K Number
K123813
Manufacturer
Date Cleared
2013-01-18

(38 days)

Product Code
Regulation Number
870.1200
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The VPS Stylet and Console are indicated for guidance and tip positioning for central venous catheters. The Console is intended for use with the stylet supplied by VasoNova. The Vascular Positioning System consists of a Console and associated power supply and cabling and a stylet. The VPS Console, when used with the VPS Stylet, provides real-time catheter tip location information by using the patient's physiological (cardiac electrical activity and blood flow) information. When the Vascular Positioning System guidance indicator shows a Blue Bullseye, the catheter tip is in the desired location. The Vascular Positioning System is indicated for use as an alternative method to fluoroscopy or chest x-ray for central venous catheter tip placement confirmation in adult patients. NOTE: If a steady blue bull's eye is not obtained, standard hospital practice should be followed to confirm catheter tip location.

Limiting but not contraindicated situations for this technique are in patients where alterations of cardiac rhythm change the presentation of the P-wave as in atrial fibrillation, atrial flutter, severe tachycardia and pacemaker-driven rhythm, and in central venous catheterization procedures performed through femoral or saphenous vein access which change the presentation of the P-wave. In such patients, who are easily identifiable prior to central venous catheter insertion, the use of an additional method is required to confirm catheter tip location.

Device Description

The VPS System consists of a VPS Console with tablet display and a VPS Stylet. The VPS G4 Console consists of two key integrated software-driven components: a data acquisition module and an embedded computer with processing capabilities. The data acquisition module within the console transmits and receives ultrasound data while receiving electrical signals from the heart through sensors mounted at the tip of the VPS Stylet. Using signals gathered by the data acquisition module, the graphical user interface provides the user with guidance for tip positioning of central venous access devices. The separately provided VPS Stylet is a polyimide tube containing a Doppler sensor on a coax cable and an intravascular electrocardiogram (ivECG) signal sensing stainless steel wire. The Doppler sensor and the exposed portion of the ivECG are located at the distal end of the stylet and are used to detect and transmit physiological information to the VPS Console for analysis. The proximal end of the stylet connects to an extension cable that connects to the VPS Console.

AI/ML Overview

The provided text describes the 510(k) summary for the Vascular Positioning System™ (VPS™) G4 Console. It does not contain a comprehensive study proving the device meets specific acceptance criteria in the way a clinical trial report would. Instead, it focuses on demonstrating substantial equivalence to a predicate device (K103260 VasoNova Vascular Positioning System™ (VPSTM) Console) by showing that the technological characteristics are similar and that the device complies with relevant electrical safety, electromagnetic compatibility, and software verification/validation standards.

Therefore, many of the requested details about acceptance criteria and study methodology are not explicit in this summary. However, I can extract the information that is present and highlight what is not available from the provided text.

Here's the breakdown:

1. A table of acceptance criteria and the reported device performance

The document does not present specific clinical or performance acceptance criteria in the typical sense of metrics like sensitivity, specificity, accuracy, or positive/negative predictive values for tip placement. Instead, the "acceptance criteria" are implied by compliance with regulatory standards and verification/validation testing.

CharacteristicStandard/TestReported Device Performance
Electromagnetic CompatibilityIEC 60601-1-2: 2007-03 - Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance: Collateral standard: Electromagnetic compatibility - Requirements and testsCompliant
Electrical Safety and Acoustic SafetyIEC 60601-1:1988 (A1:1991 + A2:1995) - Medical electrical equipment - Part 1: General requirements for safety IEC 60601-1-4: 1996 (A1:1999)/EN 60601-1-4:2000- Medical electrical equipment - Part 1-4: Collateral Standard: Programmable electrical medical systems IEC 60601-2-37:2001 (A1:2004 + A2:2005) - Medical electrical equipment - Part 2-37: Particular requirements for the safety of ultrasonic medical diagnostic and monitoring equipmentCompliant
Software verification and validationVasoNova Software and Algorithm Verification and Validation testingCompliant
Guidance indicator functionalityEvaluation against the predicate device's guidance indicator (Colored icons, waveform data)Same as predicate (Colored icons, waveform data)
Guidance signal type(s)Evaluation against the predicate device's signal types (ivECG, Doppler ultrasound)Same as predicate (ivECG, Doppler ultrasound)
Signal ConductorEvaluation against the predicate device's signal conductor (Two conductor stylet wires: coax cable and ivECG wire)Same as predicate (Two conductor stylet wires: coax cable and ivECG wire)
Acoustic OutputEvaluation against the predicate device's acoustic output (One setting; not controlled by the user)Same as predicate (One setting; not controlled by the user)
User InterfaceEvaluation against the predicate device's user interface (PC-based system connected to a touchscreen tablet display)Similar to predicate (PC-based system connected to a touchscreen tablet display)
Software InterfaceEvaluation against the predicate device's software interface (Custom GUI)Same as predicate (Custom GUI)

The primary "performance" stated is that the device is compliant with safety and functionality standards and is "substantially equivalent" to its predicate in terms of safety, efficacy, and performance. The intended use also specifies that: "When the Vascular Positioning System guidance indicator shows a Blue Bullseye, the catheter tip is in the desired location." However, performance data demonstrating the accuracy of this "Blue Bullseye" indication against a gold standard (like X-ray) is not provided in this 510(k) summary.

2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

This information is not provided in the given text. The filing focuses on technological equivalence and compliance with engineering standards rather than clinical performance data from a specific 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)

This information is not provided in the given text. As no specific clinical test set data is presented, there is no mention of experts establishing ground truth.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

This information is not provided in the given text.

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

This information is not provided in the given text. The device is a "Vascular Positioning System" that guides catheter placement, not an AI-assisted diagnostic tool for human readers.

6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

The device is designed for "guidance and tip positioning" of central venous catheters, meaning it provides real-time information to a human operator. The system "provides the user with guidance for tip positioning" and "When the Vascular Positioning System guidance indicator shows a Blue Bullseye, the catheter tip is in the desired location." This implies it's a human-in-the-loop system. A standalone performance assessment without human interaction is not described.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

The 510(k) summary does not describe specific ground truth data for a clinical test set. The intended use mentions that the VPS System is indicated for use "as an alternative method to fluoroscopy or chest x-ray for central venous catheter tip placement confirmation in adult patients." It also states: "If a steady blue bull's eye is not obtained, standard hospital practice should be followed to confirm catheter tip location." This implies that standard imaging (fluoroscopy or chest x-ray) would be the clinical gold standard (ground truth) if such a performance study were done, but no such study is detailed here.

8. The sample size for the training set

This information is not provided in the given text. Given that this is a 510(k) summary for a substantial equivalence determination based on technological characteristics and compliance with standards, details about machine learning training sets are typically not included unless the device's core functionality relies on a novel AI/ML algorithm that requires specific training data for its performance claims. The device relies on "physiological (cardiac electrical activity and blood flow) information" and "software algorithm to determine the symbols used to indicate catheter migration," but the details of any "training" are not specified.

9. How the ground truth for the training set was established

This information is not provided in the given text, for the reasons mentioned in point 8.

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12. 510(k) Summary

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SubmitterVasoNova, Inc., a wholly owned subsidiary of Teleflex, Inc.155 Jefferson Drive, Suite 100Menlo Park, CA 94025
Name of contact personChristine Ford, RAC
Office phone: 610-378-0131, ext. 3338Mobile phone: 484-797-7110
Fax: 610-478-3179Email: christine.ford@teleflex.com
Date summary preparedDecember 7, 2012
Device trade orproprietary nameVascular Positioning System™ (VPSTM) G4 Console
Common or usual nameCatheter, Ultrasound, Intravascular
Classification nameDiagnostic intravascular catheter, 21 CFR §870.1200, Class II, product code OBJ
Classification panelCardiovascular
Legally marketed device(s)to which equivalence isclaimedK103260 VasoNova Vascular Positioning System™ (VPSTM) Console
Device descriptionThe VPS System consists of a VPS Console with tablet display and a VPSStylet.The VPS G4 Console consists of two key integrated software-drivencomponents: a data acquisition module and an embedded computer withprocessing capabilities. The data acquisition module within the consoletransmits and receives ultrasound data while receiving electrical signals fromthe heart through sensors mounted at the tip of the VPS Stylet. Using signalsgathered by the data acquisition module, the graphical user interface providesthe user with guidance for tip positioning of central venous access devices.The separately provided VPS Stylet is a polyimide tube containing a Dopplersensor on a coax cable and an intravascular electrocardiogram (ivECG) signalsensing stainless steel wire. The Doppler sensor and the exposed portion of theivECG are located at the distal end of the stylet and are used to detect andtransmit physiological information to the VPS Console for analysis.Theproximal end of the stylet connects to an extension cable that connects to theVPS Console.
Intended use of thedeviceThe intended use of the VPS Stylet and Console (VPS System) is to quickly andaccurately guide market available central catheters to the desired location whichis the lower third of the SVC or at the cavo-atrial junction.
SUMMARY OF THE TECHNOLOGICAL CHARACTERISTICS OF THE SUBJECT DEVICE COMPARED TO THEPREDICATE DEVICE
CharacteristicPredicate VPS ConsoleSubject VPS G4 Console
Guidance indicatorColored icons, waveform dataColored icons, waveform data
Guidance signal type(s)ivECG, Doppler ultrasoundivECG, Doppler ultrasound
Signal ConductorTwo conductor stylet wires(coax cable and ivECG wire)Two conductor stylet wires(coax cable and ivECG wire)
Acoustic OutputOne setting; not controlled by the userOne setting; not controlled by the user
User InterfacePC-based system with keyboard and touch screenPC-based system connected to a touchscreen tablet display
Software InterfaceCustom GUICustom GUI
PERFORMANCE TESTS
CharacteristicStandard/TestResults Summary
Electromagnetic CompatibilityIEC 60601-1-2: 2007-03 - Medical electrical equipment - Part 1-2:General requirements for basic safety and essential performance:Collateral standard: Electromagnetic compatibility - Requirementsand testsCompliant
Electrical Safety and AcousticSafetyIEC 60601-1:1988 (A1:1991 + A2:1995) - Medical electricalequipment - Part 1: General requirements for safety IEC 60601-1-4: 1996 (A1:1999)/EN 60601-1-4:2000- Medicalelectrical equipment - Part 1-4: Collateral Standard: Programmableelectrical medical systems IEC 60601-2-37:2001 (A1:2004 + A2:2005) - Medical electricalequipment - Part 2-37: Particular requirements for the safety ofultrasonic medical diagnostic and monitoring equipmentCompliant
Software verification andvalidationVasoNova Software and Algorithm Verification and Validation testingCompliant
Conclusions:The intended use, technological characteristics, method of collecting andinterpreting physiological data, and performance of the predicate VasoNovaVPS Console and the VPS G4 Console along with testing to voluntary standardsand applicable FDA guidance documents provide evidence that the subject VPSG4 console is substantially equivalent to the predicate VPS Console in terms ofsafety, efficacy, and performance.The described physical, software, and hardware modifications are enhancementsto various aspects of the predicate VPS Console. They do not alter thefundamental scientific technology of the device; they do not alter the method inwhich physiological data is collected from the patient; they do not alter themethod in which physiological data is interpreted by the software algorithm todetermine the symbols used to indicate catheter migration through thevasculature and final tip placement. Any differences between the subject VPSG4 Console and the predicate VPS Console do not raise new issues of safety oreffectiveness.

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Image /page/2/Picture/0 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle with its wings spread, and the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged in a circular pattern around the eagle. The logo is black and white and appears to be a scanned image.

DEPARTMENT OF HEALTH & HUMAN SERVICES

Public Health Service

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-002

JAN 1 8 2013

Vasonova Inc. c/o: Christine Ford Regulatory Affairs Manager 155 Jefferson Drive, Suite 100 Menlo Park, CA 94025

Re: K123813

Trade Name: Vascular Positioning System (VPSTM) G4 Console Regulation Number: 21 CFR 870.1200 Regulation Name: Diagnostic intravascular catheter Regulatory Class: Class II Product Code: OBJ Dated: December 7, 2012 Received: December 19, 2012

Dear Ms. Ford:

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.

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Page 2 -- Ms. Christine Ford

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 (reporting of medical device-related 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.

Owen P. Faris -S

for

Bram D. Zuckerman, M.D. Director Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known): __ K123813

Vascular Positioning System (VPS™) G4 Console Device Name: _________________________________________________________________________________________________________________________________________________________________

Indications For Use:

The VPS Stylet and Console are indicated for guidance and tip positioning for central The Console is intended for use with the stylet supplied by venous catheters. VasoNova. The Vascular Positioning System consists of a Console and associated power supply and cabling and a stylet. The VPS Console, when used with the VPS Stylet, provides real-time catheter tip location information by using the patient's physiological (cardiac electrical activity and blood flow) information. When the Vascular Positioning System guidance indicator shows a Blue Bullseye, the catheter tip is in the desired location. The Vascular Positioning System is indicated for use as an alternative method to fluoroscopy or chest x-ray for central venous catheter tip placement confirmation in adult patients. NOTE: If a steady blue bull's eye is not obtained, standard hospital practice should be followed to confirm catheter tip location.

Limiting but not contraindicated situations for this technique are in patients where alterations of cardiac rhythm change the presentation of the P-wave as in atrial fibrillation, atrial flutter, severe tachycardia and pacemaker-driven rhythm, and in central venous catheterization procedures performed through femoral or saphenous vein access which change the presentation of the P-wave. In such patients, who are easily identifiable prior to central venous catheter insertion, the use of an additional method is required to confirm catheter tip location.

Prescription 'Use × (Part 21 CFR 801 Subpart D) AND/OR

Over-The-Counter Use (21 CFR 807 Subpart C)

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH; Office of In Vitro Diagnostics and Radiological Health (OIR)
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(Division Sign-Off)
Division of Cardiovascular Devices

Page 1 of

§ 870.1200 Diagnostic intravascular catheter.

(a)
Identification. An intravascular diagnostic catheter is a device used to record intracardiac pressures, to sample blood, and to introduce substances into the heart and vessels. Included in this generic device are right-heart catheters, left-heart catheters, and angiographic catheters, among others.(b)
Classification. Class II (performance standards).