(82 days)
The device is intended to be used as components of a hemodialysis water purification system to remove organic and inorganic substances from water used to dilute dialysis concentrate to form dialysate, and to produce purified water for other purposes such as dialyzer reprocessing and equipment rinse and disinfection. Upon exhaustion, these tanks will be replaced with other Deionization Tanks containing newly regenerated resin or with new resin altogether, or in the case of Carbon Tanks, with tanks containing fresh virgin carbon.
BTI Filtration Deionizer and Carbon Tank Exchange Service for Hemodialysis includes carbon filtration for the removal of chlorine and chloramines and deionizer (DI) exchange tanks for the removal of contaminants from the water through an ion exchange process to provide AAMI quality water for hemodialysis applications.
The renal care facilities will supply their own water treatment system, which may consist of water softeners, sediment filters, ultra-filtration, reverse osmosis system, alarms, monitors, tanks, and pumps. BTI Filtration will only be providing the activated carbon and deionization components to their systems.
This document describes a 510(k) submission for the BTI Filtration Deionization and Carbon Exchange System, a water purification component for hemodialysis. The submission focuses on demonstrating substantial equivalence to predicate devices rather than establishing novel performance criteria.
Here's an analysis of the provided text with respect to your questions:
1. Table of Acceptance Criteria and Reported Device Performance
The submission does not provide specific, quantifiable acceptance criteria or detailed device performance metrics in a tabular format. Instead, it makes a general claim of substantial equivalence.
| Acceptance Criteria | Reported Device Performance |
|---|---|
| (Not explicitly stated in terms of quantifiable thresholds) | "Performance testing was conducted to characterize performance... Results of the performance testing have demonstrated that the BTI Filtration Deionization and Carbon Exchange System is substantially equivalent to the predicate devices and is suitable for the labeled indications for use." |
| Ability to remove organic and inorganic substances from water for hemodialysis applications to provide AAMI quality water. | "The proposed device has the same technological characteristics and is similar in design and configuration as compared to the predicate devices." |
2. Sample Size Used for the Test Set and Data Provenance
The submission does not specify a "test set" in the context of clinical or performance data with a defined sample size. The performance testing appears to be functional characterization of the system components.
- Sample Size: Not specified.
- Data Provenance: Not specified, but likely laboratory or bench testing on system components, not patient data. Retrospective or prospective is not applicable here as it's not a clinical study on patients.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of those Experts
This information is not provided in the document. The type of evaluation performed was not a clinical study involving expert interpretation of patient data to establish ground truth.
4. Adjudication Method for the Test Set
This information is not provided. As no clinical test set requiring expert interpretation or adjudication is mentioned, this is not applicable.
5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study Was Done, and Effect Size
No, an MRMC comparative effectiveness study was not conducted or reported. This type of study is typically done for diagnostic imaging devices where human readers interpret medical images. This device is a water purification system component.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
This question is not applicable to this device. This is hardware (water purification components), not a software algorithm that would operate in a standalone manner. The device itself is designed to perform its function (water purification) autonomously once installed and operating.
7. The Type of Ground Truth Used
The ground truth or performance validation appears to be based on the physical and chemical characteristics of the purified water generated by the system, compared against established standards for hemodialysis water (e.g., AAMI quality water). The substantial equivalence claim is anchored on the device's technological characteristics and its ability to achieve these water quality standards, similar to the predicate devices. It is not based on expert consensus, pathology, or outcomes data in a clinical sense.
8. The Sample Size for the Training Set
This information is not applicable as this is not a device employing machine learning or AI that requires a training set.
9. How the Ground Truth for the Training Set Was Established
This information is not applicable as there is no training set for this device.
Summary of Device and Performance Information from the Given Text:
The BTI Filtration Deionization and Carbon Exchange System is intended as a component of a hemodialysis water purification system. Its purpose is to remove organic and inorganic substances from water to produce AAMI quality water for hemodialysis applications.
The manufacturer claims substantial equivalence to predicate devices (AmeriWater Purification System for Hemodialysis (K991519) and US Filter Water Purification System for Hemodialysis (K980182)) based on:
- Technological Characteristics: The proposed device has the "same technological characteristics and is similar in design and configuration" to the predicate devices, using "components commonly found in the predicate devices."
- Performance Testing: "Performance testing was conducted to characterize performance... [and] demonstrated that the BTI Filtration Deionization and Carbon Exchange System is substantially equivalent to the predicate devices and is suitable for the labeled indications for use."
The submission focuses on the engineering and functional similarity to already cleared devices, rather than presenting a novel clinical study with explicit acceptance criteria for diagnostic performance or treatment outcomes. The "acceptance criteria" can be inferred as meeting the AAMI water quality standards, which the performance testing presumably verified, consistent with the predicates.
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JUN - 2 2008
510(k) Section 5 - 510(k) Summary BTI Filtration Deionization and Carbon Exchange System
510(k) Summary (in accordance with 21 CFR 807.87(h) and 21 CFR 807.92)
-
- Submitter's name and address: BTI Filtration 7317 N Classen Blvd Oklahoma City, OK 73116
- Submitter's telephone number and fax number: 2. 405.842.2517 Fax 405.842.3626
- Contact person: 3. Ms. Crystal McKav
- বা Date this 510(k) summary prepared: March 4, 2008
- Name of the device: 5.
- . Trade/proprietary name - BTI Filtration Deionization and Carbon Exchange System
- . Common Name - Carbon tank and DI tank
- . Classification name - Water purification component for hemodialysis (21 CFR 876.5665, Product code FIP)
- Legally marketed predicate devices to which substantial equivalence is 6. claimed:
-
- Description of the device that is the subject of this premarket notification: BTI Filtration Deionizer and Carbon Tank Exchange Service for Hemodialysis includes carbon filtration for the removal of chlorine and chloramines and deionizer (DI) exchange tanks for the removal of contaminants from the water through an ion exchange process to provide AAMI quality water for hemodialysis applications.
The renal care facilities will supply their own water treatment system, which mav consist of water softeners, sediment filters, ultra-filtration, reverse osmosis system, alarms, monitors, tanks, and pumps. BTI Filtration will only be providing the activated carbon and deionization components to their systems
8. Intended use and indication for use:
The device is intended to be used as components of a hemodialysis water purification system to remove organic and inorganic substances from water used to dilute dialysis concentrate to form dialysate, and to produce purified water for other purposes such as dialyzer reprocessing and equipment rinse and disinfection.
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510(k) Section 5 - 510(k) Summary BTI Filtration Deionization and Carbon Exchange System
9. Technological characteristics:
The proposed device has the same technological characteristics and is similar in design and configuration as compared to the predicate devices. The proposed device is designed and assembled with components commonly found in the predicate devices.
10. Non-clinical performance data
BTI Filtration believes that the information and data provided in this submission clearly describes the proposed device and demonstrates that the device is adequately designed for the labeled indications for use. Performance testing was conducted to characterize performance of the proposed BTI Filtration Deionization and Carbon Exchange System to provide a basis of comparison to the predicate devices. Results of the performance testing have demonstrated that the BTI Filtration Deionization and Carbon Exchange System is substantially equivalent to the predicate devices and is suitable for the labeled indications for use.
This concludes the 510(k) Summary.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/2/Picture/1 description: The image shows the seal of the Department of Health & Human Services (HHS). The seal features a stylized eagle with three wavy lines extending from its head, representing the department's mission to protect and promote the health and well-being of all Americans. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" are arranged in a circular pattern around the eagle.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
JUN - 2 2008
4M Ventures, Inc. DBA c/o Ms. Denice Carr Gallagher Shotwell & Carr, Inc. 1415 Halsey Way, Suite 304 CARROLLTON TX 75007-4455
Re: K080703
Trade/Device Name: BTI Filtration Deionizer and Carbon Exchange Service for Hemodialysis Regulation Number: 21 CFR §876.5665
Regulation Name: Water purification system for hemodialysis Regulatory Class: II Product Code: FIP Dated: March 4, 2008
Received: March 12, 2008
Dear Ms. Gallagher:
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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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 your device on our labeling regulation (21 CFR Part 801), please contact the Center for Devices and Radiological Health's (CDRH's) Office of Compliance at one of the following numbers, based on the regulation number at the top of this letter.
| 21 CFR 876.xxxx | (Gastroenterology/Renal/Urology) | 240-276-0115 |
|---|---|---|
| 21 CFR 884.xxxx | (Obstetrics/Gynecology) | 240-276-0115 |
| 21 CFR 892.xxxx | (Radiology) | 240-276-0120 |
| Other | 240-276-0100 |
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding postmarket surveillance, please contact CDRH's Office of Surveillance and Biometric's (OSB's) Division of Postmarket Surveillance at 240-276-3474. For questions regarding the reporting of device adverse events (Medical Device Reporting (MDR)), please contact the Division of Surveillance Systems at 240-276-3464. 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 (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely vours.
Nancy Brogdon
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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510/k) Section 4 – Indications for Use BT! Filtration Deionizer and Carbon Exchange Service for Hemodialysis
Indications for Use
510(k) Number (if known): K080703
Device Name: BTI Filtration Deionizer and Carbon Exchange Service for Hemodialysis
Indications for Use:
The device is intended to be used as components of a hemodialysis water purification system to remove organic and inorganic substances from water used to dilute dialysis concentrate to form dialysate, and to produce purified water for other purposes such as dialyzer reprocessing and equipment rinse and disinfection. Upon exhaustion, these tanks will be replaced with other Deionization Tanks containing newly regenerated resin or with new resin altogether, or in the case of Carbon Tanks, with tanks containing fresh virgin carbon.
Note: The renal care facilities will supply their own water treatment system, which may consist of water softeners, sediment filters, ultra-filtration, reverse osmosis system, alarms, monitors, tanks, and pumps. BTI Filtration will only be providing the activated carbon and deionization components to their systems.
Prescription Use X (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)
Hester Heinen
Olvision Sian-Off) Division of Reproductive, Abdominal and Radiological Devices 510(k) Number
§ 876.5665 Water purification system for hemodialysis.
(a)
Identification. A water purification system for hemodialysis is a device that is intended for use with a hemodialysis system and that is intended to remove organic and inorganic substances and microbial contaminants from water used to dilute dialysate concentrate to form dialysate. This generic type of device may include a water softener, sediment filter, carbon filter, and water distillation system.(b)
Classification. Class II (special controls). The device, when it is a water purification subsystem disinfectant, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.