(156 days)
The Isopure Sodium Bicarbonate Mixing and Distribution System is intended to be used in Hemodialysis facilities for the mixing, storage and distribution of Bicarb liquid concentrate to be used in the treatment of Hemodialysis patients.
The Isopure Sodium Bicarbonate Mixing and Distribution System is designed to mix sodium bicarbonate powder into a liquid solution based on the recommended mixing procedures from the powder manufacturers. Once the powder is mixed into a liquid solution and verified for content accuracy, the solution is transferred to an independent distribution tank for transfer through a loop to the individual dialysis machines or to fill jugs which then can be transported to the individual dialysis machines when no distribution loop exists. The Isopure Sodium Bicarbonate Mixing and Distribution System features the patented SOLUBILIZER™, which utilizes a large volume of water spinning in a vortex manner to dissolve dry powder into a liquid solution that is drawn into a mix tank. The solution is mixed with AAMI quality water according to specifications outlined by the manufactures for the bicarbonate powder. Once the solution has been dissolved and mixed, the solution can be transferred from the mixing tank to the storage delivery tank for distribution to the loop or jugs. The tanks and the SOLUBILIZER™ are sealed to reduce microbial contamination. The sealed design also facilitates CO2 recovery and gassing off of CO2 during the mixing procedure. The entire system is controlled by programmable control logic (PLC), which operates the system. The PLC will control the mixing, the delivery and disinfection of the complete system. The system PLC is operated through an HMI touch screen which displays the critical aspects of the system. including the operational stages, real-time indication of various steps, and alarm conditions.
The provided text describes a 510(k) premarket notification for the Isopure Sodium Bicarbonate Mixing and Distribution System. This type of submission focuses on demonstrating substantial equivalence to a legally marketed predicate device, rather than proving safety and effectiveness through extensive de novo clinical trials. Therefore, the information typically requested in your prompt (e.g., acceptance criteria with reported device performance in a table, sample sizes for test/training sets, number and qualifications of experts for ground truth, MRMC studies, standalone performance, type of ground truth) is not explicitly present in the provided document.
The document primarily focuses on comparing the technological characteristics of the new device to its predicate and outlining non-clinical testing performed to establish equivalence.
Here's an analysis based on the available information:
1. Table of Acceptance Criteria and Reported Device Performance:
The document doesn't present a table with explicit acceptance criteria and corresponding reported device performance metrics in the format typically used for performance studies. Instead, it states that the system "was tested repeatedly for proper operation" and "each mix batch was tested for the target conductivity of the solution to confirm the correct mixture."
The implied acceptance criterion is:
- Target conductivity of the solution: The mixed sodium bicarbonate solution must achieve the "target conductivity" to confirm correct mixture.
The reported device performance is:
- "each mix batch was tested for the target conductivity of the solution to confirm the correct mixture, and then transferred to the Distribution Tank."
- "The distribution function was then tested to ensure that circulation of the solution through the loop occurred as expected."
- "The system has undergone 100% testing to ensure substantial equivalence to the Pure Water, Inc. predicate device. Both systems are fully capable of meeting the mix requirements specified for a suitable sodium bicarbonate solution."
2. Sample Size Used for the Test Set and Data Provenance:
- Sample Size: The document does not specify a numerical sample size for the test set. It states the system "was tested repeatedly" and "each mix batch was tested for the target conductivity." This suggests multiple batches were tested for each selectable volume.
- Data Provenance: The testing was non-clinical. The "testing area consists of all components of a water room that would normally be present at a dialysis clinic." It utilized "the same brand of bicarbonate typically used in an operating clinic." This implies the testing environment and materials were representative of real-world use within a dialysis facility. The country of origin for the data is implicitly the US, as the submitter is an American company and the approval is from the US FDA. The testing was prospective within the context of the device development and validation.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of those Experts:
- Experts: Not applicable. The "ground truth" for the device's function (correct mixing and distribution) was established through objective measurements (conductivity) and functional assessments (circulation). This is a technical performance verification, not a clinical interpretation requiring expert consensus.
4. Adjudication Method for the Test Set:
- Adjudication Method: Not applicable. The "ground truth" (correct mixture via conductivity, proper circulation) was determined by direct measurement and observation, not expert review or adjudication.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done:
- MRMC Study: No, an MRMC comparative effectiveness study was not done. This device is a medical equipment system for mixing and distributing solutions, not an imaging or diagnostic device that would involve human readers interpreting cases.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done:
- Standalone Performance: Not applicable in the context of typical AI/algorithm standalone performance. The device itself is an automated system controlled by a PLC, and its performance was assessed directly. There isn't a separate "algorithm" for human-in-the-loop interaction in the way AI diagnostics are often evaluated. The testing described focuses on the machine's ability to execute its programmed functions (mixing, distribution) correctly and automatically.
7. The Type of Ground Truth Used:
- Type of Ground Truth: The ground truth was based on objective technical measurements and functional verification. Specifically:
- Conductivity Readings: To confirm the correct mixture of the sodium bicarbonate solution (compared against a target conductivity).
- Functional Assessment: To ensure proper circulation of the solution through the distribution loop.
- Compliance with Manufacturer Recommendations and Standards: Adherence to powder manufacturers' recommendations and AAMI RD52-2004 requirements for mixing procedures.
8. The Sample Size for the Training Set:
- Training Set Sample Size: Not applicable. This device is not an AI/machine learning model in the conventional sense that would require a "training set" of data to learn from. Its operation is governed by pre-programmed logic (PLC) and engineering design, not statistical learning from a dataset.
9. How the Ground Truth for the Training Set was Established:
- Training Set Ground Truth: Not applicable, as there is no training set for this type of device. The operating parameters and expected performance are established through engineering specifications, manufacturer guidelines, and relevant industry standards (like AAMI RD52-2004).
§ 876.5820 Hemodialysis system and accessories.
(a)
Identification. A hemodialysis system and accessories is a device that is used as an artificial kidney system for the treatment of patients with renal failure or toxemic conditions and that consists of an extracorporeal blood system, a conventional dialyzer, a dialysate delivery system, and accessories. Blood from a patient flows through the tubing of the extracorporeal blood system and accessories to the blood compartment of the dialyzer, then returns through further tubing of the extracorporeal blood system to the patient. The dialyzer has two compartments that are separated by a semipermeable membrane. While the blood is in the blood compartment, undesirable substances in the blood pass through the semipermeable membrane into the dialysate in the dialysate compartment. The dialysate delivery system controls and monitors the dialysate circulating through the dialysate compartment of the dialyzer.(1) The extracorporeal blood system and accessories consists of tubing, pumps, pressure monitors, air foam or bubble detectors, and alarms to keep blood moving safely from the blood access device and accessories for hemodialysis (§ 876.5540) to the blood compartment of the dialyzer and back to the patient.
(2) The conventional dialyzer allows a transfer of water and solutes between the blood and the dialysate through the semipermeable membrane. The semipermeable membrane of the conventional dialyzer has a sufficiently low permeability to water that an ultrafiltration controller is not required to prevent excessive loss of water from the patient's blood. This conventional dialyzer does not include hemodialyzers with the disposable inserts (Kiil type) (§ 876.5830) or dialyzers of high permeability (§ 876.5860).
(3) The dialysate delivery system consists of mechanisms that monitor and control the temperature, conductivity, flow rate, and pressure of the dialysate and circulates dialysate through the dialysate compartment of the dialyzer. The dialysate delivery system includes the dialysate concentrate for hemodialysis (liquid or powder) and alarms to indicate abnormal dialysate conditions. This dialysate delivery system does not include the sorbent regenerated dialysate delivery system for hemodialysis (§ 876.5600), the dialysate delivery system of the peritoneal dialysis system and accessories (§ 876.5630), or the controlled dialysate delivery system of the high permeability hemodialysis system § 876.5860).
(4) Remote accessories to the hemodialysis system include the unpowered dialysis chair without a scale, the powered dialysis chair without a scale, the dialyzer holder set, dialysis tie gun and ties, and hemodialysis start/stop tray.
(b)
Classification. (1) Class II (performance standards) for hemodialysis systems and all accessories directly associated with the extracorporeal blood system and the dialysate delivery system.(2) Class I for other accessories of the hemodialysis system remote from the extracorporeal blood system and the dialysate delivery system, such as the unpowered dialysis chair, hemodialysis start/stop tray, dialyzer holder set, and dialysis tie gun and ties. The devices subject to this paragraph (b)(2) are exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.