(29 days)
The GlidePath™ 13F long-term hemodialysis catheters are indicated for use in attaining short-term or long-term vascular access for hemodialysis, hemoperfusion or apheresis therapy. Access is attained via the internal jugular vein, subclavian vein, or femoral vein. Catheters longer than 34 cm are intended for femoral vein insertion.
The GlidePath™ 13F Long-Term Hemodialysis Catheter is a vascular access device, intended for use in attaining short-term or long-term vascular access for hemodialysis, hemoperfusion or apheresis therapy and features a dual-lumen, optimized double-D cross-sectional catheter shaft with a fixed symmetrical tip design. The catheter has separate arterial and venous lumens, a molded bifurcation and, extending from the bifurcation, arterial (red) luer and venous (blue) luer and extension legs which connect to an external dialysis machine or blood cleansing device. Each extension leg has an atraumatic occlusion clamp which closes access to the lumen. The symmetrical catheter tip contains holes that aid in the distribution of blood flow and aid in overthe-guidewire placement. The GlidePath™ 13F Long-Term Hemodialysis Catheters are packaged in a tray with legally marketed accessories intended for use during catheter placement. The device is intended for single patient use only.
The provided text describes a 510(k) premarket notification for a medical device, the GlidePath™ 13F Long-Term Hemodialysis Catheter. This submission aims to demonstrate substantial equivalence to a legally marketed predicate device, the GlidePath™ Long-Term Hemodialysis Catheter (K190527).
The document details various performance tests conducted to support this claim, but it does not describe a study involving an AI/Machine Learning algorithm or human reader improvement with AI assistance. Therefore, many of the requested items related to AI device performance and clinical studies are not applicable or cannot be answered from the provided text.
The acceptance criteria mentioned are general ("met all predetermined acceptance criteria for design verification activities as specified by applicable standards, guidance, test protocols and/or customer inputs") rather than specific quantitative metrics for an AI model's performance.
Here's an analysis based on the provided text, addressing the applicable points:
Acceptance Criteria and Device Performance
The document states that the device "met all predetermined acceptance criteria for design verification activities as specified by applicable standards, guidance, test protocols and/or customer inputs." However, a specific table of quantitative acceptance criteria and reported numerical performance values is not provided in the text. The performance data section lists the types of tests conducted:
| Test Characteristic / Performance Criteria | Reported Device Performance |
|---|---|
| Catheter Tensile | Met acceptance criteria (Implied: results demonstrate substantial equivalence) |
| Catheter Tip Stiffness | Met acceptance criteria (Implied: results demonstrate substantial equivalence) |
| Catheter Tip Damage after Flexure | Met acceptance criteria (Implied: results demonstrate substantial equivalence) |
| Flow Rate | Met acceptance criteria (Implied: results demonstrate substantial equivalence) |
| Recirculation | Met acceptance criteria (Implied: results demonstrate substantial equivalence) |
| Mechanical Hemolysis | Met acceptance criteria (Implied: results demonstrate substantial equivalence) |
| Catheter Assembly Leak | Met acceptance criteria (Implied: results demonstrate substantial equivalence) |
| Catheter Burst | Met acceptance criteria (Implied: results demonstrate substantial equivalence) |
| Surface Inspection | Met acceptance criteria (Implied: results demonstrate substantial equivalence) |
| Stylet to Luer Tensile | Met acceptance criteria (Implied: results demonstrate substantial equivalence) |
| Stylet Assembly Leak | Met acceptance criteria (Implied: results demonstrate substantial equivalence) |
| Catheter to Tunneler Rod Tensile | Met acceptance criteria (Implied: results demonstrate substantial equivalence) |
| Tunneler Rod Malleability | Met acceptance criteria (Implied: results demonstrate substantial equivalence) |
Note: The text explicitly states that "The results from these tests performed in accordance with standards and FDA guidance, demonstrate that the technical characteristics and performance criteria of the GlidePath™ 13F Long-Term Hemodialysis Catheter is substantially equivalent to the predicate..."
Study Details (Applicable to Non-AI Device Testing)
This document describes a submission for a traditional medical device (a catheter), not specifically an AI/Machine Learning device. Therefore, many of the questions related to AI study design (like training/test sets, ground truth establishment for AI, expert consensus for AI interpretation, MRMC studies) are not directly applicable to this premarket notification. The "performance data" refers to physical and functional performance testing of the catheter itself, not diagnostic or clinical accuracy.
- Sample sizes used for the test set and the data provenance: The document does not specify the number of units tested for each characteristic (e.g., how many catheters were subjected to tensile testing). It also does not discuss "data provenance" in the context of clinical data for an AI model, as this is a physical device.
- Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. Ground truth in this context would be objective physical measurements or established engineering standards, not expert clinical interpretation.
- Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable.
- 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, as this is not an AI-powered device under review.
- If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable, as this is not an AI-powered device under review.
- The type of ground truth used (expert consensus, pathology, outcomes data, etc.): For the performance tests listed, the "ground truth" would be the established engineering and medical device standards (e.g., ISO standards, FDA guidance on non-clinical testing) against which the catheter's physical/functional properties were measured.
- The sample size for the training set: Not applicable, as this is not an AI device that requires a training set.
- How the ground truth for the training set was established: Not applicable, as this is not an AI device.
In summary, the provided document is a 510(k) premarket notification for a physical medical device (a hemodialysis catheter) and details its engineering and physical performance testing to demonstrate substantial equivalence to a predicate device, rather than the performance of an AI/ML algorithm.
§ 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.