal Regulating System.
Classification Name
FDA has classified the Alsius THERMOGARD/Alsius heat exchange catheters as Class Il devices under 21 C.F.R. §§ 870.5900 -- System, Hypothermia, Intravenous, Cooling, Classification Product Code: NCX.
Predicate Devices
The Alsius CoolGard 3000™ thermal requiating system.
Indications for Use
The THERMOGARD can be used with any of the Alsius Catheters. The indications for use are specific to the catheter. Please refer to the Indications for Use statement in the catheter specific Instructions for Use.
Indications for Use (K030421, K051912, K052443)
The THERMOGARD/Alsius Catheter Thermal Regulation System, using either the Icy™ or Fortius™ model catheter, is indicated for use:
- In cardiac surgery patients to achieve and or maintain normothermia during . surgery and recovery/intensive care, and
Page 20
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- To induce, maintain and reverse mild hypothermia in neurosurgery patients in . surgery and recovery/intensive care.
Indications for Use (K014241, K051912)
The Alsius THERMOGARD™ and Cool Line™ Catheter Thermal Regulation System is indicated for use in fever reduction, as an adjunct to other antipyretic therapy, in patients with cerebral infarction and intracerebral hemorrhage who require access to the central venous circulation and who are intubated and sedated.
Warning - Fever Reduction
The safety of this device has not been demonstrated for fever reduction in patients presenting with subarachnoid hemorrhage or primary traumatic brain injury. The safety and effectiveness of this device was examined in a randomized controlled trial of 296 patients. The mortality results reported in this trial, for the four patient cohorts enrolled. are presented in the table below (CI - cerebral infarction, ICH - intracerebral hemorrhage, PTBI - primary traumatic brain injury, SAH - subarachnoid hemorrhage),
| Cool Line | Control | ||||||
|---|---|---|---|---|---|---|---|
| n | N | % | n | N | % | p-value* | |
| CI | 3 | 16 | 18.8 | 3 | 14 | 21.4 | 0.74 |
| ICH | 8 | 33 | 24.2 | 7 | 27 | 25.9 | 1.00 |
| PTBI | 10 | 44 | 22.7 | 4 | 38 | 10.5 | 0.24 |
| SAH | 13 | 61 | 21.3 | 7 | 63 | 11.1 | 0.15 |
| Table | 1-1. Mortality by Diagnosis (ITT) | |
|---|---|---|
*Fischer's exact test
For more details on the results of this study please refer to Physician's Manual – "Normothermia for the Neuro-critically !!! Stroke Patient" #101416-001.
Technical Characteristics
The THERMOGARD and Catheter Thermal Regulation System consists of the THERMOGARD, a disposable Start Up Kit used to interface between the cooling bath of the THERMOGARD and the intravascular Catheter. The THERMOGARD is an integrated electro-mechanical heater/cooler that consists of a temperature monitor, a temperature controller unit, a heat exchanger unit, and roller pump. It supplies temperature controlled sterile saline to the indwelling Catheter that is placed percutaneously in the patient.
The technical characteristics of the Catheter are identical to the predicate device with the exception of revisions to the software that controls the device.
All models of Alsius Intravascular catheters are available for use with the THERMOGARD.
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Image /page/2/Picture/1 description: The image contains the words "Company Confidential" in a simple, sans-serif font. The text is horizontally aligned and appears to be part of a document or presentation. The words are likely intended to indicate the sensitive or proprietary nature of the information contained within the document.
Principles of Operation
106 3829
The THERMOGARD system automatically adjusts the temperature of the heater/chiller saline bath to achieve the patient target temperature that has previously been set by the attending physician. This is done via data from a temperature probe in the patient that interfaces with the temperature controller. This principle of operation is identical to the predicate device.
Summary of the Basis for Finding of Substantial Equivalence
The THERMOGARD System is substantially equivalent to the Alsius CoolGard 3000™ heat exchange system in all its specifications.
Conclusion
In summary, descriptive information and performance data demonstrate that the Alsius THERMOGARD and Catheter Thermal Regulation System characteristics do not raise new questions of safety and effectiveness. Where appropriate, performance data demonstrate equivalence. The system in this revision acts as its own predicate device. The THERMOGARD and Catheter Thermal Regulation System is safe and effective when used in accordance with the Directions For Use and substantially equivalent to the predicate device.
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Image /page/3/Picture/1 description: The image shows the logo for the Department of Health and Human Services (HHS). The logo features a stylized caduceus, which is a symbol often associated with healthcare. The words "DEPARTMENT OF HEALTH AND HUMAN SERVICES . USA" are arranged in a circular pattern around the caduceus.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
Alsius Corporation % Kenneth A. Collins. M.D. Executive Vice President 15770 Laguna Canyon Road Suite 150 Irvine, California 92618
JAN 2 2 2007
Re: K063829
Trade/Device Name: Alsius Thermogard and Catheter Thermal Regulation System Regulation Number: 21 CFR 870.5900 Regulation Name: Thermal regulating system Regulatory Class: II Product Code: NCX Dated: December 22, 2006 Received: December 26, 2006
Dear Dr. Collins:
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.
The Office of Device Evaluation has determined that there is a reasonable likelihood that this device will be used for an intended use not identified in the proposed labeling and that such use could cause harm. Therefore, in accordance with Section 513(i)(1)(E) of the Act, the following limitation must appear in the Warnings section of the device's labeling as a box warning immediately following the indications for use statement:
The safety of this device has not been demonstrated for fever reduction in patients presenting with subarachnoid hemorrhage or primary traumatic brain injury. The safety and effectiveness of this device was examined in a randomized controlled trial of 296 patients. The mortality results reported in this trial, for the four patient cohorts enrolled, are presented in the table below (CI -- cerebral infarction, ICH -- intracerebral hemorrhage, PTBI - primary traumatic brain injury, SAH - subarachnoid hemorrhage).
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| Cool Line | Control | |||||||
|---|---|---|---|---|---|---|---|---|
| n | N | % | n | N | % | p-value* | ||
| CI | 3 | 16 | 18.8 | 3 | 14 | 21.4 | 0.74 | |
| ICH | 8 | 33 | 24.2 | 7 | 27 | 25.9 | 1.00 | |
| PTBI | 10 | 44 | 22.7 | 4 | 38 | 10.5 | 0.24 | |
| SAH | 13 | 61 | 21.3 | 7 | 63 | 11.1 | 0.15 |
Mortality by Diagnosis (ITT)
*Fischer's exact test
For more details on the results of this study please refer to "Physician's Manual – Fever Reduction for Patients with Cerebral Infarction and Intracerebral Hemorrhage" #101416-001.
Please note that the above labeling limitations are required by Section 513(i)(1)(E) of the Act. Therefore, a new 510(k) is required before these limitations are modified in any way or removed from the device's labeling.
The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and permits your device to proceed to the market. This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification if the limitation statement described above is added to your labeling.
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 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 information about the application of other labeling requirements to your device (21 CFR Part 801), 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
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Page 3 – Kenneth A. Collins, M.D.
toll-free number (800) 638-2041 or (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely yours,
Hartum MD for
Donna-Bea Tillman, Ph.D., M.P.A. Director Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
:
:
:
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Indications for Use
510(k) Number (if known):
Device Name:
Alsius Thermogard and Catheter Thermal Regulation System
Indications For Use:
Indications For Use:
Alsius Thermogard - Indications for Use:
The Alsius Thermogard and Cool Line ™ Catheter Thermal Regulation System is indicated for use in fever reduction, as an adjunct to other antipyretic therapy, in patients with cerebral infarction and intracerebral hemorrhage who require access to the central venous circulation and who are intubated and sedated.
Warning - Fever Reduction
The safety of this device has not been demonstrated for fever reduction in patients presenting with subarrachnoid hemorrhage or primary traumatic brain injury. The safety and effectiveness of this device was examined in a randomized controlled trial of 296 patients. The mortality results reported in this trial, for the four patient cohorts enrolled, are presented in the table below (CI - cerebral infarction, ICH - intracerebral hemorrhage, PTBI - primary traumatic brain injury, SAH - subarrachnoid hemorrhage).
| Cool Line | Control | ||||||
|---|---|---|---|---|---|---|---|
| n | N | % | n | N | % | p* | |
| CI | 3 | 16 | 18.8 | 3 | 14 | 21.4 | 0.74 |
| ICH | 8 | 33 | 24.2 | 7 | 27 | 25.9 | 1.00 |
| PTBI | 10 | 44 | 22.7 | 4 | 38 | 10.5 | 0.24 |
| SAH | 13 | 61 | 21.3 | 7 | 63 | 11.1 | 0.15 |
rtality by Diagnosis (ITT analysis)
For more details on the clinical trial results please refer to Physician's Manual -"Normothermia for the Neuro-critically III stroke patient" #101416-001.
| Prescription Use X | AND/OR | Over-The-Counter Use ________ |
|---|---|---|
| (Part 21 CFR 801 Subpart D) | (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)
(Division Sign-Off)
Division of General, Restorative, and Neurological Devices
mn Deputy Dr
510(k) Number K013828
Page 1 of 2
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Indications for Use
510(k) Number (if known):
Alsius Thermogard and Catheter Thermal Regulation System Device Name:
Indications For Use:
Fortius and Icy Catheters - Indications for Use:
The Alsius Thermogard/Alsius Catheter Thermal Regulation System, using either the Icy™ or Fortius™ model catheter, is indicated for use:
- in cardiac surgery patients to achieve and or maintain normothermia during . surgery and recovery/intensive care, and
- to induce, maintain and reverse mild hypothermia in neurosurgery patients in . surgery and recovery/intensive care.
Prescription Use X
AND/OR
Over-The-Counter Use (21 CFR 807 Subpart C)
(Part 21 CFR 801 Subpart D)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
§ 870.5900 Thermal regulating system.
(a)
Identification. A thermal regulating system is an external system consisting of a device that is placed in contact with the patient and a temperature controller for the device. The system is used to regulate patient temperature.(b)
Classification. Class II (performance standards).