K Number
K100163
Manufacturer
Date Cleared
2011-10-13

(631 days)

Product Code
Regulation Number
876.5980
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

For nasogastric/oralgastric enteral feeding, incorporating safety connectors which reduce the risk of misconnections between feeding tubes and intravenous connectors.

Device Description

The Nutrisafe 2 feeding tubes are a product line extension to the existing Nutrisafe 2 feeding tubes. The subject feeding tubes are available in several sizes and in two materials. The feeding system contains a unique connection that does not incorporate a luer, reducing the risk of inadvertently connecting to intravenous connectors. The locking connection reduces the risk of involuntary disconnection; voluntary disconnection is achieved by simply unscrewing the hub connections.

AI/ML Overview

The provided text describes a 510(k) premarket notification for a medical device, the Nutrisafe 2 Feeding Tube, and its substantial equivalence to a predicate device. However, it does not involve an AI/ML device or a study that evaluates its performance against acceptance criteria in the way described in your request. The document focuses on the regulatory clearance process for a common medical device (feeding tube) based on its technological characteristics and intended use, rather than an AI algorithm's diagnostic or predictive capabilities.

Therefore, many of the requested categories in your prompt are not applicable to the provided information. I will, however, outline what can be extracted from the text in relation to your request.

Summary of Provided Information Regarding Acceptance Criteria and Study:

The provided document, K100163, is a 510(k) summary for a medical device (Nutrisafe 2 Feeding Tube), which is a product line extension. This type of regulatory submission assesses substantial equivalence to a predicate device, rather than proving performance against specific quantitative acceptance criteria of an AI model.

The "study" mentioned is a non-clinical verification through in-vitro bench testing. This type of testing ensures the device meets its specifications and intended use, primarily focusing on physical and functional characteristics suitable for a feeding tube, such as the integrity of the connection system, material compatibility, and flow rates. It does not involve human subjects, comparison to AI, or expert adjudication of outcomes.

Here's how the information aligns (or doesn't align) with your request categories:

  1. Table of Acceptance Criteria and Reported Device Performance: This kind of quantitative data (e.g., sensitivity, specificity, AUC) is not present because this is a physical medical device, not an AI/ML diagnostic tool. The general "acceptance criteria" for this device would be its ability to meet specifications for a feeding tube as determined by the in-vitro bench testing.

    Metric/CriteriaReported Device Performance
    All Specifications and Intended Use"meets all specifications and intended use."
  2. Sample size used for the test set and the data provenance: Not applicable in the context of an AI/ML device. The "test set" here would refer to the physical samples of the Nutrisafe 2 Feeding Tubes used in the in-vitro bench testing. The document does not specify the number of tubes tested, nor their manufacturing origin beyond "Vygon, Montgomeryville, PA 18936." This was in-vitro testing, not human data.

  3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. Ground truth, in the context of an AI/ML model, refers to validated diagnoses or outcomes. For a physical feeding tube, "ground truth" is established by engineering standards and functional tests. No external experts or adjudication were involved in establishing "ground truth" for the device's functional performance beyond the internal verification process.

  4. Adjudication method (e.g., 2+1, 3+1, none) for the test set: Not applicable. This method is used for resolving discrepancies in expert labeling or diagnoses for AI/ML validation datasets.

  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 study type is for evaluating the impact of AI assistance on human diagnostic performance. The Nutrisafe 2 Feeding Tube is a standalone medical device, not an AI component.

  6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done: Not applicable. This refers to the performance of an AI algorithm alone.

  7. The type of ground truth used (expert consensus, pathology, outcomes data, etc): For this device, the "ground truth" for its performance is derived from engineering specifications and in-vitro functional and safety testing results. For example, the "locking connection reduces the risk of involuntary disconnection" is a functional characteristic tested against design requirements.

  8. The sample size for the training set: Not applicable. This device does not have a "training set" in the context of AI/ML.

  9. How the ground truth for the training set was established: Not applicable.

In summary, the provided document describes a traditional medical device (feeding tube) and its regulatory clearance based on substantial equivalence and non-clinical bench testing, not an AI/ML device. Therefore, most of the detailed questions regarding AI/ML study methodologies are not relevant to this specific premarket notification.

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PREMARKET NOTIFICATION510(k) SUMMARY
(As Required By 21 CFR §807.92)
510k number:K100163
Applicant:Vygon103A Park DrMontgomeryville, PA 18936
Contact Name:Cindy VarugheseSr. Manager, Regulatory AffairsPhone: 800-473-5414Fax: 215-672-6740
Trade Name:Nutrisafe 2 Feeding Tube
Common Name:Tubes, Feeding
Regulation Number:876.5980
Product Code:FPD
Classification Name:Gastrointestinal tube and accessories devices, 21 CFR §876.5980
Regulatory Class:Class II
Predicate Device:Nutrisafe 2 Feeding Tubes, K060944
Date Prepared:March 15, 2011

Device Description:

The Nutrisafe 2 feeding tubes are a product line extension to the existing Nutrisafe 2 feeding tubes. The subject feeding tubes are available in several sizes and in two materials. The feeding system contains a unique connection that does not incorporate a luer, reducing the risk of inadvertently connecting to intravenous connectors. The locking connection reduces the risk of involuntary disconnection; voluntary disconnection is achieved by simply unscrewing the hub connections.

Intended Use:

For nasogastric/oralgastric enteral feeding, incorporating safety connectors which reduce the risk of misconnections between feeding tubes and intravenous connectors.

Technology Characteristics:

The subject Nutrisafe 2 feeding tubes have the same technological characteristics of the predicate device with the exception of the size of the tubes. The subject devices are 14, 16, and 18F, while the predicate devices range from 4F-12F. The technological characteristics are substantially equivalent to the predicate device.

Non-Clinical Summary:

Non-clinical verification of Nutrisafe 2 Feeding Tubes was conducted through in-vitro bench testing. Results of this testing indicate that the Nutrisafe 2 Feeding Tube product line extension meets all specifications and intended use.

15 March 2011

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Image /page/1/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle or bird-like figure with three curved lines representing its body and wings. The logo is encircled by the text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" in a circular arrangement.

Food and Drug Administration 10903 New Hampshire Avenue Document Mail Center - WO66-G609 Silver Spring, MD 20993-0002

Ms. Cindy Varughese Sr. Regulatory Affairs Manager Vygon 103A Park Drive MONTGOMERYVILLE PA 18936

OCT 1 3 2011

Re: K100163

Trade/Device Name: Nutrisafe 2 Feeding Tube Regulation Number: 21 CFR$ 876.5980 Regulation Name: Gastrointestinal tube and accessories Regulatory Class: II Product Code: FPD Dated: September 20, 2011 Received: September 21, 2011

Dear Ms. Varughese:

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.

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 of medical device-related

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Page 2

adverse events) (21 CFR 803); 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 advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm 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,

Hubert Lemmering

Herbert P. Lerner, M.D., Director (Acting) Division of Reproductive, Gastro-Renal and Urological Devices Office of Device Evaluation Center for Devices and Radiological Health.

Enclosure

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Indications for Use

510(k) Number (if known):

K100163

Device Name:

Indications For Use:

Nutrisafe 2 Feeding Tube

For nasogastric/oralgastric enteral feeding, incorporating safety connectors which reduce the risk of misconnections between feeding tubes and intravenous connectors.

Prescription Use X

AND/OR Over-The-Counter Use (Part 21 CFR 801 Subpart D) (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)

Avon M

(Division Sign Off) Division of Reproductive, Abdominal and Radiological Devices 510(k) Number

Page 1 of

§ 876.5980 Gastrointestinal tube and accessories.

(a)
Identification. A gastrointestinal tube and accessories is a device that consists of flexible or semi-rigid tubing used for instilling fluids into, withdrawing fluids from, splinting, or suppressing bleeding of the alimentary tract. This device may incorporate an integral inflatable balloon for retention or hemostasis. This generic type of device includes the hemostatic bag, irrigation and aspiration catheter (gastric, colonic, etc.), rectal catheter, sterile infant gavage set, gastrointestinal string and tubes to locate internal bleeding, double lumen tube for intestinal decompression or intubation, feeding tube, gastroenterostomy tube, Levine tube, nasogastric tube, single lumen tube with mercury weight balloon for intestinal intubation or decompression, and gastro-urological irrigation tray (for gastrological use).(b)
Classification. (1) Class II (special controls). The barium enema retention catheter and tip with or without a bag that is a gastrointestinal tube and accessory or a gastronomy tube holder accessory is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.(2) Class I (general controls) for the dissolvable nasogastric feed tube guide for the nasogastric tube. The class I device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to § 876.9.