K Number
K121248
Date Cleared
2013-12-13

(597 days)

Product Code
Regulation Number
882.5550
Panel
NE
Reference & Predicate Devices
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The LiquoGuard CSF system is indicated for the external drainage of cerebrospinal fluid (CSF). It connects to any drainage catheter (not part of the product) which is usually inserted by the doctor into the lateral or third ventricle of the brain or lumbar subarachnoid space in selected patients to reduce intracranial pressure. The LiquoGuard CSF system controls CSF pressure using pressure sensors and a pump, thus taking the role of the conventional CSF dripping chamber and collection bag (predicate devices). The LiquoGuard CSF system also monitors intracranial pressure up to 75 mmHg and cerebrospinal fluid flow during CSF drainage, and provides many alarm functions not offered by the passive dripping chamber systems.

Device Description

The LiquoGuard CSF System consists of a pump and a corresponding tube set with pressure sensors. The dynamic range of this system is from -15mmHg to +75 mmHg. The tube set is inserted into the pump, connected to the intrathecal drainage catheter (not part of the product) via Luer-Lock and the LiquoGuard CSF System device via cable connector. The device then continuously measures the pressure inside the tube and operates a tube pump whenever the actual pressure is higher than a preselected target pressure. Thus the LiquoGuard CSF System combines CSF drainage and intracranial pressure (ICP) monitoring with integrated alarm and documentation/data logging functions, improving safety, simplifying the handling and enhancing patient mobility (by its battery back-up).

AI/ML Overview

Acceptance Criteria and Device Performance for LiquoGuard CSF System (K121248)

The provided document describes the Moller Medical LiquoGuard CSF System, which is indicated for external drainage and monitoring of cerebrospinal fluid (CSF). The acceptance criteria for this device are established through a combination of bench tests and a comparative clinical study against predicate devices.

1. Table of Acceptance Criteria and Reported Device Performance

The acceptance criteria are implicitly defined by the successful completion of the bench tests and the demonstration of equivalence in adverse event rates during the clinical study. No specific numerical thresholds for acceptance were explicitly stated beyond "all tests passed according to the predetermined pass/fail criteria."

Acceptance Criteria CategorySpecific Test/CriterionReported Device Performance
Pressure MeasurementAbsence of sensor drift during packaging / sterilizationPassed
Absence of sensor drift during ageingPassed
Precision of displayed pressure at various pump rates and pressure loadsPassed
Pressure RegulationEndurance test with in-vitro simulated patientPassed
Performance comparison with drip chamberPassed
Reliability of pump shut-off with negative pressuresPassed
Device functions independent of positioningPassed
Volume and Flow MeasurementPrecision of total volume and flow (pump rate) measurementPassed
Alarm Functions (Patient Condition)Pressure alarmsPassed
Pulsation alarm (e.g., catheter occlusion, collapsed ventricles, disconnected catheter)Passed
Pressure too constant alarm (e.g., catheter occlusion, collapsed ventricles, disconnected catheter)Passed
Influence of pressure on catheter wallsPassed
Detection of clogged catheterPassed
Alarm Functions (Device Functions)Defective/disconnected sensorsPassed
Disconnected/leaking tube setPassed
Battery lowPassed
Main controller/watchdog cross-checkPassed
Double safetyPassed
Tube set too oldPassed
Battery defectivePassed
Mechanical Handling and OperationDisposable check for single-usePassed
Wrong tube set insertionPassed
Opening of front panelPassed
Disposable check for agePassed
EnduranceAutomatic switch to battery upon power failurePassed
Tube set durabilityPassed
OtherExternal connectivityPassed
Clinical Equivalence (Adverse Events)Total rates of incidence of adverse events compared to predicate devices"Very close, with most small variations in favor of the LiquoGuard." Supports equivalence.

2. Sample Size Used for the Test Set and Data Provenance

  • Sample Size (Clinical Study): 413 patient records.
  • Data Provenance: The records were collected from "several hospitals," indicating a multi-center study. The clinical study combines "similar, independent studies," suggesting a retrospective collection and aggregation of existing patient data rather than a new prospective study exclusively for this submission. The country of origin of the data is not explicitly stated in the provided text.

3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications

The document does not specify the number or qualifications of experts used to establish ground truth for the clinical study. The clinical study compares "adverse events" between the LiquoGuard and predicate devices, implying that these events were recorded as part of standard clinical practice.

4. Adjudication Method for the Test Set

The document does not specify an adjudication method (e.g., 2+1, 3+1, none) for the clinical study's adverse event data. It mentions identifying and comparing rates of incidence, which suggests a quantitative analysis of pre-recorded data rather than a consensus-based adjudication process for individual cases.

5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

No, a multi-reader multi-case (MRMC) comparative effectiveness study was not conducted. The study focused on comparing adverse event rates between the device and predicate devices in a clinical setting, not on assessing human reader performance with or without AI assistance.

6. Standalone (Algorithm Only) Performance

The device is not an AI-driven diagnostic algorithm. It is a medical device that combines hardware (pump, sensors) and software for CSF drainage and monitoring. Therefore, a standalone (algorithm only) performance study as typically understood for AI/CAD devices was not performed. Its performance is assessed through the comprehensive bench tests and clinical comparison.

7. Type of Ground Truth Used for the Test Set

The ground truth for the "test set" (clinical study) was based on clinical outcomes data, specifically "adverse events" recorded in patient records resulting from CSF drainage using either the LiquoGuard or predicate drip chambers.

8. Sample Size for the Training Set

The document does not explicitly mention a "training set" as would be typical for machine learning models. The device's development and validation relied on engineering principles, bench testing, and a clinical comparison to existing devices. Therefore, a specific sample size for a "training set" in the context of an AI/ML model is not applicable from the provided information.

9. How the Ground Truth for the Training Set Was Established

As there is no explicit mention of a training set in the context of machine learning, the question of how its ground truth was established is not directly applicable. The device's functionality is based on established fluid dynamics, pressure sensing, and pump control mechanisms. Its design and performance would have been refined through iterative engineering development and testing against specifications derived from medical requirements and predicate device functions.

§ 882.5550 Central nervous system fluid shunt and components.

(a)
Identification. A central nervous system fluid shunt is a device or combination of devices used to divert fluid from the brain or other part of the central nervous system to an internal delivery site or an external receptacle for the purpose of relieving elevated intracranial pressure or fluid volume (e.g., due to hydrocephalus). Components of a central nervous system shunt include catheters, valved catheters, valves, connectors, and other accessory components intended to facilitate use of the shunt or evaluation of a patient with a shunt.(b)
Classification. Class II (performance standards).