(163 days)
Custodiol HTK Solution is indicated for perfusion and flushing donor kidneys prior to removal from the donor or immediately after removal from the donor. The solution is left in the organ vasculature during hypothermic storage and transportation (not for continuous perfusion) to the recipient.
The HTK solution is intended for perfusion and flushing donor kidneys prior to removal from the donor and for preserving the kidney during hypothermic storage and transport to the recipient. HTK solution is based on the principle of inactivating organ function by withdrawal of extracellular sodium and calcium, together with intensive buffering of the extracellular space by means of histidine/histidine HCl, so as to prolong the period for which the organs will tolerate interruption of blood and oxygen supply. Only a small portion of the osmolality of the HTK solution is due to the sodium and potassium. The composition of HTK is similar to that of extracellular fluid. All of the components of the HTK solution occur naturally in the body.
The HTK solution is relatively low in potassium concentration so that residual solution in the transplanted organ poses no danger to the recipient. This is particularly important in organs that take up relatively large amounts of the perfusate, which may find its way into the recipient's circulation.
The HTK solution has a low viscosity, even at low temperatures. This characteristic assures rapid flow rates during initial perfusion, allowing the organ to be quickly cooled.
Here's an analysis of the provided 510(k) summary regarding the Custodiol® HTK Solution, focusing on acceptance criteria and the study that proves its equivalence:
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria (Predicate Device Performance) | Reported Device Performance (Custodiol HTK Solution) | Metric |
|---|---|---|
| 91% kidney survival at 1 month | 91% kidney survival at 1 month | Kidney Survival Rate |
| 82% kidney survival at 12 months | 83% kidney survival at 12 months | Kidney Survival Rate |
| 74% kidney survival at 24 months | 77% kidney survival at 24 months | Kidney Survival Rate |
| 68% kidney survival at 36 months | 74% kidney survival at 36 months | Kidney Survival Rate |
Note: The acceptance criteria are implicitly derived from the performance of the predicate device (Viaspan Belzer UW Cold Storage Solution), as the study aims to demonstrate "as well as" performance.
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: "Over a thousand kidneys" were included in the study.
- Data Provenance: The study was a "47-center randomized clinical study carried out under the guidance of the Eurotransplant organization of Leiden, The Netherlands." This indicates prospective data from multiple European centers.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of Those Experts
This information is not provided in the document. The study focuses on "overall kidney survival rates" as outcome measures, which are clinical outcomes rather than expert-established ground truth in an imaging or diagnostic sense. The determination of kidney survival likely relies on standardized clinical criteria and medical records, rather than expert interpretation of a specific artifact.
4. Adjudication Method for the Test Set
This information is not explicitly provided. Given the nature of kidney survival rates as the primary outcome, it's unlikely that the "adjudication method" in the context of expert review (e.g., 2+1, 3+1) is directly applicable. Outcomes like kidney survival are typically determined by clinical follow-up and documented medical facts.
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 is a comparison of two organ preservation solutions, not an AI-assisted diagnostic device. Therefore, a MRMC study with human readers and AI assistance is not relevant to this submission.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not Applicable. This is a medical solution, not an algorithm or AI device.
7. The Type of Ground Truth Used
The ground truth used was outcomes data, specifically "overall kidney survival rates." These rates are clinical outcomes reflecting the functional status of the transplanted kidneys over time.
8. The Sample Size for the Training Set
Not Applicable. This is not a machine learning or AI device that requires a distinct training set. The clinical study described served as the primary performance evaluation.
9. How the Ground Truth for the Training Set Was Established
Not Applicable. As there is no training set in the context of an AI/ML device, this question is not relevant. The "ground truth" for the performance evaluation (kidney survival) was established through clinical follow-up and medical documentation within the multi-center study.
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510(k) Summary
Custodiol® HTK Solution
Common/Classification Name: Isolated Kidney Perfusion and Transport System and Accessories, 21 CFR 876.5880
Dr. Franz Kohler Chemie GmbH Postfach 1117 D-64659 Alsbach-Hahnlein Germany
Contact: E. Schaffner, M.D. Prepared: June 16, 1999
LEGALLY MARKETED PREDICATE DEVICES A.
The Custodiol HTK Solution is substantially equivalent to the Viaspan Belzer UW Cold Storage Solution, which was cleared by FDA as K944866 on 04 April 1996.
B. DEVICE DESCRIPTION
The HTK solution is intended for perfusion and flushing donor kidneys prior to removal from the donor and for preserving the kidney during hypothermic storage and transport to the recipient. HTK solution is based on the principle of inactivating organ function by withdrawal of extracellular sodium and calcium, together with intensive buffering of the extracellular space by means of histidine/histidine HCl, so as to prolong the period for which the organs will tolerate interruption of blood and oxygen supply. Only a small portion of the osmolality of the HTK solution is due to the sodium and potassium. The composition of HTK is similar to that of extracellular fluid. All of the components of the HTK solution occur naturally in the body.
The HTK solution is relatively low in potassium concentration so that residual solution in the transplanted organ poses no danger to the recipient. This is particularly important in organs that take up relatively large amounts of the perfusate, which may find its way into the recipient's circulation.
The HTK solution has a low viscosity, even at low temperatures. This characteristic assures rapid flow rates during initial perfusion, allowing the organ to be quickly cooled.
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INDICATIONS FOR USE C.
Custodiol HTK Solution is indicated for perfusion and flushing donor kidneys prior to removal from the donor or immediately after removal from the donor. The solution is left in the organ vasculature during hypothermic storage and transportation (not for continuous perfusion) to the recipient.
SUBSTANTIAL EQUIVALENCE SUMMARY D.
The Custodiol HTK Solution is a medical device, and it has a similar indications for use as the legally marketed predicate device. While the indications for use statement is not identical to that of the predicate device, the intended use is clearly the same.
The Custodiol HTK Solution has the same technological characteristics as the predicate devices. However, the characteristics may not be sufficiently precise to assure equivalence through a point by point comparison. Therefore, extensive clinical data has been collected by the sponsor and others. The performance data clearly demonstrates equivalence.
ய் TECHNOLOGICAL CHARACTERISTICS
Both the Custodiol HTK Solution and the predicate device are solutions containing electrolytes, buffering agents, and other materials occurring naturally in the body. Both solutions are intended to reduce metabolism and preserve physiological conditions of explanted organs and tissue during cold storage.
F. TESTING
Several clinical studies have been reported that compared the performance of Custodiol HTK Solution with the Viaspan Belzer UW These studies have compared survival rates and other Solution. outcome measures. The primary evidence for the equivalence of Custodiol and UW solutions has come from the 47-center randomized clinical study carried out under the guidance of the Eurotransplant organization of Leiden, The Netherlands. Over a thousand kidneys were included in the study.
This study showed that the HTK solution performs as well as the UW solution and significantly better than EC solution for kidney transplants. The overall kidney survival rates from the 47-center study for HTK versus UW at four time points were:
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| HTK | UW | |
|---|---|---|
| 1 Month | 91% | 91% |
| 12 Months | 83% | 82% |
| 24 Months | 77% | 74% |
| 36 months | 74% | 68% |
CONCLUSIONS G.
The clinical and other performance data amply demonstrate that Custodiol performs as well as the predicate device. This pre-market submission demonstrates Substantial Equivalence as defined and understood in the Federal Food Drug and Cosmetic Act and various guidance documents issued by the Center for Devices and Radiological Health.
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Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
DEC 1 0 1999
Dr. Franz Kohler Chemie GmbH c/o T. Whit Athey, Ph.D. Senior Consultant C.L. McIntosh & Associates, Inc. Medical & Regulatory Affairs Services 12300 Twinbrook Parkway, Suite 625 Rockville, MD 20852
Dear Dr. Athey:
Re: K992209 Custodiol® HTK Solution Dated: October 21, 1999 Received: October 21, 1999 Regulatory Class: II 21 CFR §876.5880/Procode: 78 KDN
We have reviewed your Section 510(k) notification of intent to market the device referenced above and we 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). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act indude requirements for annual registration, listing of devices, good manufacturing practice, fabeling, and prohibitions against misbranding and adulteration.
If your device is classified (see above) into either class II (Special Controls) or class III (Premarket Approval), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 895. A substantially equivalent determination assumes compliance with the Current Good Manufacturing Practice requirements, as set forth in the Quality System Regulation (QS) for Medical Devices: General regulation (21 CFR Part 820) and that, through periodic QS inspections, the Food and Drug Administration (FDA) will verify such assumptions. Failure to comply with the GMP regult in regulatory action. In addition, FDA may publish further announcements concerning your device in the Federal Register. Please note: this response to your premarket notification submission does not affect any obligation you might have under sections 531 through 542 of the Act for devices under the Electronic Product Radiation Control provisions, or other Federal laws or regulations.
This letter will allow you to begin marketing your device as described in your 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and additionally 809.10 for in vitro diagnosic devices), piease contact the Office of Compliance at (301) 594-4613. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers Assistance at its toll-free number (800) 638-2041 or (301) 443-6597, or at its internet address "http://www.fda.gov/cdrh/dsma/dsmamain.html".
Sincerely yours,
CART David J. Schilit, M.D.
CAPT Daniel G. Schultz, M.D. Acting Director, Division of Reproductive, Abdominal, Ear, Nose and Throat, and Radiological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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STATEMENT OF INDICATIONS FOR USE
| 510(k) Number (if known): | K112209 |
|---|---|
| --------------------------- | --------- |
Custodiol HTK Solution Device Name:
Indications For Use:
Custodiol HTK Solution is indicated for perfusion and flushing donor kidneys prior to removal from the donor or immediately after removal from the donor. The solution is left in the organ vasculature during hypothermic storage and transportation (not for continuous perfusion) to the recipient.
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Prescription Use (Per 21 CFR 801.109)
OR
Over-The-Counter Use _________________________________________________________________________________________________________________________________________________________
(Division Sign-Off)
Division of Reproductive, Abdominal, ENT,
and Radiological Devices
510(k) Number K992209/5⁰⁰1
000041
§ 876.5880 Isolated kidney perfusion and transport system and accessories.
(a)
Identification. An isolated kidney perfusion and transport system and accessories is a device that is used to support a donated or a cadaver kidney and to maintain the organ in a near-normal physiologic state until it is transplanted into a recipient patient. This generic type of device may include tubing, catheters, connectors, an ice storage or freezing container with or without bag or preservatives, pulsatile or nonpulsatile hypothermic isolated organ perfusion apparatus with or without oxygenator, and disposable perfusion set.(b)
Classification. Class II (performance standards).