(106 days)
The CritiCool is a thermal regulating system, indicated for monitoring and controlling patient temperature.
The CritiCool system consists of the following elements:
- Temperature controlled garment .
- . Body sensors
- Connecting flexible water pipes .
- Heating/Cooling Unit .
The system is operated by circulating water by a pump in a closed loop between the device and a disposable garment - CureWrap, worn by the patient. The water circulates through the thermoregulating unit. Temperature (body) sensors are placed on the patient's skin to measure surface temperature and in the rectum, nasopharynx or esophagus to measure core temperature. The operator selects the desired patient core temperature (between 30-40°C) and the unit automatically controls it via a feedback loop. The heating / cooling unit is based on a solid-state thermo-electric device, which operates as a heat pump
The provided document is a 510(k) premarket notification for the CritiCool System, a thermal regulating device. This type of submission focuses on demonstrating substantial equivalence to a predicate device, rather than providing extensive clinical study data proving efficacy or meeting specific acceptance criteria in the way a new drug or novel medical device might.
Therefore, the document does not contain a detailed study proving the device meets acceptance criteria in the format requested. Instead, it relies on demonstrating that the CritiCool device has similar specifications and indications for use as previously cleared predicate devices (ArcticSun and Allon 2001 Version 5).
However, I can extract the relevant information regarding performance specifications and any implied "acceptance criteria" through comparison with the predicate devices.
Here's a breakdown of the requested information based on the provided text, with clarifications where the information is not explicitly stated in the context of a "study":
1. Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria are implied by the specifications of the predicate devices. The CritiCool device is considered "substantially equivalent" if its performance matches or is within acceptable limits of these predicate devices.
| Specification (Implied Acceptance Criteria) | Predicate Device (Allon 2001 Version 5) Performance | CritiCool Reported Performance |
|---|---|---|
| Control Modes | Automatic | Automatic |
| Heater Capability | 500W | 500W |
| Circulating Fluid | Tap Water | Tap Water |
| Reservoir Capacity | 6 liters (1.6 gal) | 6 liters (1.6 gal) |
| Heat Exchanger | Garment | Garment |
| Water Flow Rate (total) | 1-1.2 Liter/min | 1-1.2 Liter/min |
| Patient Probe Type | YSI 400 Series compatible | YSI 400 Series compatible |
| Patient Temperature Inputs | 2 – Core and Surface temperature | 2 – Core and Surface temperature |
| Patient Temperature Display Range | 18.5°C to 43.9°C (65.3°F to 111.0°F) in 0.1°C/°F steps | 18.5°C to 43.9°C (65.3°F to 111.0°F) in 0.1°C/°F steps |
| Patient Temperature Measurement Accuracy | ±0.3°C (0.4°F) | ±0.3°C (0.4°F) |
| Patient Temperature Control Range - Automatic Mode | 30°C to 40°C (86°F to 104°F) in 0.1°C/F increments | 30°C to 40°C (86°F to 104°F) in 0.1°C/F increments |
| Water Temperature Display Range | 9°C to 44°C (48.2°F to 111.2°F) in 0.1°C/F | 9°C to 44°C (48.2°F to 111.2°F) in 0.1°C/F |
| Maximum Water Temperature (Automatic Mode) | 40.8°C (105.4°F) | 40.8°C (105.4°F) |
| Minimum Water Temperature (Automatic Mode) | 13°C (55.4°F) | 13°C (55.4°F) |
| Mains Input | 230/115 VAC, 500W, 50/60 Hz, 6.3 amp | 230/115 VAC, 500W, 50/60 Hz, 6.3 amp |
| Current Leakage | < 150uA | < 150uA |
| Circuit Breaker | 2 X 6.3 Amp fuse | 2 X 6.3 Amp fuse |
| Data Output | Yes | Yes |
| Operating Relative Humidity Range | 10%-100% | 10%-100% |
| Storage Relative Humidity Range | 10%-100% | 10%-100% |
| Operating Temperature Range | 30°C to 40°C (50-104°F) | 30°C to 40°C (50-104°F) |
| Storage Temperature Range | -40°C to 70°C (-40°F to 158°F) | -40°C to 70°C (-40°F to 158°F) |
| Weight when filled | 86 lbs (39 Kg) | 86 lbs (39 Kg) |
| Water Temperature High Alarm | 42°C | 42°C |
| Water Temperature Low Alarm | 10°C | 10°C |
| System Patient Temperature High Alarm | 38.5°C (101.3°F) or 2°C above set point | 38.5°C (101.3°F) or 2°C above set point |
| System Patient Temperature Low Alarm | 35.5°C (95.9°F) or 0.5°C below set point | 35.5°C (95.9°F) or 0.5°C below set point |
| Patient Probe Fault Alarm Short or Open | Yes | Yes |
| Water Flow Alert 50% of case maximum | Yes | Yes |
| System Water Temperature High Alarm | 42°C | 42°C |
| System Water Temperature Low Alarm | 10°C | 10°C |
| Reservoir level Alert then Alarm Low then Empty | Yes | Yes |
| System Self Test Alarm At power up | Yes | Yes |
The document states that the CritiCool system's specifications are "compares to the predicate, ArcticSun and Allon 2001version 5." The table above focuses on direct comparisons to the primary predicate, Allon 2001 Version 5, where the values for CritiCool match exactly, indicating that these specifications are the "reported performance" and are accepted because they are equivalent to the cleared predicate.
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
This 510(k) submission primarily relies on design specifications and functional comparisons to predicate devices. It does not describe a clinical study with a "test set" of patient data in the typical sense.
The document mentions "Materials were tested and proven for biocompatibility (see part 15)," which refers to a separate section not provided here. Such testing would involve laboratory samples, not human patient data in a "test set."
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)
Not applicable. The submission does not describe a study involving expert-established ground truth for a test set of patient data, as it is not a diagnostic device.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable, as there is no described test set requiring adjudication.
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
Not applicable. This device is a thermal regulating system, not a diagnostic imaging device that would involve human "readers" or AI assistance for interpretation.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This refers to the performance of the device's automatic control system. The "standalone" performance is described by its specifications (e.g., patient temperature control range and accuracy, alarm thresholds) which are directly compared and found equivalent to the predicate device. The claim of "automatic" control mode performance for CritiCool (matching Allon 2001) implies that the algorithm controlling the heating/cooling unit functions autonomously to maintain the set temperature within specified ranges.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
The "ground truth" for this type of device's performance is typically established through:
- Engineering verification and validation testing: Confirming that the device meets its design specifications (e.g., temperature accuracy, flow rates, alarm functionality) under various simulated and real-world conditions. This would involve calibrated instruments as the "ground truth" reference.
- Comparison to predicate device specifications: The fundamental "ground truth" for FDA clearance via 510(k) is demonstrating that the new device's specifications and performance are substantially equivalent to a legally marketed predicate device.
The document does not detail specific "ground truth" for a patient study, as that is not the primary mechanism for demonstrating substantial equivalence for this type of device.
8. The sample size for the training set
Not applicable. This device does not use machine learning or AI that would require a "training set" of data in the common sense.
9. How the ground truth for the training set was established
Not applicable, as there is no "training set."
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MAR 2 6 2009
Food and Drug Administration Traditional 510(k) for CritiCool System
Image /page/0/Picture/3 description: The image shows the logo for MTRE. The logo consists of a geometric shape on the left and the letters "MTRE" on the right. The geometric shape is made up of six triangles arranged in a hexagon shape. The letters "MTRE" are in a simple, sans-serif font.
Topic: 510K for CritiCool system . . .
Establishment Name, Registration Number and Address:
Name: Registration Number: Operator Number: Address: Postal Address: Tel: Fax: Contact person:
MTRE Advanced Technology Ltd. 9616800 9038416 4 Hayarden Street, Yavne, 81228, Israel PO Box 102, Rehovot, 76100, Israel +972-8-9323333 +972-8-9328510 Ifat Oren, Regulatory Affairs
- To: Food and Drug Administration Center for Devices and Radiological Health Document Mail Center (HFZ-401) 9200 Corporate Boulevard Rockville MD, 20850
Attn .: Document Control Clerk From: Ifat Oren, Regulatory Affairs
Additional electronic copy (which is an exact duplicate of the paper copy) of the submission is attached on CD
The following information is being submitted in conformance with 21 CFR 807.87:
-
- Classification Name 2. Classification Number: 3. Common/Usual Name 4. Trade/Proprietary Name CritiCool 5. Part Number of CritiCool 100-00003 6. Establishment Registration Number 9616800 7. FDA Classification Class II 8. Product Code DWJ 9. Reviewing Panel 10. 510 (k) marketing clearance of Medivance ArcticSun system 510(k) Marketing clearance for Allon system
System Thermal regulating 21 CFR 870.5900 Thermal regulating systems Cardiovascular
- Classification Name 2. Classification Number: 3. Common/Usual Name 4. Trade/Proprietary Name CritiCool 5. Part Number of CritiCool 100-00003 6. Establishment Registration Number 9616800 7. FDA Classification Class II 8. Product Code DWJ 9. Reviewing Panel 10. 510 (k) marketing clearance of Medivance ArcticSun system 510(k) Marketing clearance for Allon system
K071341 August 3, 2007 K024128 - February 10, 2003 K003349 - November 13, 2000
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K001546 - June 8, 2000 K992386 - March 7, 2000
Terminology
CritiCool = subiect of this 510(k) submission. The CritiCool is a thermoregulation system based on water circulating via disposable Garment .
Arctic Sun Temperature Management System = the predicate device. was approved for marketing by the FDA - K071341 August 3, 2007
Allon 2001 Ver 5 = the predicate device was approved for marketing by the FDA - K024128 February 10, 2003
Device Description:
The CritiCool system consists of the following elements:
- Temperature controlled garment .
- . Body sensors
- Connecting flexible water pipes .
- Heating/Cooling Unit .
The system is operated by circulating water by a pump in a closed loop between the device and a disposable garment - CureWrap, worn by the patient. The water circulates through the thermoregulating unit. Temperature (body) sensors are placed on the patient's skin to measure surface temperature and in the rectum, nasopharynx or esophagus to measure core temperature. The operator selects the desired patient core temperature (between 30-40°C) and the unit automatically controls it via a feedback loop. The heating / cooling unit is based on a solid-state thermo-electric device, which operates as a heat pump
The system is essentially portable, vibration free and quiet. It is designed to be connected to a standard 120 /230 VAC supply. The device is placed near the patient. Tubing is connected to both the unit and the garment (worn by the patient) and the unit is switched on. The operator selects the desired body temperature, which the unit then automatically and autonomously regulate.
CritiCool is used with CureWrap Gaments with sizes equivalent to the sizes of the gaments of the Allon 2001 Version 5, predicated device K024128.
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Body Sensors:
The body sensors are the same sensors as those of the already cleared device with its former label of Allon 2001 Version 5. Therefore, there are no new issues of safety and effectiveness associated with these sensors
Indications for Use:
The CritiCool is a thermal regulating system, indicated for monitoring and controlling patient temperature.
Intended Use
The Intended Use of the CritiCool monitor as indicated above is the same as the Indications for use
The following table shows all the existing CureWrap garments:
| No. | ModelNo. | Maximum GarmentHeight, m | Maximum GarmentWidth, m | GarmentArea, sq. m. |
|---|---|---|---|---|
| 1 | 3521 | 0.698 | 0.602 | 0.347 |
| 2 | 3525 | 0.981 | 0.628 | 0.425 |
| 3 | 3531 | 1.118 | 0.740 | 0.637 |
| 4 | 3536 | 1.225 | 0.841 | 0.763 |
| 5 | 3541 | 1.390 | 1.054 | 1.089 |
| 6 | 3548 | 1.582 | 1.193 | 1.399 |
| 7 | 3500 | 2.030 | 1.354 | 2.324 |
Product Specifications *****
Listed below are the major attributes of the CritiCool compares to the predicate, ArcticSun and Allon 2001version 5.
| Specifications | ArcticSun | Allon 2001Version 5 | CritiCool |
|---|---|---|---|
| FDA approval | K071341 | K024128 | This application |
| Specifications | ArcticSun | Allon 2001Version 5 | CritiCool |
| Control Modes | Automatic, Manual,Purge, Stop | Automatic | Automatic |
| Heater Capability | 750 W | 500W | 500W |
| Circulating Fluid | Distilled or SterileWater | Tap Water | Tap Water |
| Reservoir Capacity | 5 liters | 6 liters ( 1.6 gal) | 6 liters (1.6 gal) |
| Heat exchanger | Jell Pads | Garment | Garment |
| Water flow rate (total) | 0.5 - 8.0 Liter/min | 1-1.2 Liter/min | 1-1.2 Liter/min |
| Patient Probe Type | YSI 400 Seriescompatible | YSI 400 Seriescompatible | YSI 400 Seriescompatible |
| Patient Temperature Inputs | 2 | 2 – CoretemperatureSurfacetemperature | 2 – CoretemperatureSurfacetemperature |
| Patient Temperature DisplayRange | 10°C to 44°C,(50°F to 111.2°F)in 0.1°C/°F steps | 18.5°C to 43.9°C(65.3°F to111.0°F)in 0.1°C/°F steps | 18.5°C to43.9°C(65.3°F to111.0°F)in 0.1°C/°Fsteps |
| Patient TemperatureMeasurementAccuracy | ±0.4°C 10 to 32°C±0.2°C 32 to 38°C±0.4°C 38 to 44°C | ±0.3°C (0.4°F) | ±0.3°C (0.4°F) |
| Patient Temperature ControlRange - Automatic Mode | 32°C to 38.5°C(89.6° F to 101.3°F)in 0.1°C/Fincrements | 30°C to 40°C(86°F to 104°F)in 0.1°C/Fincrements | 30°C to 40°C(86°F to 104°F)in 0.1°C/Fincrements |
| Water Temperature DisplayRange | 3°C to 45°C(37.4°F to 113.0°F )in 0.1°C/F | 9°C to 44°C(48.2°F to111.2°F)in 0.1°C/F | 9°C to 44°C(48.2°F to111.2°F)in 0.1°C/F |
| Water Temperature ControlRange Manual Mode | 4°C to 42°C | N/A | N/A |
| Specifications | ArcticSun | Allon 2001Version 5 | CritiCool |
| (39.2°F to 107.6°F)in 0.1°C/Fincrements | |||
| Maximum WaterTemperature (AutomaticMode) | 36°C to 42°C96.8°F to 107.6°Fin 1°C/F increments | 40.8°C (105.4°F) | 40.8°C(105.4°F) |
| Minimum WaterTemperature (AutomaticMode) | 4°C to 25°C39.2°F to 77°Fin 1°C/F increments | 13°C (55.4°F) | 13°C (55.4°F) |
| Mains Input* | 115VAC, 60 Hz,11.0 A (nominal)230VAC, 50 Hz,5.5 A | 230/115 VAC500W 50/60 Hz6.3 amp | 230/115 VAC500W 50/60 Hz6.3 amp |
| Current Leakage | < 300uA | < 150uA | < 150uA |
| Circuit Breaker | 12.0 Amp | 2 X 6.3 Amp fuse | 2 X 6.3 Ampfuse |
| Data output | Yes | Yes | Yes |
| Operating relative humidityrange | 5 - 70% | 10%-100% | 10%-100% |
| Storage relative humidityrange | 5 - 95% non-condensing | 10%-100% | 10%-100% |
| Operating temperature range | 10°C to 27°C(50°F to 80°F) | 30°C to 40°C (50-104°F) | 30°C to 40°C(50-104°F) |
| Storage temperature range | -30°C to - 50°C(20°F to 120°F) | -40°C to 70°C( 40°F to 158°F) | -40°C to 70°C( 40°F to158°F) |
| Height (handle down) | 30" (76cm) | 24.4" (62 cm) | 24.4" (62 cm) |
| Length | 22" (56cm) | 24.6" (62.5 cm) | 24.6" (62.5 cm) |
| Width | 12.5" (32cm) | 10.23" (26 cm) | 10.23" (26 cm) |
| Weight when filled | 116 lbs (53kg.) | 86 lbs (39 Kg) | 86 lbs (39 Kg) |
| Alarm Limits | |||
| Water Temperature High | 42.5°C / 44°C | 42°C | 42°C |
| Specifications | ArcticSun | Allon 2001Version 5 | CritiCool |
| Alarm | (108.5° F / 111.2°F) | ||
| Water Temperature LowAlarm | 3.5°C (38.3°F) | 10°C | 10°C |
| System Patient TemperatureHigh Alarm | 39.5°C (103.1°F) | 38.5°C (101.3°F) or 2°C above set point | 38.5°C (101.3°F) or2°C above setpoint |
| System Patient TemperatureLow Alarm | 31.0°C (87.8°F) | 35.5°C (95.9°F) or0.5°C below setpoint | 35.5°C (95.9°F) or 0.5°C below set point |
| Adjustable PatientTemperature High Alert | 10.1°C to 44°C(50.1°F to 111.2°F) | N/A | N/A |
| Adjustable PatientTemperature Low Alert | 10.0°C to41.9°C to107.5°F | N/A | N/A |
| Patient Probe Fault AlarmShort or Open | Yes | Yes | Yes |
| Water flow Alert 50% ofcase maximum | Yes | Yes | Yes |
| System Water TemperatureHigh Alarm | 43.0°C/ 44°C | 42°C | 42°C |
| (109.4°F/ 111.2°F) | |||
| System Water TemperatureLow Alarm | 3.0°C (37.4°F) | 10°C | 10°C |
| Reservoir level Alert thenAlarm Low then Empty | Yes | Yes | Yes |
| System Self Test AlarmAt power up | Yes | Yes | Yes |
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Food and Drug Administration
Traditional 510(k) for CritiCool System
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Food and Drug Administration
Traditional 510(k) for CritiCool System
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Food and Drug Administration Traditional 510(k) for CritiCool System
Materials Materials James Bron
The material used for the CureWrap garments are :
- Water Barrier Film -- Appelton MPE Grade #S6606 .
- Non-Woven PP (Avgol Ltd.) .
- Frontal Tape FT 600 .
{6}------------------------------------------------
Materials were tested and proven for biocompatibility. (see part 15)
Indications for Use:
The CritiCool is a thermal regulating system, indicated for monitoring and controlling patient temperature. Intended Use
*The Intended Use of the CritiCool monitor as indicated above is the same as the Indications For Use
Over-The-Counter Use _ NO AND/OR Prescription Use YES (21 CFR 801 Subpart C) (Part 21 CFR 801 Subpart D)
Confidentiality
MTRE Advanced Technology Ltd. considers its intent to market the CritiCool System to be confidential commercial information.
The Company, therefore, requests the FDA not disclose the existence of this application until such time as final action on the submission is taken.
In addition, some of the material in this application may be trade secret or confidential commercial or financial information within the meaning of 21 CFR § 20.61 and therefore not disclosable under the Freedom of Information Act, even after the existence of the application becomes public. We ask that FDA consult with the Company as provided in 21 CFR § 20.45 before making any part of this submission publicly available.
Signature:
Stat. Oren.
Ifat Oren OA & Regulatory Affairs MTRE Advanced Technology Ltd. +972-8-9323333 ext. 213 Tel: +972-8-9328510 Fax: E-mail: Ifat oren@mmi.co.il
{7}------------------------------------------------
Public Health Service
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
MAR 2 6 2009
MTRE Advanced Technology Ltd. c/o Ms. Ifat Oren QA & Regulatory Affairs 4 Havarden Street Yavne, 81228, Isracl
Re: K083662
CritiCool Regulation Number: 21 CFR 870.5900 Regulation Name: System, Thermal Regulating Regulatory Class: Class II Product Code: DWJ Dated: March 9, 2009 Received: March 11, 2009
Dear Ms. Oren:
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.
{8}------------------------------------------------
Page 2 - Ms. Ifat Oren
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 (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. 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 (240) 276-0120. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding postmarket surveillance, please contact CDRH's Office of Surveillance and Biometrics' (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 yours,
uma D. Wachner
^ Bram D. Zuckerman, M.D. Division Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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.
Indications for Use
510(k) Number (if known): Ko83662
Device Name: CritiCool
Indications For Use:
The CritiCool is a thermal regulating system, indicated for monitoring and controlling patient temperature.
. ... . . . . . . . . . . . . . . . . . . . . . . .
*The Intended Use of the CritiCool monitor as indicated above is the same as the Indications For Use
Prescription Use _YES (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use NO (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)
Quna R. Vochmes
Page 1 of 1
Ivision Sign-Off Division of Cardiovascular Devices
510(k) Number Ko8366
§ 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).