(244 days)
ClearGuard HD is indicated for use as an end cap for use with hemodialysis catheter hubs.
The antimicrobial treatment on the ClearGuard HD has been shown to be effective at reducing microbial colonization in hemodialysis catheter hubs against the following microorganisms: Enterococcus faecium (VRE), Enterococcus faecalis (VRE), Acinetobacter baumannii, Escherichia coli, Staphylococcus aureus (MRSA), Staphylococcus aureus, Staphylococcus epidermidis (MRSE), Pseudomonas aeruginosa, Candida albicans and Candida parapsilosis and has not been shown to be effective against Candida paratropicalis and Klebsiella pneumoniae.
The antimicrobial effectiveness was evaluated using in vitro methods and correlation between in vitro antibacterial activity and any clinical effectiveness has not been tested. It is not intended to be used for the treatment of existing infections. The antimicrobial is only effective within the hub of the catheter, and does not migrate to distal portions of the catheter.
The ClearGuard HD end cap is male lucr lock end cap that incorporates an antimicrobial treatment on its surfaces. It is designed to reduce microbial colonization within a hemodialysis catheter hub.
The ClearGuard HD end cap consists of 1) a copolyester polymer plug, which has a rod extending from the luer region that is coated with the antimicrobial agent chlorhexidine actate (CHA) and 2) a nylon lock ring with threads that are also coated with CHA. When a ClearGuard HD end cap is inserted into a liquid-filled catheter, CHA clutes into the catheter lock solution. This CHA solution is designed to reduce the number of microorganisms in the hemodialysis catheter hub.
The catheter extension line pinch clamps are used to maintain the lock solution within the catheter lumens and minimize the risk of air embolism. These clamps, which are closed when the catheter is not in use, mechanically confine the CHA and prevent diffusion of CHA toward the catheter tip and the patient's bloodstream.
This document describes the 510(k) summary for the Pursuit Vascular, Inc. ClearGuard HD.
The information provided within the input focuses on the submission for a medical device (ClearGuard HD End Cap) for 510(k) clearance based on substantial equivalence, primarily through non-clinical testing. Therefore, many of the typical acceptance criteria and study details for AI/software-based diagnostics (e.g., sample sizes for test sets, expert consensus, MRMC studies) are not applicable in this context.
Here's an analysis of the provided information, addressing what is present and what is not applicable:
1. A table of acceptance criteria and the reported device performance
The document doesn't explicitly define "acceptance criteria" in a quantitative, pass/fail threshold manner for performance metrics like sensitivity or specificity, as one might find for a diagnostic algorithm. Instead, the "acceptance criteria" are implied by the requirements for demonstrating substantial equivalence to a predicate device.
The reported device performance primarily relates to its antimicrobial effectiveness and safety.
| Acceptance Criteria (Implied by Substantial Equivalence and Device Claims) | Reported Device Performance (Summary of Non-Clinical Testing) |
|---|---|
| Intended Use Equivalence: Same intended use as predicate device. | ClearGuard HD is indicated for use as an end cap for use with hemodialysis catheter hubs, equivalent to the end caps on the predicate (Boston Scientific Corporation Vaxcel™ Plus Chronic Dialysis Catheter). |
| Antimicrobial Effectiveness: Ability to reduce microbial colonization. | The antimicrobial treatment on the ClearGuard HD has been shown to be effective at reducing microbial colonization in hemodialysis catheter hubs against the following microorganisms (evaluated using in vitro methods): Enterococcus faecium (VRE), Enterococcus faecalis (VRE), Acinetobacter baumannii, Escherichia coli, Staphylococcus aureus (MRSA), Staphylococcus aureus, Staphylococcus epidermidis (MRSE), Pseudomonas aeruginosa, Candida albicans and Candida parapsilosis. |
(Note: Not effective against Candida paratropicalis and Klebsiella pneumoniae). The antimicrobial agent (chlorhexidine acetate) is the same as on a reference device (Arrow Antimicrobial Pressure Injectable PICC). |
| Safety: Device is safe for use and introduces no new safety concerns. | Results of design verification and validation testing demonstrate that the ClearGuard HD end cap is safe for use with hemodialysis catheters and reliably seals catheter hubs. It introduces no new or increased safety concerns compared to the predicate and reference devices. The risk assessment results confirm this. |
| Reliable Seals: Ability to reliably seal catheter hubs. | Results of design verification and validation testing demonstrate that the ClearGuard HD end cap reliably seals catheter hubs. |
| Other: Hub compatibility, sterile, non-pyrogenic, single-use. | The device meets these characteristics, making it substantially equivalent to the predicate device in these aspects. |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Not Applicable / Not Provided for Clinical Data: The submission explicitly states: "Not applicable - no clinical data was needed to demonstrate substantial equivalence to its predicate device."
- For the non-clinical (in vitro) testing of antimicrobial effectiveness and safety, the specific "sample size" of individual tests (e.g., number of cultures, number of sealing integrity tests) is not detailed in this summary. The data provenance would be laboratory-based in vitro studies.
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)
- Not Applicable: Given the absence of clinical data and the nature of the device (an end cap with antimicrobial properties), there was no "ground truth" to be established by clinical experts in the context of diagnostic accuracy. The effectiveness was assessed through in vitro microbiological methods.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not Applicable: There was no clinical imagery or diagnostic interpretation requiring an adjudication method.
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 is a physical medical device (an end cap), not an AI diagnostic algorithm. Therefore, MRMC studies and AI assistance are irrelevant to this submission.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not Applicable: This is a physical medical device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- Not Applicable / In Vitro Results: For the antimicrobial effectiveness, the "ground truth" was established by in vitro microbiological culture results (i.e., quantifying microbial colonization reduction in laboratory settings). For safety and sealing, it was established by engineering and design verification/validation testing.
8. The sample size for the training set
- Not Applicable: As this is not an AI/machine learning device, there is no concept of a "training set."
9. How the ground truth for the training set was established
- Not Applicable: There is no training set for this type of device.
§ 876.5540 Blood access device and accessories.
(a)
Identification. A blood access device and accessories is a device intended to provide access to a patient's blood for hemodialysis or other chronic uses. When used in hemodialysis, it is part of an artificial kidney system for the treatment of patients with renal failure or toxemic conditions and provides access to a patient's blood for hemodialysis. The device includes implanted blood access devices, nonimplanted blood access devices, and accessories for both the implanted and nonimplanted blood access devices.(1) The implanted blood access device is a prescription device and consists of various flexible or rigid tubes, such as catheters, or cannulae, which are surgically implanted in appropriate blood vessels, may come through the skin, and are intended to remain in the body for 30 days or more. This generic type of device includes various catheters, shunts, and connectors specifically designed to provide access to blood. Examples include single and double lumen catheters with cuff(s), fully subcutaneous port-catheter systems, and A-V shunt cannulae (with vessel tips). The implanted blood access device may also contain coatings or additives which may provide additional functionality to the device.
(2) The nonimplanted blood access device consists of various flexible or rigid tubes, such as catheters, cannulae or hollow needles, which are inserted into appropriate blood vessels or a vascular graft prosthesis (§§ 870.3450 and 870.3460), and are intended to remain in the body for less than 30 days. This generic type of device includes fistula needles, the single needle dialysis set (coaxial flow needle), and the single needle dialysis set (alternating flow needle).
(3) Accessories common to either type include the shunt adaptor, cannula clamp, shunt connector, shunt stabilizer, vessel dilator, disconnect forceps, shunt guard, crimp plier, tube plier, crimp ring, joint ring, fistula adaptor, and declotting tray (including contents).
(b)
Classification. (1) Class II (special controls) for the implanted blood access device. The special controls for this device are:(i) Components of the device that come into human contact must be demonstrated to be biocompatible. Material names and specific designation numbers must be provided.
(ii) Performance data must demonstrate that the device performs as intended under anticipated conditions of use. The following performance characteristics must be tested:
(A) Pressure versus flow rates for both arterial and venous lumens, from the minimum flow rate to the maximum flow rate in 100 milliliter per minute increments, must be established. The fluid and its viscosity used during testing must be stated.
(B) Recirculation rates for both forward and reverse flow configurations must be established, along with the protocol used to perform the assay, which must be provided.
(C) Priming volumes must be established.
(D) Tensile testing of joints and materials must be conducted. The minimum acceptance criteria must be adequate for its intended use.
(E) Air leakage testing and liquid leakage testing must be conducted.
(F) Testing of the repeated clamping of the extensions of the catheter that simulates use over the life of the device must be conducted, and retested for leakage.
(G) Mechanical hemolysis testing must be conducted for new or altered device designs that affect the blood flow pattern.
(H) Chemical tolerance of the device to repeated exposure to commonly used disinfection agents must be established.
(iii) Performance data must demonstrate the sterility of the device.
(iv) Performance data must support the shelf life of the device for continued sterility, package integrity, and functionality over the requested shelf life that must include tensile, repeated clamping, and leakage testing.
(v) Labeling of implanted blood access devices for hemodialysis must include the following:
(A) Labeling must provide arterial and venous pressure versus flow rates, either in tabular or graphical format. The fluid and its viscosity used during testing must be stated.
(B) Labeling must specify the forward and reverse recirculation rates.
(C) Labeling must provide the arterial and venous priming volumes.
(D) Labeling must specify an expiration date.
(E) Labeling must identify any disinfecting agents that cannot be used to clean any components of the device.
(F) Any contraindicated disinfecting agents due to material incompatibility must be identified by printing a warning on the catheter. Alternatively, contraindicated disinfecting agents must be identified by a label affixed to the patient's medical record and with written instructions provided directly to the patient.
(G) Labeling must include a patient implant card.
(H) The labeling must contain comprehensive instructions for the following:
(
1 ) Preparation and insertion of the device, including recommended site of insertion, method of insertion, and a reference on the proper location for tip placement;(
2 ) Proper care and maintenance of the device and device exit site;(
3 ) Removal of the device;(
4 ) Anticoagulation;(
5 ) Management of obstruction and thrombus formation; and(
6 ) Qualifications for clinical providers performing the insertion, maintenance, and removal of the devices.(vi) In addition to Special Controls in paragraphs (b)(1)(i) through (v) of this section, implanted blood access devices that include subcutaneous ports must include the following:
(A) Labeling must include the recommended type of needle for access as well as detailed instructions for care and maintenance of the port, subcutaneous pocket, and skin overlying the port.
(B) Performance testing must include results on repeated use of the ports that simulates use over the intended life of the device.
(C) Clinical performance testing must demonstrate safe and effective use and capture any adverse events observed during clinical use.
(vii) In addition to Special Controls in paragraphs (b)(1)(i) through (v) of this section, implanted blood access devices with coatings or additives must include the following:
(A) A description and material characterization of the coating or additive material, the purpose of the coating or additive, duration of effectiveness, and how and where the coating is applied.
(B) An identification in the labeling of any coatings or additives and a summary of the results of performance testing for any coating or material with special characteristics, such as decreased thrombus formation or antimicrobial properties.
(C) A Warning Statement in the labeling for potential allergic reactions including anaphylaxis if the coating or additive contains known allergens.
(D) Performance data must demonstrate efficacy of the coating or additive and the duration of effectiveness.
(viii) The following must be included for A-V shunt cannulae (with vessel tips):
(A) The device must comply with Special Controls in paragraphs (b)(1)(i) through (v) of this section with the exception of paragraphs (b)(1)(ii)(B), (b)(1)(ii)(C), (b)(1)(v)(B), and (b)(1)(v)(C), which do not apply.
(B) Labeling must include Warning Statements to address the potential for vascular access steal syndrome, arterial stenosis, arterial thrombosis, and hemorrhage including exsanguination given that the device accesses the arterial circulation.
(C) Clinical performance testing must demonstrate safe and effective use and capture any adverse events observed during clinical use.
(2) Class II (performance standards) for the nonimplanted blood access device.
(3) Class II (performance standards) for accessories for both the implanted and the nonimplanted blood access devices not listed in paragraph (b)(4) of this section.
(4) Class I for the cannula clamp, disconnect forceps, crimp plier, tube plier, crimp ring, and joint ring, accessories for both the implanted and nonimplanted blood access device. The devices subject to this paragraph (b)(4) are exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.