(41 days)
The FreedomFlow™ Orbital Circumferential Atherectomy System is indicated for use as a therapy in patients with occlusive atherosclerotic disease in peripheral arteries. The therapy is intended for patients who are acceptable candidates for percutaneous transluminal atherectomy.
The FreedomFlow™ Orbital Circumferential Atherectomy System is a flexible over-the-wire rotational device used to ablate atherosclerotic plaque from peripheral arterial blood vessels within the body. The FreedomFlow™ System consists of three components: User Handle with integrated driveshaft, Tubing Set, and Power Supply. The User Handle with the integrated driveshaft is sterile, single use, and disposable. The User Handle provides the operator interface to control driveshaft rotation (with two speed options) and translation within the vessel. The User Handle also incorporates a guidewire mechanical clamp. The User Handle controls the saline fluid flow down the driveshaft catheter. The User Handle utilizes firmware and hardware to perform these functions. The Tubing Set is sterile, single use, and disposable. The Tubing Set connects a user provided sterile saline supply to the User Handle. The Tubing Set is connected by the operator to the User Handle. The Power Supply is a medical grade AC powered transformer, supplying DC electrical energy to the User Handle. The power supply is reusable.
This looks like a 510(k) summary for a medical device called the "FreedomFlow™ Orbital Circumferential Atherectomy System". This document focuses on demonstrating substantial equivalence of a modified device to a previously cleared predicate device, rather than providing a detailed study proving the device meets specific acceptance criteria in the way one might for a novel AI/software device.
The premise of a 510(k) is that if a new device is shown to be substantially equivalent to a legally marketed predicate device, it does not require a new Pre-Market Approval (PMA) application. Substantial equivalence is often established by demonstrating that the device has the same intended use, similar technological characteristics, and that any differences do not raise new questions of safety or effectiveness.
Therefore, the requested information about acceptance criteria, study design parameters (sample size, data provenance, expert adjudication, MRMC, standalone performance, training set details), which are common for AI/software device submissions, are largely not applicable in the context of this specific 510(k) submission.
Here's a breakdown of why this information is largely absent and what is provided:
1. A table of acceptance criteria and the reported device performance:
- Acceptance Criteria/Performance: This document does not provide a table of acceptance criteria and reported device performance in the form typically expected for AI/software evaluations (e.g., sensitivity, specificity, AUC). Instead, it establishes "substantial equivalence" to predicate devices. The "performance" being evaluated here relates to the manufacturing process change (soldering to welding) and a pump head change. The document states: "There are no performances differences incurred as a result of this change." and "Testing verifies all pump related specifications."
- Table of Comparison (from the document): The document includes a large table on pages 6-7 comparing the subject devices (H6001 & H6004 with changes) to predicate devices (H6001 [K231538] & H6004 [K233483]). This table highlights that all key characteristics, including Product Code, Classification, Intended Use, Indications for Use, Mechanism of Operation, System Components, Driveshaft Variations, Rotational Speed, Saline flow rate, Shelf life, Sterility, etc., are "Same." The core acceptance criterion for this 510(k) is demonstrating that these characteristics remain equivalent despite the manufacturing changes.
2. Sample size used for the test set and the data provenance:
- Not Applicable in this context: The document does not describe a "test set" in the sense of a clinical or image dataset for an AI algorithm. The evaluations conducted are likely engineering bench tests, biocompatibility tests, and potentially functional tests related to the manufacturing processes. Details on sample sizes for these types of tests are not typically included in the 510(k) summary provided to the public.
- Data Provenance: Not applicable as there isn't a "data set" originating from specific countries or clinical studies as would be for an AI device. The data provenance would be internal engineering and manufacturing quality control data.
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 this context. The evaluation is against engineering specifications and the established performance of the predicate device.
4. Adjudication method for the test set:
- Not Applicable: There is no "adjudication method" as this is not a subjective diagnostic or interpretative task.
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 device is a physical medical device (atherectomy system) and does not involve AI or human readers for diagnostic interpretation. Therefore, an MRMC study is completely irrelevant.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done:
- Not Applicable: This is a physical atherectomy system; it is not an algorithm.
7. The type of ground truth used:
- Ground Truth: In the context of this 510(k), the "ground truth" for the device's performance is its adherence to engineering specifications, functional requirements, and safety standards, which are themselves benchmarked against the predicate device. For example, biocompatibility testing would be compared against ISO standards, and functional tests (like rotational speed, saline flow) would be compared against their defined operational parameters.
8. The sample size for the training set:
- Not Applicable: There is no "training set" as this is not an AI/ML device.
9. How the ground truth for the training set was established:
- Not Applicable: There is no "training set."
In summary:
This 510(k) pertains to a manufacturing process change and a component change for a physical medical device (Atherectomy System). The regulatory submission demonstrates substantial equivalence to existing predicate devices by showing that these changes do not alter the intended use, indications for use, or fundamental technological characteristics, and do not raise new questions of safety or effectiveness. The detailed study parameters typically associated with AI/software device evaluation are not relevant to this type of submission.
§ 870.4875 Intraluminal artery stripper.
(a)
Identification. An intraluminal artery stripper is a device used to perform an endarterectomy (removal of plaque deposits from arterisclerotic arteries.)(b)
Classification. Class II (performance standards).