(144 days)
The Epidrum is intended for use in epidural procedures between a luer syringe and an epidural needle to give a clear visual signal that the needle tip has entered the epidural space.
The Epidrum is intended for use, in conjunction with an epidural needle, to verify the needle tip placement in the epidural space.
The Epidrum comprises a small chamber, featuring a female Luer inlet port and a male Luer exit port on opposing sides, with an expandable membrane as one of the sides between the ports. The Epidrum is a single use device, manufactured from medical grade polymers.
The provided text is a 510(k) summary for the Epidrum device and does not contain detailed information about a study proving its acceptance criteria, or the specific performance metrics typically found in such studies for AI/ML devices. The Epidrum is a medical device designed to visually signal when an epidural needle has entered the epidural space. The filing focuses on demonstrating substantial equivalence to a predicate device rather than presenting a performance study against specific acceptance criteria.
Therefore, the requested information, particularly regarding acceptance criteria, study data, sample sizes, ground truth establishment, expert qualifications, adjudication methods, and MRMC/standalone studies, cannot be extracted from this document as it pertains to AI/ML device evaluations.
The document primarily compares the Epidrum to a predicate device (Avid-Nit Loss of Resistance Syringe) based on intended use, indications for use, and technological principles (loss of resistance). It concludes that the Epidrum operates on the same principle despite using visual cues instead of tactile feedback, and therefore "raises no new questions of safety and effectiveness."
Summary of available information (as per the prompt's request, but acknowledging the limits of the document):
- Acceptance Criteria and Reported Device Performance: Not explicitly stated as the primary focus is on substantial equivalence to a predicate device.
- Sample Size for Test Set and Data Provenance: Not applicable as no performance study data is presented.
- Number of experts and qualifications to establish ground truth for the test set: Not applicable.
- Adjudication method for the test set: Not applicable.
- Multi Reader Multi Case (MRMC) comparative effectiveness study: No, this type of study is not described.
- Standalone (algorithm only without human-in-the-loop performance) study: No, as this is a mechanical device, not an algorithm.
- Type of ground truth used: Not applicable.
- Sample size for the training set: Not applicable.
- How the ground truth for the training set was established: Not applicable.
However, the document does contain the following relevant comparisons to a predicate device:
1. A table of acceptance criteria and the reported device performance
| Criteria/Aspect | Epidrum (Device Under Review) | Avid-Nit Loss of Resistance Syringe (Predicate Device) |
|---|---|---|
| Intended Use | Intended for use in epidural procedures between a Luer syringe and an epidural needle to give a clear visual signal that the needle tip has entered the epidural space. | Intended for use, in conjunction with an epidural needle, to verify the needle tip placement in the epidural space by the Loss of Resistance technique as explained in standard medical textbooks. |
| Indications for Use | Intended for use, in conjunction with an epidural needle, to verify the needle tip placement in the epidural space. | Intended for use, in conjunction with an epidural needle, to verify the needle tip placement in the epidural space. |
| Technological Differences | The design incorporates an expandable membrane which deflates when the needle tip enters the epidural space giving an instantaneous, clear, visual signal. | The loss of resistance to the plunger of the syringe, when the distal tip of the needle penetrates the epidural space, is sensed by touch via the user's thumb. |
| Conclusion of Equivalence | Although the Epidrum uses different senses of the user (visual:touch) from the Loss of Resistance Syringe mentioned above, it operates on precisely the same loss of resistance principle, has the same intended use and raises no new questions of safety and effectiveness. |
The study that "proves the device meets the acceptance criteria" in this context is the 510(k) submission itself, which argues for substantial equivalence to a predicate device (Avid-Nit Loss of Resistance Syringe, K001731) based on comparison of intended use, indications for use, and operating principle. The "acceptance criteria" here are implicitly related to the requirements for substantial equivalence, which primarily involve demonstrating that the new device is as safe and effective as a legally marketed predicate device. No specific clinical trial or performance study data comparing the Epidrum's visual signal performance against a predefined numerical acceptance threshold is provided.
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KOS3863
MAY 1 0 2010
510k Summary of Epidrum
Owner:
ﺬ
ﺔ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤﺘﺤﺪﺓ ﺍﻟﻤ
Exmoor Plastics Limited Lisieux Way Taunton Somerset TA1 2LB United Kingdom
Contact: Patrick East 044823 351040 Telephone: 044823 326240 Fax: Email: Margaret.Blackmore@exmoorltd.com Patrick.east@exmoorltd.com
| Prepared on: | 29th September 2009 |
|---|---|
| -------------- | --------------------- |
Trade Name: Epidrum
Common Name: Loss of Resistance Device
ll
Classification Name: Piston syringe
Class:
Regulation Number: 880.5860
Product Code: FMF
Device Description: The Epidrum comprises a small chamber, featuring a female Luer inlet port and a male Luer exit port on opposing sides, with an expandable membrane as one of the sides between the ports.
The Epidrum is a single use device, manufactured from medical grade polymers.
- Intended use: The Epidrum is intended for use in epidural procedures between a luer syringe and an epidural needle to give a clear visual signal that the needle tip has entered the epidural space.
Indications for Use:
The Epidrum is intended for use, in conjunction with an epidural needle, to verify the needle tip placement in the epidural space.
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| Equivalent Device: | Avid-Nit Loss of Resistance Syringe |
|---|---|
| 510K Number: | K001731 |
| Manufacturer: | Avid Medical Inc.9000 Westmont DriveStonehouse Commerce ParkToanoVirginia 23168 |
| Comparison: | Epidrum | Avid-nit LOR Syringe |
|---|---|---|
| IntendedUse | Intended for use between aLuer syringe and an epiduralneedle to give a clear visualsignal that the needle tip hasentered the epidural space. | Intended for use, in conjunctionwith an epidural needle, to verifythe needle tip placement in theepidural space by the Loss ofResistance technique as explainedin standard medical textbooks. |
| IndicationsFor Use | The AVID-NIT Loss of ResistanceSyringe is intended for use, in |
The Epidrum is intended for use, in conjunction with an epidural needle to verify the needle tip placement in the epidural space.
Syringe is intended for use, in conjunction with an epidural needle, to verify the needle tip placement in the epidural space
Technological
- Differences: The design incorporates an expandable membrane which deflates when the needle tip enters the epidural space giving an instantaneous, clear, visual signal.
The loss of resistance to the plunger of the syringe, when the distal tip of the needle penetrates the epidural space, is sensed by touch via the user's thumb.
Conclusion: Although the Epidrum uses different senses of the user (visual:touch) from the Loss of Resistance Syringe mentioned above, it operates on precisely the same loss of resistance principle, has the same intended use and raises no new questions of safety and effectiveness.
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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 features a stylized caduceus, a symbol often associated with medicine and healthcare, with three overlapping lines forming a stylized shape. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular fashion around the caduceus symbol. The logo is black and white.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
Ms. Margaret Blackmore Exmoor Plastics LTD Lisieux Way Taunton, Somerset United Kingdom TA1 2LB
MAY 1 0 2010
Re: K093863
Trade/Device Name: EPIDRUM Regulation Number: 21 CFR 880.5860 Regulation Name: Piston Syringe Regulatory Class: II Product Code: FMF Dated: March 26, 2010 Received: April 27, 2010
Dear Ms. Margaret Blackmore:
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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
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. Margaret Blackmore
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); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); 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.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to
http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.html for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
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) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely yours,
Susan Farrar
Anthony D. Watson, B.S., M.S., M.B.A. Director
Division of Anesthesiology, General Hospital, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Exmoor Epidrum
.
Section 4 Page 1
xmoo
Indications for Use
510(k) Number (if known):
Epidrum Device Name:
Indications For Use:
The Epidrum is intended for use, in conjunction with an epidural needle, to verify the needle tip placement in the epidural space.
Prescription Use YES (Part 21 CFR 801 Subpart D) 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)
L Schuth
(Division Sign-Off) Division of Anesthesiology, General Hospital infection Control, Dental Devices
Page 1 of 1
1093863 510(k) Number:
§ 880.5860 Piston syringe.
(a)
Identification. A piston syringe is a device intended for medical purposes that consists of a calibrated hollow barrel and a movable plunger. At one end of the barrel there is a male connector (nozzle) for fitting the female connector (hub) of a hypodermic single lumen needle. The device is used to inject fluids into, or withdraw fluids from, the body.(b)
Classification. Class II (performance standards).