(266 days)
The Hudson RCI® Addipak® Unit Dose Vial, 0.9% Full Normal Saline Solution may be used in conjunction with a non-ventilatory nebulizer for lavage therapy, or for tracheal irrigation.
Hudson RCI® AddiPak® Unit Dose Vial, 0.9% Full Normal Saline Solution is a pre-filled vial of sterile 0.9% saline for inhalation therapy. The content of this product is a 0.90% sodium chloride solution (normal saline). Vials are factory-sealed, made of translucent, color-coded polyethylene, and are available in three sizes (3mL, 5mL, and 15mL). These products are single-use, disposable, and intended for inhalation only.
Hudson RCI® AddiPak® Unit Dose Vial, 0.9% Full Normal Saline Solution filled with sterile saline solutions conforms to the specifications of the USP monograph for Sodium Chloride Inhalation Solution.
Hudson RCI® AddiPak® Unit Dose Vial, 0.9% Full Normal Saline Solution have a perforated, break-away twist cap for dispensing the solution. When twisted by the user, the cap breaks away and opens a small hole for solution to pass through. The Hudson RCT® AddiPak® Unit Dose Vial, 0.9% Full Normal Saline Solution are designed with inverted graduations to allow the clinician to read volume while dispensing the solution.
This document is a 510(k) Pre-market Notification for a medical device called the "Hudson RCI® AddiPak® Unit Dose Vial, 0.9% Full Normal Saline Solution." This type of submission is for demonstrating substantial equivalence to a predicate device, not for proving the safety and efficacy of a novel device through extensive clinical trials.
Therefore, the provided document does not contain the kind of information typically associated with AI/ML diagnostic device studies. Specifically, it lacks:
- Acceptance Criteria for AI Performance: There's no AI model, so no performance metrics like sensitivity, specificity, AUC, F1-score, etc., are defined or measured.
- Sample Size for Test/Training Sets, Data Provenance, Ground Truth Experts/Methods, MRMC Studies, Standalone Performance: These are all concepts related to the evaluation of AI algorithms, which are not applicable to this saline solution product.
Instead, this document describes a non-clinical evaluation comparing a new saline solution product to existing, legally marketed predicate devices. The goal is to demonstrate that the new device is "substantially equivalent" and raises no new questions of safety or effectiveness.
Here's a breakdown of the relevant information provided in the document regarding the acceptance criteria and study for the saline solution product:
1. Table of Acceptance Criteria and Reported Device Performance
The document doesn't present acceptance criteria and performance in a single table for the saline solution itself. Instead, it outlines bench testing conducted to ensure the proposed device performs as intended and is substantially equivalent to predicate devices. The "performance" is demonstrated by meeting the standards of these non-clinical tests.
| Test Performed | Principle of Test | Acceptance Criteria (Implied) | Reported Device Performance (Implied) |
|---|---|---|---|
| Leak Test | Leak detection in polyethylene vial by vacuum method | No leaks detected | "performed to verify that the performance...will perform as intended." (No leaks detected) |
| Twist-Off Test | A manual removal of the twist-off cap to ensure proper dispensing of solution when inverted and squeezed | Cap twists off easily, and solution dispenses properly | "performed to verify that the performance...will perform as intended." (Cap functions as designed) |
| Ship Test | Shipping simulation (ISTA 1A) to ensure vials are damage-free and do not leak | Vials are damage-free and do not leak after shipping simulation | "performed to verify that the performance...will perform as intended." (Vials withstand shipping simulation successfully) |
| Biocompatibility | Cytotoxicity, irritation, sensitization, genotoxicity, and implantation testing (ISO 10993-1) | All patient-contacting materials comply with ISO 10993-1 | "All patient contacting materials are in compliance with ISO 10993-1." |
| Material Testing | USP <661> physiochemical test for plastics (nonvolatile residue, heavy metals, buffering capacity) | Meet USP <661> criteria | "found to meet the criteria for nonvolatile residue, heavy metals and buffering capacity." |
| Solution Purity | Conforms to USP monograph for Sodium Chloride Inhalation Solution | Conforms to USP specifications | "conforms to the specifications of the USP monograph for Sodium Chloride Inhalation Solution." |
| Sterilization | Per USP <71> | Meets USP <71> sterility requirements | "Per USP <71>" (implies compliance) |
2. Sample Size Used for the Test Set and Data Provenance
- Test Set Sample Size: Not explicitly stated for each test. The testing is non-clinical bench testing.
- Data Provenance: The tests are conducted in a laboratory setting by the manufacturer (Teleflex Medical, Inc.). This is likely an internal, prospective study as part of the product development and regulatory submission. No country of origin for "data" in the sense of patient data is applicable.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts
Not applicable. There is no "ground truth" established by experts in the context of an AI/ML diagnostic device. The evaluation relies on standardized physical, chemical, and biological tests for product performance and safety.
4. Adjudication Method for the Test Set
Not applicable. There is no "adjudication" in the context of human expert disagreement on interpretations for an AI model. The tests have objective pass/fail criteria.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
Not applicable. This is not an AI/ML diagnostic device, and thus no MRMC study, human reader improvement with AI, or effect size is relevant.
6. Standalone Performance Study
Not applicable in the context of AI. The device is the saline solution itself, and its performance is evaluated in a standalone manner via bench testing as detailed in point 1.
7. The Type of Ground Truth Used
Not applicable in the AI sense. The "ground truth" for this product's evaluation is defined by:
- Physical characteristics (e.g., absence of leaks, proper cap function).
- Chemical specifications (e.g., 0.90% sodium chloride solution, meeting USP monograph).
- Biocompatibility standards (e.g., ISO 10993-1).
- Sterility standards (e.g., USP <71>).
8. The Sample Size for the Training Set
Not applicable. This is not an AI/ML device, so there is no training set.
9. How the Ground Truth for the Training Set Was Established
Not applicable. This is not an AI/ML device, so there is no training set or ground truth establishment for it.
In summary: This document is a regulatory submission for a simple medical device (a saline solution) demonstrating its substantial equivalence to previously approved devices through non-clinical bench testing and adherence to recognized standards. It does not involve any artificial intelligence or machine learning components, and thus the questions pertinent to AI device evaluation are not addressed.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
April 29, 2015
Teleflex Medical, Inc. James A. Cochie Sr. Regulatory Affairs Specialist 2917 Weck Drive Research Triangle Park, NC 27709
Re: K142153
Trade/Device Name: Hudson RCI® AddiPak® Unit Dose Vial, 0.9% Full Normal Saline Solution Regulation Number: 21 CFR 868.5630 Regulation Name: Nebulizer (Direct Patient Interface) Regulatory Class: II Product Code: CAF Dated: March 30, 2015 Received: April 1, 2015
Dear Mr. Cochie:
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.
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Page 2 - Mr. Cochie
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 contact the Division of Small Manufacturers, International and Consumer Assistance at its tollfree number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm. 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/ResourcesforYou/Industry/default.htm.
Sincerely yours,
Teiashri Purohit-Sheth, M.D.
Tejashri Purohit-Sheth, M.D. Clinical Deputy Director DAGRID/ODE/CDRH FOR
Erin I. Keith, M.S. Division Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
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Indications for Use
510(k) Number (if known)
Device Name
Hudson RCI® Addipak® Unit Dose Vial, 0.9% Full Normal Saline Solution
Indications for Use (Describe)
The Hudson RCI® Addipak® Unit Dose Vial, 0.9% Full Normal Saline Solution may be used in conjunction with a non-ventilatory nebulizer for lavage therapy, or for tracheal irrigation.
Type of Use (Select one or both, as applicable)
2 Prescription Use (Part 21 CFR 801 Subpart D)
_ Over-The-Counter Use (21 CFR 801 Subpart C)
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FOR FDA USE ONLY
Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)
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Section 25 - 510(k) Summary
510(k) SUMMARY
Hudson RCI® AddiPak® Unit Dose Vial, 0.9% Full Normal Saline Solution
A. Name, Address, Phone and Fax Number of Applicant
Teleflex Medical, Incorporated 2917 Weck Drive Research Triangle Park, NC 27709 USA Phone: 919-433-8083 Fax: 919-433-4996
B. Contact Person
James Cochie Sr. Regulatory Affairs Specialist
C. Date Prepared
July 25, 2014 (Revised April 28, 2015)
D. Device Name
| Trade Name: | Hudson RCI® AddiPak® Unit Dose Vial, 0.9% FullNormal Saline Solution |
|---|---|
| Common Name: | Saline Solution for Inhalation |
| Classification Name: | Nebulizer (Direct Patient Interface)CFR - 868.5630, Class II |
E. Device Description
Hudson RCI® AddiPak® Unit Dose Vial, 0.9% Full Normal Saline Solution is a pre-filled vial of sterile 0.9% saline for inhalation therapy. The content of this product is a 0.90% sodium chloride solution (normal saline). Vials are factory-sealed, made of translucent, color-coded polyethylene, and are available in three sizes (3mL, 5mL, and 15mL). These products are single-use, disposable, and intended for inhalation only.
Hudson RCI® AddiPak® Unit Dose Vial, 0.9% Full Normal Saline Solution filled with sterile saline solutions conforms to the specifications of the USP monograph for Sodium Chloride Inhalation Solution.
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Section 25 – 510(k) Summary
Hudson RCI® AddiPak® Unit Dose Vial, 0.9% Full Normal Saline Solution have a perforated, break-away twist cap for dispensing the solution. When twisted by the user, the cap breaks away and opens a small hole for solution to pass through. The Hudson RCT® AddiPak® Unit Dose Vial, 0.9% Full Normal Saline Solution are designed with inverted graduations to allow the clinician to read volume while dispensing the solution.
F. Indications for Use
The Hudson RCI® AddiPak® Unit Dose Vial, 0.9% Full Normal Saline Solution may be used in conjunction with a non-ventilatory nebulizer for lavage therapy, or for tracheal irrigation.
G. Target Population
This device is intended for use on any patient requiring lavage therapy or tracheal irrigation.
H. Environments of Use
This device is intended for home, hospital, and sub-acute facilities.
This product is single use only.
I. Contraindications
There are no known contraindications.
J. Comparative Equivalence Characteristics
The proposed Hudson RCI® AddiPak® Unit Dose Vial, 0.9% Full Normal Saline Solution is substantially equivalent to the predicate devices:
| ComparativeCharacteristics | Proposed Device,Hudson RCI®AddiPak® Unit DoseVial, 0.9% FullNormal SalineSolution | Predicate Device,Hudson RCI®AddiPak® Unit DoseVial, 0.9% FullNormal SalineSolution | Predicate Device,NephronPharmaceuticals,Sodium ChlorideSolution USP, 0.9% |
|---|---|---|---|
| Manufacturer | Teleflex Medical, Inc. | Teleflex Medical, Inc. | NephronPharmaceuticals |
| 510(k) Number | K142153 | Pre-amendment | K113033 |
| Indications forUse | The Hudson RCI®AddiPak® Unit DoseVial, 0.9% Full NormalSaline may be used inconjunction with a | The Hudson RCI®AddiPak® Unit DoseVial, 0.9% FullNormal Saline maybe used in | Sterile, single usedevice is intended tobe used as anaccessory tomedicinal |
Teleflex Medical, Inc.
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| non-ventilatorynebulizer for lavagetherapy, or fortracheal irrigation. | conjunction with anon-ventilatorynebulizer for lavagetherapy, or trachealirrigation | nonventilatorynebulizers forrespiratory therapy orfor tracheal irrigationor lavage therapy | |
|---|---|---|---|
| Prescription | Yes | Yes | Yes |
| Environment ofUse | Home, hospital, sub-acute facilities | Home, hospital, sub-acute facilities | Home, hospital, sub-acute facilities |
| PatientPopulation | Any patient requiringlavage therapy ortracheal irrigation | Any patient requiringlavage therapy ortracheal irrigation | Same |
| Contraindications | None | None | None |
| Materials in FluidContact | Vial LDPE - DuPontDPE-20 and DowHEALTH+ 692 | Vial LDPE - DuPontDPE-20 andCelanese EVA 7110 | Vial LDPE |
| Solutions | 0.90% SalineInhalation Solution,USP: 3ml, 5ml, 15ml | 0.90% SalineInhalation Solution,USP: 3ml, 5ml, 15ml | 0.9% SalineInhalation Solution,USP: 3ml, 5ml |
| Vial Design | Pinched seambetween vial and capfor openingNozzle openingdesign to keepcontents within wheninvertedRaised invertedgraduations | Pinched seambetween vial and capfor openingNozzle openingdesign to keepcontents within wheninvertedRaised invertedgraduations | Pinched seambetween vial and capfor openingNozzle openingdesign to keepcontents within wheninvertedRaised invertedgraduations |
| ManufacturingProcess | Per USP monographBlow-Fill-Seal asepticprocess | Per USP monographBlow-Fill-Seal asepticprocess | Per USP monographBlow-Fill-Seal asepticprocess |
| Sterilization | Per USP <71> | Per USP <71> | Per USP <71> |
| Single Use | Yes | Yes | Yes |
| Shelf Life | 2 years from date ofmanufacture | 2 years from date ofmanufacture | Unknown |
| Packaging | 3ml and 5ml vialspackaged 100/box, 10boxes/case15ml vials packaged48/box, 3 boxes/case | 3ml and 5ml vialspackaged 100/box, 10 boxes/case15ml vials packaged48/box, 3 boxes/case | 3ml and 5ml vialspackaged 100/box or30 individuallywrapped and bar-coded vials |
Section 25 – 510(k) Summary
K. Non-clinical Comparative Performance Testing
Bench testing has been performed to verify that the performance of the proposed Hudson RCI® AddiPak® Unit Dose Vial, 0.9% Full Normal Saline Solution is substantially equivalent to the predicate devices, and that the Hudson RCI® AddiPak® Unit Dose Vial, 0.9% Full Normal Saline Solution will perform as intended.
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| TestPerformed | Reference to Standard (ifapplicable) | Principle of Test |
|---|---|---|
| Leak Test | N/A | Leak detection in polyethylene vial byvacuum method |
| Twist-OffTest | N/A | A manual removal of the twist-off cap toensure proper dispensing of solutionwhen inverted and squeezed |
| Ship Test | ISTA 1A | Shipping simulation to ensure vials aredamage-free and do not leak |
Section 25 - 510(k) Summary
All patient contacting materials are in compliance with ISO 10993-1. Testing included cytotoxicity, irritation, sensitization, genotoxicity and implantation testing.
In addition, the vial material was tested to USP <661> physiochemical test for plastics and found to meet the criteria for nonvolatile residue, heavy metals and buffering capacity.
L. Substantial Equivalence
The proposed Hudson RCI® AddiPak® Unit Dose Vial, 0.9% Full Normal Saline Solution is substantially equivalent in intended use for lavage therapy and tracheal irrigation, design, performance and principles of operation to the identified predicate devices. The differences between the Hudson RC1® AddiPak® Unit Dose Vial, 0.9% Full Normal Saline Solution and the predicate devices are minor and raise no new issues of safety and efficacy. The Hudson RC1® AddiPak® Unit Dose Vial, 0.9% Full Normal Saline Solution are substantially equivalent to the currently marketed predicate device.
§ 868.5630 Nebulizer.
(a)
Identification. A nebulizer is a device intended to spray liquids in aerosol form into gases that are delivered directly to the patient for breathing. Heated, ultrasonic, gas, venturi, and refillable nebulizers are included in this generic type of device.(b)
Classification. Class II (performance standards).