K Number
K192659
Date Cleared
2019-10-21

(26 days)

Product Code
Regulation Number
880.5725
Panel
HO
Reference & Predicate Devices
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Omnipod DASH Insulin Management System is intended for subcutaneous delivery of insulin at set and variable rates for the management of diabetes mellitus in persons requiring insulin.

Additionally, the Omnipod DASH System is interoperable with a compatible blood glucose meter to receive and display glucose measurements.

The Omnipod Insulin Management System is intended for subcutaneous delivery of insulin at set and variable rates for the management of diabetes mellitus in persons requiring insulin and for the quantitative measurement of glucose in fresh whole capillary blood (in vitro) from the finger.

The glucose measurements should not be used for the diagnosis of or screening for diabetes. The PDM glucose meter is intended for single-patient use and should not be shared.

Abbott FreeStyle test strips are used with the built-in FreeStyle meter for the quantitative measurement of blood glucose in fresh whole capillary blood from the finger, upper arm and palm. Abbott Freestyle Control Solutions are used to verify that the meter and test strips are working together properly and that the test is performed correctly.

Device Description

The subject devices provide for the management of insulin therapy by patients with diabetes mellitus. The devices are comprised of two primary components: the disposable insulin infusion pump (Pod) and an associated wireless remote controller referred to as the Personal Diabetes Manager (PDM). The PDMs incorporates a suggested bolus calculator which aids the user in determining the insulin bolus dosage needed based on carbohydrates ingested, most recent blood glucose reading, programmable correction factor, insulin to carbohydrate ratio, target blood glucose value, and Insulin on Board (IoB).

The Pod is a body-wearable insulin pump that affixes to the user on the back of the arm, the lower back or abdomen, the thigh area, or any site that has a layer of fatty tissue available. It is held in place by an adhesive pad and provides up to three days of insulin before it is removed and replaced with a new Pod. The PDM is a handheld device that controls the Pod. The user interfaces with the device system through the PDM, where they control basal and bolus delivery and various insulin program settings and calculations. The PDM also has a food library to assist with carbohydrate calculations, and it maintains several variables in a history log for the viewer to track their diabetes therapy. The Omnipod Insulin Management System PDM has an integrated blood glucose meter and communicates with the Pod using wirelessly using secure, low power, bi-directional radio frequency (RF) communications at 433.92MHz. The Omnipod DASH Insulin Management System PDM does not have an integrated blood glucose meter, but is interoperable with a compatible blood glucose meter to receive and display glucose measurements. The Omnipod DASH PDM communicates to the Pod and a compatible blood glucose meter using Bluetooth Low Energy.

The systems are for prescription use only.

AI/ML Overview

This document is a 510(k) premarket notification for the Omnipod Insulin Management System and Omnipod DASH Insulin Management System. It primarily discusses a labeling change to add Fiasp U100 insulin as compatible and asserts substantial equivalence to a previously cleared device (K182630). Therefore, the information typically found for acceptance criteria and a study proving device performance in a de novo or original 510(k) submission (which often includes specifics on a clinical trial or performance study with detailed metrics) is not present here.

Based on the provided document, I can extract the following relevant information regarding acceptance criteria and studies:

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

The document does not provide a table with specific quantitative acceptance criteria or detailed reported device performance metrics in the way a clinical study report would. Instead, it states that:

  • Acceptance Criteria Mentioned: "Verification activities, as required by the risk analysis, demonstrated that the predetermined acceptance criteria were met and the devices are safe for use." However, the specific criteria themselves are not listed.
  • Reported Device Performance:
    • "Drug Stability and Compatibility; In-use stability and leachables testing was conducted with Fiasp U100 insulin to verify and validate that the systems do not adversely affect the insulin."
    • "Fiasp stability testing in Omnipod Pods"
    • "Leachables study"

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

The document does not specify the sample sizes for the stability and leachables testing, nor does it provide information about the provenance of the data (e.g., country of origin, retrospective or prospective nature).

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 applicable to the type of testing described (drug stability and leachables) and is therefore not present in the document. These tests are laboratory-based and do not involve expert interpretation or ground truth establishment in the same way a diagnostic device might.

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

This information is not applicable to the type of testing described (drug stability and leachables) and is therefore not present in the document.

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 applicable. The device is an insulin management system, not an AI-assisted diagnostic tool requiring MRMC studies.

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

This information is not applicable in the context of the described modifications. The primary device function (insulin delivery) is not an algorithm-only standalone performance that would be assessed in this manner for the stated purpose of the submission. The "dose calculator" is mentioned within the context of the PDM, implying human interaction.

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

For the stability and leachables testing, the "ground truth" would be established by scientific analytical methods (e.g., chemical assays, chromatography) to measure insulin degradation, chemical composition of leachates, and ensure the drug substance remains within predefined acceptable ranges, as per established pharmaceutical and medical device testing standards. The document does not explicitly detail these laboratory "ground truth" methods but refers to "Fiasp stability testing in Omnipod Pods" and a "Leachables study."

8. The sample size for the training set

The document describes a 510(k) submission for a modification (labeling change for compatible insulins) to existing devices. There is no mention of a "training set" as would be used for machine learning or AI algorithm development because that is not the nature of this submission. The testing described (stability, leachables) does not involve training sets.

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

As there is no "training set" reported for this submission, this question is not applicable.

§ 880.5725 Infusion pump.

(a)
Identification. An infusion pump is a device used in a health care facility to pump fluids into a patient in a controlled manner. The device may use a piston pump, a roller pump, or a peristaltic pump and may be powered electrically or mechanically. The device may also operate using a constant force to propel the fluid through a narrow tube which determines the flow rate. The device may include means to detect a fault condition, such as air in, or blockage of, the infusion line and to activate an alarm.(b)
Classification. Class II (performance standards).