(121 days)
The intended use of the modified devices with continue to be provision of tracheal access for airway management in adults.
These devices are used to provide an artificial airway, in order to assist in the treatment of a variety of respiratory diseases and airway management in adults. After insertion in place through a tracheotomy incision in the patient's neck and trachea, the devices are then secured in place with a tiestrap around the patient's neck. which is attached to the tracheostomy tube's swivel neck plate/flange. Once in place, these devices provide a secure artificial airway for spontaneous breathing or direct hook-up to ventilation or anesthesia equipment.
Each device described in this present notification will be essentially identical to an existing Shiley Tracheostomy Tube. The only modification to each of these nine marketed devices will be replacement of the current stiff swivel neck plate/flange with a soft, contoured swivel neck plate/flange to facilitate conformity to individual neck anatomies and, thus. improve patient comfort.
This report describes the acceptance criteria and the study that proves the enhanced Shiley Tracheostomy Tubes meet the acceptance criteria.
1. Table of Acceptance Criteria and Reported Device Performance
| Test | Acceptance Criteria (CEN Standard Requirements) | Reported Device Performance (Modified Device Test Results) |
|---|---|---|
| Tie Strap Hole Strength | No specific requirement | 32.1 lbs force |
| Neck Plate to Trach Tube Body Attachment Strength | Minimum 11.3 lbs force | 22.7 lbs force |
2. Sample Size Used for the Test Set and Data Provenance
The document does not explicitly state the sample sizes used for the in-vitro performance tests. The data provenance is also not specified, though it can be inferred that the testing was conducted internally by the manufacturer, Mallinckrodt Medical, Inc., as part of their 510(k) submission. These tests are in-vitro performance data (bench testing), not clinical data from patients.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of Experts
This section is not applicable. The "ground truth" for this device modification is based on engineering performance standards (CEN Standard Requirements) and internal testing results, not on expert consensus from clinical cases.
4. Adjudication Method for the Test Set
This section is not applicable. The "adjudication" is based on direct comparison of the modified device's performance against established engineering standards and a predicate device, not on expert review of clinical cases.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and Effect Size of How Much Human Readers Improve with AI vs. Without AI Assistance
This is not an AI-based device, nor is it a diagnostic device that would involve human readers interpreting results. Therefore, an MRMC comparative effectiveness study was not performed and is not relevant to this submission.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
This is not an algorithm or AI-based device. Therefore, a standalone algorithm performance study was not done and is not relevant.
7. The Type of Ground Truth Used (Expert Consensus, Pathology, Outcomes Data, etc.)
The ground truth for the in-vitro performance tests is based on engineering performance standards and comparison to predicate device performance. Specifically, for the "Neck Plate to Trach Tube Body Attachment Strength," the ground truth is a "minimum 11.3 lbs force" derived from CEN Standard Requirements. For "Tie Strap Hole Strength," there was no specific ground truth requirement, but the modified device's performance was reported alongside the predicate device's performance.
8. The Sample Size for the Training Set
This section is not applicable. This is not an AI/ML device that requires a training set.
9. How the Ground Truth for the Training Set Was Established
This section is not applicable, as there is no training set for this device.
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OCT 4 1996
Appendix E Page 1 of 3
510(k) Class II SUMMARY
Date Submitted: May 31, 1996
- Submitter: Mallinckrodt Medical, Inc. Establishment Registration Number 2029387, 18691 Jamboree Road Irvine, CA 92715
- Contact Person: Michael Schoeck, Regulatory Affairs Associate Mallinckrodt Medical, Inc. 675 McDonnell Blvd. Hazelwood, MO 63134 (corporate offices) (314) 895-2318 (phone) or (314) 895-2355 (fax)
- Device Name: Shiley Tracheostomy Tubes
Common Name and Classification: Tracheostomy Tube and tube cuff, 21 CFR 868.5800
Predicate Devices:
| Predicate Device Name | Product Designation | 510(k) Number | |
|---|---|---|---|
| 1. | Shiley Low Pressure, Cuffed Tracheostomy Tube | LPC | K792222, 12/18/79K811033, 5/13/81 |
| 2. | Shiley Fenestrated, Low Pressure, Cuffed TracheostomyTube | FEN | K812302, 9/8/81 |
| 3. | Shiley Cuffless Tracheostomy Tubes | CFS (non-fenestrated)CFN (fenestrated) | pre-amendment |
| 5. | Shiley Disposable Cannula, Low Pressure, CuffedTracheostomy Tube | DCT | K811447, 6/26/81 |
| 6. | Shiley Disposable Cannula, Fenestrated, Low Pressure,Cuffed Tracheostomy Tube | DFEN | K843729, 10/19/84K865061, 1/15/87 |
| 7. | Shiley Disposable Cannula, Cuffless TracheostomyTubes | DCFS (non-fenestrated)DCFN (fenestrated) | K880614, 3/9/88 |
| 8. | Shiley Pediatric/Neonatal Tracheal Tubes | PEDNEO | K945513, 1/13/95 |
| 9. | Shiley Single Cannula Tracheostomy Tube | SCT | K810106, 2/2/81 |
:' .
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Device Description:
These devices are used to provide an artificial airway, in order to assist in the treatment of a variety of respiratory diseases and airway management in adults. After insertion in place through a tracheotomy incision in the patient's neck and trachea, the devices are then secured in place with a tiestrap around the patient's neck. which is attached to the tracheostomy tube's swivel neck plate/flange. Once in place, these devices provide a secure artificial airway for spontaneous breathing or direct hook-up to ventilation or anesthesia equipment.
Each device described in this present notification will be essentially identical to an existing Shiley Tracheostomy Tube. The only modification to each of these nine marketed devices will be replacement of the current stiff swivel neck plate/flange with a soft, contoured swivel neck plate/flange to facilitate conformity to individual neck anatomies and, thus. improve patient comfort.
| Products Which will Incorporate the new Soft Swivel Neck Plate/flange | Product Designation) | |
|---|---|---|
| 1. | Shiley Low Pressure, Cuffed Tracheostomy Tube | LPC |
| 2. | Shiley Fenestrated, Low Pressure, Cuffed Tracheostomy Tube | FEN |
| 3. | Shiley Cuffless Tracheostomy Tube (non-fenestrated) | CFS |
| 4. | Shiley Cuffless Tracheostomy Tube (fenestrated) | CFN |
| 5. | Shiley Laryngectomy Tube | LGT |
| 6. | Shiley Disposable Cannula, Low Pressure, Cuffed Tracheostomy Tube | DCT |
| 7. | Shiley Disposable Cannula, Fenestrated, Low Pressure, CuffedTracheostomy Tube | DFEN |
| 8. | Shiley Disposable Cannula, Cuffless Tracheostomy Tube (non-fenestrated) | DCFS |
| 9. | Shiley Disposable Cannula, Cuffless Tracheostomy Tube (fenestrated) | DCFN |
Intended Use:
The intended use of the modified devices with continue to be provision of tracheal access for airway management in adults.
Comparison of Technological Characteristics of Subject Versus Predicate Devices:
Similarities:
- The modified tracheostomy tubes will be identical to their respective predicate devices in intended use, . indications for use, ID, OD, length, # of fenestrations, location and size of fenestrations, cannula bend, and in their packaged accessories.
- . The modified trach tubes will feature a soft (not rigid) neck plate design like the predicate PED/NEO and SCT devices.
- All materials used in the modified tracheostomy tubes and their packaged accessories will remain the ● same as the predicate devices. Only the configuration and materials of the swivel neck plate/flange on each device will change.
- The product designations (i.e., model #'s) for each of the modified Trach Tubes will remain the same. .
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- Since the soft swivel neck plate/flange is used clinically in the same way as the previous rigid swivel . neck plate/flange, it will be unnecessary to modify the Instructions for Use.
Differences:
- The swivel neck plate/flanges have changed from a uniformly rigid polycarbonate design to a . configuration which combines both rigid and soft biocompatible plastic materials.
The new neck plate/flange will feature a rigid copolyester core for strength. The pins upon which the neck plate/flange swivels (after connection to the main body of the Trach tube) are part of this rigid inner core.
Soft PVC will then be overmolded around the rigid core to form the outer surface of the swivel neck plate/flange. Thus, the outer surface of the neck plate will be soft and flexible along the edges.
- . The soft swivel neck plate/flange will also be slightly larger and more contoured than the current design to facilitate patient comfort.
Performance/Clinical Data:
A. In-vitro performance data:
| Test | Predicate DeviceTest Results | Modified Device TestResults | CEN StandardRequirements |
|---|---|---|---|
| Tie Strap Hole Strength: | 26.7 lbs force(SCT) | 32.1 lbs force | No requirement for thistest parameter |
| Neck Plate to Trach Tube BodyAttachment Strength: | 42.1 lbs force(DCT) | 22.7 lbs force | minimum 11.3 lbs force |
- B. Clinical Data: Clinical data was not necessary, since device performance can be adequately assessed by in-vitro testing.
In conclusion, the similarities to the predicate devices, in conjunction with the physical integrity test results, demonstrate that the soft swivel neck plate/flange modification to these devices does not impact safety or effectiveness.
Summary:
The data presented demonstrate that the proposed modification (soft swivel neck plate/flange) to Shiley Tracheostomy Tubes does not impact device performance characteristics and, thus, does not raise new safety and efficacy questions. This information supports the conclusion that the modified Shiley Tracheostomy Tubes and accessories are substantially equivalent in intended use, operation, and characteristics, as compared to existing legally marketed devices.
§ 868.5800 Tracheostomy tube and tube cuff.
(a)
Identification. A tracheostomy tube and tube cuff is a device intended to be placed into a surgical opening of the trachea to facilitate ventilation to the lungs. The cuff may be a separate or integral part of the tracheostomy tube and is, when inflated, intended to establish a seal between the tracheal wall and the tracheostomy tube. The cuff is used to prevent the patient's aspiration of substances, such as blood or vomit, or to provide a means for positive-pressure ventilation of the patient. This device is made of either stainless steel or plastic.(b)
Classification. Class II.