(90 days)
The BAROnova Access Sheath Kit is used in conjunction with an endoscope for procedures requiring multiple insertions of the endoscope into the upper gastrointestinal tract, with or without instruments through the instrument chamel of the endoscope.
The BAROnova Access Sheath Kit is used in conjunction with the TransPyloric Shuttle Delivery Device to facilitate insertion and positioning of the device during TPS delivery and deployment.
The Access Sheath Kit is NOT indicated for foreign body removal or instrument use alongside the endoscope.
The BAROnova Access Sheath Kit includes the following products:
- BAROnova Access Sheath (with obturator)
- Endoscope (Seal) Cap
- Insufflation Syringe
The BAROnova Access Sheath consists of a clean, non-sterile mated Obturator/Access Sheath Assembly. The Access Sheath is composed of thinwalled tubing, a handle and a distal cuff and balloon with an atraumatic tip. The Obturator is made of flexible tubing with an atraumatic tip. The Seal Cap consists of a non-sterile, plastic cap for use with standard endoscopes. A 10cc syringe is also provided with the Access Sheath Kit to enable balloon inflation and deflation.
This document is a 510(k) summary statement for the BAROnova Access Sheath Kit. It's a regulatory submission to the FDA demonstrating that a new device is substantially equivalent to a legally marketed predicate device. This type of document generally focuses on comparing the new device to existing ones and providing non-clinical performance data (e.g., bench testing) to support safety and effectiveness, rather than detailed clinical study data with acceptance criteria for device performance in a clinical setting.
Therefore, much of the requested information about clinical acceptance criteria, sample sizes, expert ground truth, adjudication methods, and human reader studies is not available in this document. This submission emphasizes technological equivalence and non-clinical performance.
Here's an analysis of the provided text in relation to your request:
1. Table of acceptance criteria and reported device performance:
Based on the provided text, specific numerical acceptance criteria (e.g., minimum tensile strength, maximum leakage rate) for design verification tests are not explicitly stated in this summary. The document broadly states that the device "meet all requirements."
| Acceptance Criteria (Conceptual based on listed tests) | Reported Device Performance |
|---|---|
| Dimensional requirements met | Met all requirements |
| Mechanical performance requirements met | Met all requirements |
| Balloon integrity requirements met | Met all requirements |
| Shaft wall integrity requirements met | Met all requirements |
| Seal cap functionality requirements met | Met all requirements |
| Simulated use performance requirements met | Met all requirements |
| Biocompatibility requirements met | Met all requirements |
| Animal study performance met (safety/functionality) | Met all requirements |
2. Sample size used for the test set and the data provenance:
- Sample Size for Test Set: Not specified for any of the non-clinical tests.
- Data Provenance: The tests are non-clinical (bench testing, simulated use, animal study) and were conducted by BAROnova, Inc. (the manufacturer). The country of origin for the data generation is not explicitly stated but would likely be the location of the manufacturing and testing facilities. It is inherently "retrospective" in the sense that the tests were performed to validate the device's design before submission.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable/Not specified. For non-clinical tests (dimensional, mechanical, etc.), "ground truth" is typically established by engineering specifications and objective measurements, not expert consensus in the clinical sense. For the animal study, the assessment would be made by veterinary or medical professionals participating in the study, but their number and specific qualifications are not detailed.
4. Adjudication method for the test set:
- Not applicable/Not specified. Adjudication methods (like 2+1, 3+1) are typically used in clinical studies with human assessors to resolve discrepancies in diagnoses or interpretations. Non-clinical tests usually involve objective measurements against predefined specifications.
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:
- No. This document describes a medical device (an access sheath kit), not an AI-powered diagnostic or assistive tool. Therefore, an MRMC study comparing human readers with and without AI assistance is not relevant and was not performed.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
- No. As noted above, this is a physical medical device, not a standalone algorithm.
7. The type of ground truth used:
- For non-clinical tests (e.g., dimensional, mechanical, balloon integrity, shaft wall integrity, seal cap functionality), the "ground truth" is typically engineering specifications, design requirements, and quantifiable measurements. Deviations from these specifications are considered failures.
- For the simulated use and animal studies, "ground truth" would relate to the observed functional performance, safety, and any adverse events or complications during the simulated or animal procedures, assessed against expected outcomes and safety profiles.
8. The sample size for the training set:
- Not Applicable. This is a physical medical device, not a machine learning algorithm that requires a "training set."
9. How the ground truth for the training set was established:
- Not Applicable. No training set was used.
Summary of what is present:
The document primarily focuses on demonstrating substantial equivalence to predicate devices based on:
- Identical Indications for Use.
- Identical Technological Characteristics (design, materials, construction) to the predicate BAROnova Access Sheath, and the included Seal Cap and Syringe being standard components.
- Non-clinical testing: This included dimensional, mechanical, balloon integrity, shaft wall integrity, seal cap functionality, simulated use, animal, and biocompatibility studies. The outcome of these tests was that the devices "met all requirements" and were found to be safe and effective for their intended use.
This 510(k) submission is a device-specific regulatory filing for a physical medical product, not a software or AI-driven product, which explains the absence of information related to clinical studies, expert adjudication, or AI performance metrics.
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July 23, 2019
BAROnova, Inc. Lian Cunningham Senior Vice President, Clinical Affairs 1551 Industrial Road San Carlos, CA 94070
Re: K191078 Trade/Device Name: BAROnova Access Sheath Kit Regulation Number: 21 CFR 21 CFR 876.1510 Regulation Name: Anchored Esophageal Sheath Regulatory Class: Class II Product Code: QGG, FED, OCX, FMF Dated: April 22, 2019 Received: April 23, 2019
Dear Lian Cunningham:
This letter corrects our substantially equivalent letter of July 22, 2019.
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. However, you are responsible to determine that the medical devices you use as components in the kit have either been determined as substantially equivalent under the premarket notification process (Section 510(k) of the act), or were legally on the market prior to May 28, 1976, the enactment date of the Medical Device Amendments. Please note: If you purchase your device components in bulk (i.e., unfinished) and further process (e.g., sterilize) you must submit a new 510(k) before including these components in your kit/tray. 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
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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 of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
for
Martha W. Betz, Ph.D. Acting Assistant Division Director DHT3A: Division of Renal, Gastrointestinal. Obesity and Transplant Devices OHT3: Office of Gastrorenal, ObGyn, General Hospital and Urology Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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Indications for Use
510(k) Number (if known) K191078
Device Name BAROnova Access Sheath Kit
Indications for Use (Describe)
The BAROnova Access Sheath Kit is used in conjunction with an endoscope for procedures requiring multiple insertions of the endoscope into the upper gastrointestinal tract, with or without instruments through the instrument chamel of the endoscope.
The BAROnova Access Sheath Kit is used in conjunction with the TransPyloric Shuttle Delivery Device to facilitate insertion and positioning of the device during TPS delivery and deployment.
The Access Sheath Kit is NOT indicated for foreign body removal or instrument use alongside the endoscope.
| Type of Use (Select one or both, as applicable) | |
|---|---|
| X Prescription Use (Part 21 CFR 801 Subpart D) | Over-The-Counter Use (21 CFR 801 Subpart C) |
| | Over-The-Counter Use (21 CFR 801 Subpart C)
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SECTION 5.1: 510(k) SUMMARY STATEMENT
This 510(k) summary is being submitted in accordance with the requirements of the Safe Medical Devices Act of 1990, 21 CFR 807.92.
1. General Information
Date of Submission: April 22, 2019
| Submitted By: | BAROnova, Inc.1551 Industrial RoadSan Carlos, CA 94070 |
|---|---|
| Contact Person: | Lian Cunningham, MD, PhD |
| Contact Person: | Lian Cunningham, MD, PhD |
|---|---|
| Senior VP, Regulatory and Clinical Affairs | |
| Phone 650-638-9796 ext. 22 | |
| Fax: 650-638-9094 | |
| lcunningham@baronova.com |
2. Device Information:
| Common/Usual Name: | Anchored Esophageal Sheath |
|---|---|
| Trade Name: | BAROnova Access Sheath Kit |
| Regulation Number | 876.1510 |
| Regulation Description: | Anchored Esophageal Sheath |
| Product Code: | QGG, FED, OCX, FMF |
| Device Panel: | Gastroenterology/Urology |
| Device Classification: | Class II |
3. Legally Marketed Predicate Device for Claimed Equivalence:
| Primary Predicate: | |
|---|---|
| Name: | BAROnova Access Sheath |
| Accessory | |
| Classification #: | Q181451 |
Secondary Predicates: Name: Seal Cap 510(k) #: K172575
Hypodermic Syringe Name: K980987 510(k) #:
4. Device Description
The BAROnova Access Sheath Kit includes the following products:
- BAROnova Access Sheath (with obturator) ●
- . Endoscope (Seal) Cap
- . Insufflation Syringe
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The BAROnova Access Sheath consists of a clean, non-sterile mated Obturator/Access Sheath Assembly. The Access Sheath is composed of thinwalled tubing, a handle and a distal cuff and balloon with an atraumatic tip. The Obturator is made of flexible tubing with an atraumatic tip. The Seal Cap consists of a non-sterile, plastic cap for use with standard endoscopes. A 10cc syringe is also provided with the Access Sheath Kit to enable balloon inflation and deflation.
5. Indications for Use Statement
The BAROnova Access Sheath Kit is used in conjunction with an endoscope for procedures requiring multiple insertions of the endoscope into the upper gastrointestinal tract, with or without instruments through the instrument channel of the endoscope.
The BAROnova Access Sheath Kit is used in conjunction with the TransPyloric Shuttle Delivery Device to facilitate insertion and positioning of the device during TPS delivery and deployment.
The Access Sheath Kit is NOT indicated for foreign body removal or instrument use alongside the endoscope.
6. Substantial Equivalence Comparison
Indications for Use:
The BAROnova Access Sheath Kit has the same indication for use as the predicate BAROnova Access Sheath, thus substantial equivalence is met. No changes have been made to the indication for use for the Endoscope (Seal) Cap and Syringe included within the Access Sheath Kit for convenience. Technological Characteristics:
No changes from the predicate devices have been made to the design, materials, or construction of the BAROnova Access Sheath, Endoscope (Seal) Cap and Syringe included with the BAROnova Access Sheath Kit. The Access Sheath, Endoscope (Seal) Cap and Syringe are packaged together as a convenience kit.
7. Summary of Performance Data (Non-clinical testing)
Non-clinical testing of the subject devices for structural and functional use has been performed, including dimensional, mechanical, balloon integrity, shaft wall integrity, seal cap functionality, simulated use, animal and biocompatibility. The subject devices were found to meet all requirements.
The results of the testing performed demonstrate that the BAROnova Access Sheath Kit is safe and effective when used in accordance with its intended use and labeling.
8. Conclusion
Substantial equivalence of the BAROnova Access Sheath Kit is supported by a comparison of the intended use, indications for use, design and materials with the predicate devices as well as acceptable results from verification and validation tests.
N/A