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510(k) Data Aggregation

    K Number
    K230742
    Manufacturer
    Date Cleared
    2023-12-13

    (271 days)

    Product Code
    Regulation Number
    874.4180
    Reference & Predicate Devices
    N/A
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The ACCLARENT AERA® Eustachian Tube Balloon Dilation System is intended to dilate the Eustachian tube for treatment of persistent Eustachian tube dysfunction in patients ages 18 and older.

    For patients ages 8-17 years, the ACCLARENT AERA® Eustachian Tube Balloon Dilation System, alone or in combination with adjunctive procedures, is intended to treat patients with objective signs of persistent obstructive Eustachian tube dysfunction from inflammatory pathology, resulting in chronic otitis media with effusion and are refractory to at least one surgical intervention for persistent obstructive Eustachian tube dysfunction.

    Device Description

    The ACCLARENT AERA® Eustachian Tube Balloon Dilation System includes a Eustachian Tube Balloon Catheter and Guide Catheter designed specifically for use in accessing and dilating the Eustachian Tube. The system is used with the following additional devices: the Acclarent® SE Inflation Device (or Acclarent® Balloon Inflation Device). The Acclarent® SE Inflation Device or Acclarent® Balloon Inflation Device is used to inflate the balloon. All devices are provided sterile for single-patient use. The ACCLARENT AERA® Eustachian Tube Balloon Dilation System includes is a 6x16mm (inflated diameter x length) flexible Balloon Catheter with an integrated shaft and a nylon balloon at the distal tip. The non-compliant balloon is designed to dilate the cartilaginous portion of the Eustachian tube. The shaft consists of dual lumen tubing with an actuator component that is designed to assist in rotation and advancement of the balloon catheter. The balled catheter tip (aka, “blueberry tip") on the balloon catheter is designed to restrict advancement of the device into the bony portion of the Eustachian tube, known as the isthmus. There is an endoscopic marker placed at the proximal taper of the balloon to aid in positioning under direct endoscopic visualization. The AERA Guide Catheter is anatomically designed to facilitate AERA Balloon Catheter access to the Eustachian tube. The AERA Guide Catheter incorporates an atraumatic distal tip and distal angled tip profile that facilitates access to the Eustachian tube. The Guide Catheter supplied with the ACCLARENT AERA® Eustachian Tube Balloon Dilation System contains a lubricious inner liner to allow smooth passage for the balloon catheter and includes a hypotube for rigidity.

    AI/ML Overview

    The Acclarent AERA Eustachian Tube Balloon Dilation System is intended to dilate the Eustachian tube for the treatment of persistent Eustachian tube dysfunction. The expanded indication covers patients aged 8-17 years with objective signs of persistent obstructive Eustachian tube dysfunction from inflammatory pathology, resulting in chronic otitis media with effusion and refractory to at least one surgical intervention.

    Here's the breakdown of the acceptance criteria and the study that proves the device meets them:

    1. Table of Acceptance Criteria and Reported Device Performance:

    Acceptance Criteria CategorySpecific CriteriaReported Device Performance and Validation
    Mechanical PerformanceDimensional attributes, cycle fatigue, balloon burst, bond separation.Previously submitted bench testing met all acceptance criteria for these attributes. No new testing for mechanical characteristics was performed for this submission as the technological characteristics of the device are identical to the predicate device.
    BiocompatibilityDevice materials are biocompatible.Testing has shown that the ACCLARENT AERA® Eustachian Tube Balloon Dilation System is biocompatible.
    SterilizationSterility assurance level (SAL) of 10^-6.The sterilization process was validated per AAMI/ANSI/ISO 11135-1: 2007, using the overkill (half-cycle approach) in a fixed chamber, and demonstrated a sterility assurance level of 10^-6.
    Ethylene Oxide ResidualsMeet ISO 10993-7:2008 requirements.Testing of ethylene oxide residuals met ISO 10993-7:2008 requirements.
    Packaging Shelf LifeOne-year shelf life.Packaging shelf life was established at one year via accelerated aging per ASTM F1980-07.
    Safety (Pediatric)Acceptable adverse event rate in pediatric patients (8-17 years old) with persistent obstructive Eustachian tube dysfunction from inflammatory pathology, resulting in chronic otitis media with effusion, and refractory to at least one surgical intervention.A review of safety data in the expanded pediatric population (8-17 years) found the device to be safe with no serious adverse events reported after ETBD. A minor AE rate of 8.2% of patients in this expanded age group was observed. This evidence was derived from real-world evidence, including published literature and data provided by established physicians.
    Efficacy (Pediatric)Improvement in tympanometry and failure-free rate in pediatric patients (8-17 years old) with persistent obstructive Eustachian tube dysfunction from inflammatory pathology, resulting in chronic otitis media with effusion, and refractory to at least one surgical intervention.Efficacy data from 20 ears in patients aged 8-17 years with Chronic Otitis Media with Effusion (COME) showed an improvement in tympanometry in 75% of procedures. A total of 84% of ears were failure-free after a mean of 2.7 years of follow-up (failure defined as requiring further surgery for ETD, e.g., tympanostomy tube insertion or revision ETBD). This evidence was derived from real-world evidence, including published literature and data provided by established physicians, and supports that ETBD is comparable, if not superior, to tympanostomy tube placement alone in the treatment of chronic otitis media with effusion in the pediatric population.
    Anatomical EquivalenceEustachian tube anatomy in the expanded patient population (8-17 years) to be similar to the predicate age group (18+ years).Equivalence of anatomy was demonstrated through a systematic literature review including several articles evaluating Eustachian tube anatomy. Based on CT scan reviews, the anatomy of the target pediatric patient population (8-17 years) was found to be similar to that of the predicate adult age group (18+) with no issues of safety raised.

    2. Sample Sizes and Data Provenance:

    • Test Set (for pediatric expansion):

      • Clinical Data: Efficacy data was reported from 20 ears of patients aged 8-17 years with Chronic Otitis Media with Effusion. Safety data encompassed a broader analysis across the expanded pediatric age group (8-17 years), without a specific patient count provided for the 8.2% minor AE rate, but it was derived from real-world evidence.
      • Anatomical Equivalence: "Several articles" based on CT scan reviews were used. No specific number of patients or scans are provided for this.
      • Provenance: "Real-world evidence, with data from published literature and data provided by established physicians" was analyzed. It is retrospective in nature, as it relies on existing published literature and real-world clinical experience. The country of origin of the data is not specified but is generally understood to be diverse given the nature of a systematic literature review and physician-provided data.
    • Training Set: The document does not explicitly describe a separate "training set" in the context of an AI/ML algorithm requiring such a set. The performance data for the device (mechanical, biocompatibility, sterilization, etc.) relies on previously submitted bench testing and validations, which are not typically referred to as training sets. The clinical data for the pediatric expansion relies on real-world evidence and a systematic literature review, which also does not fit the typical definition of a training set for an AI/ML model.

    3. Number of Experts and Qualifications for Ground Truth:

    • For Clinical Data (Pediatric Expansion): The document mentions "data provided by established physicians." It does not specify the number or specific qualifications (e.g., years of experience) of these individual physicians, nor does it detail the experts involved in conducting the systematic literature review.
    • For Anatomical Equivalence: Similarly, the CT scan reviews were used as evidence for anatomical equivalence, based on "several articles." The experts performing these CT scan reviews or evaluating the articles are not explicitly identified or qualified.

    4. Adjudication Method for the Test Set:

    • The document does not describe an explicit adjudication method (e.g., 2+1, 3+1) for the clinical data or anatomical equivalence evaluations for the pediatric expansion. The data from published literature and physician-provided data likely reflect outcomes as recorded and reported in their respective studies or practices.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:

    • No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. The ACCLARENT AERA® Eustachian Tube Balloon Dilation System is a physical medical device for dilation, not an AI or imaging diagnostic software that would typically involve human readers interpreting cases with and without AI assistance. Therefore, an effect size of human readers improving with AI vs. without AI assistance is not applicable.

    6. Standalone (Algorithm Only) Performance Study:

    • No, a standalone (algorithm only) performance study was not done. As noted above, this device is a physical medical device (balloon dilation system), not a software algorithm that would have standalone performance.

    7. Type of Ground Truth Used:

    • For the pediatric efficacy data, the ground truth was based on:
      • Clinical Outcomes/Measurements: Improvement in tympanometry (an objective measure of middle ear function).
      • Failure-Free Rate: Defined as not requiring further surgery for ETD (e.g., tympanostomy tube insertion or revision ETBD), which is an outcome-based measure.
    • For the pediatric safety data, the ground truth was based on:
      • Reported Adverse Events: Classification of events as serious or minor, as observed in real-world clinical practice and literature.
    • For anatomical equivalence, the ground truth was based on:
      • CT Scan Reviews: Morphometric analysis of Eustachian tube anatomy as reported in published studies.

    8. Sample Size for the Training Set:

    • As mentioned in section 2, the document does not describe a "training set" in the context of AI/ML. All referred performance data are either previously established bench tests for the device itself or real-world clinical evidence/literature reviews for the expanded indication.

    9. How the Ground Truth for the Training Set Was Established:

    • Not applicable, as a conventional "training set" with established ground truth for an AI/ML model is not described in this submission. The "ground truth" for the device's functional and safety characteristics was established through standard engineering bench testing and clinical data collection/review methodologies relevant to medical devices.
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    K Number
    K231862
    Manufacturer
    Date Cleared
    2023-07-21

    (28 days)

    Product Code
    Regulation Number
    882.4560
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The TruDi® Navigation system is intended for use during surgical procedures in ENT and ENT skull base surgery to support navigation of instruments to targeted anatomy, where reference to a rigid anatomical structure can be identified relative to a CT or MR based model.

    Device Description

    The TruDi® Navigation System V3 is intended to be used during surgical procedures in ENT and ENT skull base surgery to support navigation of instruments to the targeted anatomy, where reference to a rigid anatomical structure can be identified relative to a CT or MR based model. The TruDi® Navigation System V3 enables ENT physicians to access sphenoid, frontal, and maxillary sinuses, as well as the skull base, by using the systems magnetic tracking technology, which is the same technology used by the predicate device. The system incorporates a Navigation Console, Emitter Pad, Instrument Hub, Patient Tracker, Registration Probe, Workstation and peripherals. A magnetic field generated by the Emitter Pad induces a current in the magnetic sensor embedded in the tip of the navigated tool, which helps to accurately calculate the tool tip position. A CT or MR image is imported and registered to the patient coordinates and the navigated tool tip icon is displayed on top of the registered image, indicating the position of the tool tip in reference to the patient anatomy. A Patient Tracker is fixed to the patient forehead to compensate for the head movement during the surgical procedure.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and the study that proves the device meets them, based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Specification)Reported Device Performance (Subject Device V3)
    Accuracy specification: 2mm RMSBench Location Accuracy: 0.55mm (STD 0.2)
    Simulated Use Location Accuracy: 1.2mm (STD 0.2mm)

    2. Sample Size Used for the Test Set and Data Provenance

    The document does not specify a distinct "test set" in the context of human data or patient cases. The performance data is derived from non-clinical bench testing and simulated use.

    • Bench Location Accuracy: This test compared the TruDi® Navigation System's electromagnetic locations to those provided by a highly accurate robot system over its entire navigation volume. While a sample size of "locations" would have been involved in this measurement, the specific number is not provided.
    • Simulated Use Location Accuracy: This involved performing a complete CT image registration and instrument navigation workflow. The specific sample size for "simulated uses" is not provided.

    The data provenance is not from human patients; it's from laboratory (bench) and simulated environments. Therefore, country of origin is not applicable in the typical sense.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications

    This information is not applicable as the 'test set' for accuracy was based on objective measurements (robot system, simulated workflow) and not on expert interpretation of medical images or patient outcomes.

    4. Adjudication Method for the Test Set

    This information is not applicable as the ground truth was established through objective measurement tools and processes (robot system, simulated workflow) rather than human adjudication.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done

    No, an MRMC comparative effectiveness study was not done. The document explicitly states: "Clinical data was not necessary to determine that the subject TruDi® Navigation System V3 performs as intended." This indicates that the evaluation was purely technical and non-clinical.

    6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done

    Yes, a standalone (algorithm only without human-in-the-loop performance) evaluation of the device's core accuracy functions was done. The "Location Accuracy tests... where the TruDi® Navigation System electromagnetic locations were compared to the locations provided by a highly accurate robot system" directly assesses the system's inherent accuracy in a controlled, non-human environment. The "Simulated use accuracy test" also falls under this, evaluating the system's accuracy within a simulated workflow.

    7. The Type of Ground Truth Used

    The ground truth used for accuracy assessments was based on:

    • Highly accurate robot system measurements for Location Accuracy tests.
    • Known/defined parameters within a simulated use workflow for Simulated Use Location Accuracy tests.

    8. The Sample Size for the Training Set

    The document does not provide any information regarding a training set size. This device is a navigation system primarily relying on electromagnetic tracking technology, not a machine learning model that typically requires a separate training set.

    9. How the Ground Truth for the Training Set Was Established

    This information is not applicable as there is no mention of a training set or its ground truth establishment within the provided document.

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    K Number
    K221037
    Manufacturer
    Date Cleared
    2022-07-20

    (104 days)

    Product Code
    Regulation Number
    882.4560
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    TruDi® Shaver Blades are intended for use with the Bien-Air S120 Shaver Handpiece and the TruDi® Navigation System to aid in the incision and removal of soft and hard tissue or bone in ENT, Maxillofacial surgery, Head and Neck and ENT skull base surgery. Their use is indicated for any medical condition in which the use of navigated surgery may be appropriate, and where reference to a rigid anatomical structure can be identified relative to a CT or MR based model.

    TruDi® Shaver Blades may be used in, but is not limited to, the following procedures:

    • · Endoscopic sinus surgery (such as ethmoidectomy, polypectomy, septoplasty)
    • · Drainage of mucoceles or abscesses that have extended from the paranasal sinuses and up to the dura mater
    • · Orbital decompression
    • · Any other of a number of tumors involving the lateral nasal wall, paranasal sinuses and orbit
    • · Access to the sphenoid sinus
    Device Description

    The subject device, TruDi® Shaver Blade, is a single-use and sterile electromagnetically (EM) navigated instrument, which is intended to be used with the Bien-Air S120 Shaver Handpiece (reference device, K083720) and the TruDi® Navigation System (K192397) to aid in the incision and removal of soft and hard tissue or bone in ENT, Maxillofacial surgery, Head and Neck and ENT skull base surgery. The device is tracked by the navigation system within the low energy magnetic field volume generated by the TruDi® Navigation System. The TruDi® Navigation System software displays the position of the shaver blade distal tip on preoperative scans (e.g. CT, MRI). The TruDi® Shaver Blade consists of several configurations ranging from straight to curved blades of different diameters.

    AI/ML Overview

    The TruDi® Shaver Blade underwent various performance tests to demonstrate its substantial equivalence to its predicate device. This device is an electromagnetically (EM) navigated instrument intended for use with the Bien-Air S120 Shaver Handpiece and the TruDi® Navigation System to aid in incision and removal of soft and hard tissue or bone in various ENT and maxillofacial surgeries.

    1. Table of Acceptance Criteria and Reported Device Performance:

    Test CategoryAcceptance CriteriaReported Device Performance
    Dimensional SpecificationsAll specified dimensions are within established tolerances.Met all acceptance criteria for attributes such as dimensional specifications.
    Electrical TestsCompliance with relevant electrical safety and performance standards.Met all acceptance criteria for attributes such as electrical tests. Electrical safety and EMC tests were performed to verify compliance with IEC 60601-1 (3rd Edition) and IEC60601-1-2 (4th Edition).
    Connector Joint Separation ForceConnector joint separation force meets established minimum requirements to ensure secure connection during use.Met all acceptance criteria for attributes such as connector joint separation force.
    Heat Shrink SlipHeat shrink components remain securely in place, without slipping, under specified conditions.Met all acceptance criteria for attributes such as heat shrink slip.
    Strain Relief Axial ForceStrain relief mechanisms exhibit sufficient axial force to prevent damage or unintended disconnections.Met all acceptance criteria for attributes such as strain relief axial force.
    Navigational Location AccuracyAccuracy of the TruDi® Shaver Blade when used with the TruDi® Navigation System is $\le$ 2mm RMS over the entire navigation volume. (Predicate device requirement: 95% confidence / 99.5% reliability, of $\le$ 3.00 mm).The accuracy of TruDi® Shaver Blade used in conjunction with the navigation views of the TruDi® Navigation System is $<$ 2mm RMS over the entire navigation volume. (This meets the reference device (TruDi® Curette) criteria and exceeds the predicate device criteria).
    Sterilization Assurance Level (SAL)Achieves a sterility assurance level of 10-6.Validation per ISO 11135:2014 demonstrated a sterility assurance level of 10-6.
    BiocompatibilityBiocompatible per ISO 10993-1.Biocompatibility testing was successfully completed to determine that the TruDi® Shaver Blade is biocompatible per ISO 10993-1.
    Packaging Shelf LifeMeets a shelf life of three months.Packaging shelf life was established through accelerated aging via ASTM F1980-16, ASTM F88-15, and ASTM F2096-11 requirements and confirmed to meet a shelf life of three months.
    Simulated Use (Functional Performance)Functions in accordance with its intended use and design specifications in a simulated clinical setting, including effective tissue incision and removal, and proper display of navigational information. Packaging, labeling, and instructions for use are successfully assessed.Design validation testing (simulated use testing) on cadavers was successfully conducted to verify that the TruDi® Shaver Blade functions in accordance with its intended use and design specifications in a simulated clinical setting. The packaging, labeling, and instructions for use were also successfully assessed by evaluators as part of the study. The TruDi® Shaver Blade passed all intended criteria in accordance with appropriate test criteria and standards.

    2. Sample size used for the test set and the data provenance:

    • Test set sample size: Not explicitly stated for each bench test, but the design validation testing involved "cadavars." The number of cadavers used is not specified.
    • Data provenance: The testing was non-clinical (bench testing and simulated use on cadavers). The country of origin for the data is not specified, but the submission is for the US FDA, implying testing was conducted to meet US regulatory requirements. The testing is considered prospective as it was conducted to demonstrate the performance of the specified device.

    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):

    • The document mentions "evaluators" for assessing packaging, labeling, and instructions for use during the simulated use study. However, the number and qualifications of these evaluators or other experts establishing ground truth for the bench tests or cadaver study are not specified.

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

    • No specific adjudication method is mentioned for the test set. The data appears to be derived from direct measurements and objective assessments against predefined technical specifications.

    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:

    • No MRMC comparative effectiveness study was mentioned. This device is a surgical instrument with navigation capabilities, not an AI-assisted diagnostic device typically evaluated with MRMC studies.

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

    • A "standalone" performance for the navigation accuracy component was assessed as part of the system accuracy requirement, stating "The accuracy of TruDi® Shaver Blade used in conjunction with the navigation views of the TruDi® Navigation System is < 2mm RMS over the entire navigation volume." This refers to the accuracy of the system's tracking and display. However, the overall device performance in terms of surgical outcome inherently involves human-in-the-loop (the surgeon). The simulated use on cadavers assesses both the device's technical function and its usability for a surgeon.

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

    • For bench testing, the ground truth was based on engineering specifications and established test standards (e.g., dimensional tolerances, electrical safety standards, sterilization standards, biocompatibility standards).
    • For navigational accuracy, the ground truth would be established by precision measurement systems (e.g., optical tracking systems) used to verify the reported position of the instrument within the navigation volume.
    • For the simulated use on cadavers, the "ground truth" for functional performance would be assessed against the intended surgical actions and design specifications for incision and removal of tissue/bone, likely through expert observation and potentially post-procedure assessment of the cadaver.

    8. The sample size for the training set:

    • The document does not provide information about a separate "training set" as it would for a machine learning or AI-based device. The development and validation of medical devices typically involve design verification and validation testing, which are distinct from the training/test set paradigm of AI.

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

    • Not applicable, as no external "training set" in the context of machine learning was described. The device's design and engineering would be based on established medical and engineering principles rather than learn from a labeled dataset.
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    K Number
    K201174
    Device Name
    TruDi Curette
    Manufacturer
    Date Cleared
    2020-08-12

    (103 days)

    Product Code
    Regulation Number
    882.4560
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    TruDi™ Curette is intended for use with the TruDi™ Navigation System to manipulate, dissect and/or remove tissue, cartilage and bone during surgical procedures in ENT and ENT skull base surgery.

    Device Description

    The subject device, TruDi™ Curette (K201174), is a single-use and sterile electromagnetically (EM) navigated instrument, which is intended for use with the TruDi™ Navigation System (K192397) to manipulate, dissect and/or remove tissue, cartilage and bone during surgical procedures in ENT and ENT skull base surgery. The TruDi™ Curette consists of one configuration (straight 0°). The TruDi™ shaft, and a curette cup, which is located at the distal tip and houses a magnetic sensor. The device is sold in sterile packaging. Each package includes one TruDi™ Curette in conjunction with a disposable bending tool. The bending tool is provided to allow the user to customize the shape of the distal shaft as needed.

    The TruDi™ Curette incorporates a sensor at the distal tip, which is tracked by the TruDi™ Navigation System. The location of the distal tip of the device is identified by the navigation system and displayed in real-time view over the patient's pre-operative CT/MRI scan to confirm access, and to locate anatomical structures during ENT and ENT skull base surgery.

    AI/ML Overview

    The provided document is a 510(k) summary for the TruDi™ Curette, which seeks to demonstrate substantial equivalence to a predicate device. While it includes a lot of information about bench testing and design validation, it does not detail a study involving AI performance or human readers. Therefore, several requested sections, particularly those related to AI and human reader studies, cannot be extracted from this document.

    Here's a summary of the available information:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance CriteriaReported Device Performance
    Non-Clinical Performance Data:
    Dimensional specificationsMet all acceptance criteria
    Connector joint separation forceMet all acceptance criteria
    Distal shaft deflection/flexureMet all acceptance criteria
    End to end joint strengthMet all acceptance criteria
    Cable strain relief separation forceMet all acceptance criteria
    Tip sharpnessMet all acceptance criteria
    Bending tool functionalityMet all acceptance criteria
    Navigational location accuracyMet all acceptance criteria; Accuracy of TruDi™ Curette in conjunction with TruDi™ Navigation System is ≤ 2mm RMS over the entire navigation volume.
    Electrical safety and EMCCompliance with IEC 60601-1 (3rd Edition) and IEC60601-1-2 (4th Edition)
    Sterilization processValidated per ISO 11135:2014, demonstrated a sterility assurance level of 10^-6
    Ethylene oxide residualsMet ISO 10993-7:2008 requirements
    BiocompatibilitySuccessfully completed per ISO 10993-1
    Packaging shelf lifeEstablished for three months via accelerated aging (ASTM F1980-07, ASTM F88/F88M-09, ASTM F2096-11)
    Design Validation (Simulated Use Testing):
    Functionality in simulated clinical settingSuccessfully conducted and verified that the TruDi™ Curette functions in accordance with its intended use and design specifications
    Packaging and instructions for use assessmentSuccessfully assessed by evaluators
    Overall Product PerformancePassed all intended criteria in accordance with appropriate test criteria and standards

    2. Sample size used for the test set and the data provenance

    The document mentions "Design validation testing (simulated use testing) on cadavers" but does not specify the sample size (number of cadavers or test cases) used for this test set nor the detailed provenance beyond "cadavers". It is a prospective study in a simulated clinical setting.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    Not specified in the provided document. The document mentions "evaluators" for assessing packaging and instructions for use, but not for establishing ground truth regarding clinical performance.

    4. Adjudication method for the test set

    Not specified in the provided 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

    Not applicable. The TruDi™ Curette is a physical surgical instrument, not an AI or imaging diagnostic device that would involve human readers or AI assistance in the way typically assessed by MRMC studies.

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

    Not applicable. The TruDi™ Curette is a physical surgical instrument, not an algorithm. Its navigation capability is part of the TruDi™ Navigation System, which has a stated accuracy of ≤ 2mm RMS. This accuracy is a standalone measurement of the system's ability to track the instrument's tip.

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

    For the navigational location accuracy, the ground truth would typically be established through precise metrological measurements using a known standard or reference system. For the simulated use testing on cadavers, the "ground truth" or successful performance would be based on the device functioning as intended in manipulating, dissecting, and/or removing tissue, cartilage, and bone, as verified by the evaluators. Specific methods for establishing this ground truth (e.g., expert observation, quantitative assessment of tissue removal) are not detailed.

    8. The sample size for the training set

    Not applicable. The TruDi™ Curette is a physical device, and the document describes performance testing and design validation, not the development or training of an AI algorithm.

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

    Not applicable. There is no mention of a training set or AI model in the context of this device.

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    K Number
    K193453
    Device Name
    TruDi Probe
    Manufacturer
    Date Cleared
    2020-03-23

    (101 days)

    Product Code
    Regulation Number
    882.4560
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The TruDi™ Probe is intended for use with the TruDi™ Navigation System to locate anatomical structures during surgical procedures in ENT and ENT skull base surgery.

    Device Description

    The subject device, TruDi™ Probe, is a single-use and sterile electromagnetically (EM) navigated instrument, which is intended for use with the TruDi™ Navigation System (K192397) to locate anatomical structures during surgical procedures in ENT and ENT skull base surgery.

    The TruDi™ Probe consists of two configurations, straight (0°) and frontal (70°). The TruDi™ Probe comprises of a fixed proximal connector, cable, handle, stainless steel shaft, and a distal tip that houses a magnetic sensor. The device is sold in sterile packaging. Each package includes one TruDi™ Probe (either straight or frontal) in conjunction with a disposable bending tool. The bending tool is provided to allow the user to customize the shape of distal tip as needed.

    The TruDi™ Probe incorporates a sensor at the distal tip, which is tracked by the TruDi™ Navigation System. The location of the distal tip of the device is identified by the navigation system and displayed in real-time view over the patient's pre-operative CT scan to confirm access and locate anatomical structures during ENT surgery.

    AI/ML Overview

    The document describes the Acclarent TruDi™ Probe, a single-use electromagnetically (EM) navigated instrument for locating anatomical structures during ENT and ENT skull base surgery. The device is intended for use with the TruDi™ Navigation System.

    Here's an analysis of the acceptance criteria and supporting studies:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document outlines performance data from various non-clinical tests. Since specific quantified acceptance criteria are not presented in a direct table format alongside the reported performance values, I will infer them from the descriptions.

    Acceptance Criteria (Inferred)Reported Device Performance
    Mechanical Performance:
    - Dimensional specifications metBench testing performed and met all acceptance criteria
    - Connector joint separation force metBench testing performed and met all acceptance criteria
    - Tip flexure within limitsBench testing performed and met all acceptance criteria
    - Distal tube to handle separation force metBench testing performed and met all acceptance criteria
    - Cable strain relief separation force metBench testing performed and met all acceptance criteria
    - Bending tool functionalityBench testing performed and met all acceptance criteria
    Navigational Location Accuracy:A mean bench accuracy of 0.43 mm (Standard deviation 0.15 mm) was measured for the device. With 95% confidence measured devices have location accuracy of ≤ 2 mm RMS over the entire navigation volume.
    Electrical Safety and EMC:Met requirements of IEC 60601-1 (3rd Edition) and IEC60601-1-2 (4th Edition).
    Sterilization:Sterility assurance level of 10-6 per ISO 11135:2014 (overkill/half-cycle approach). Ethylene oxide residuals meet ISO 10993-7:2008 requirements.
    Biocompatibility:Successfully completed per ISO 10993-1.
    Packaging Shelf Life:Confirmed to meet a shelf life of three months through accelerated aging per ASTM F1980-07, ASTM F88/F88M-09, and ASTM F2096-11.
    Simulated Use Performance:Successfully conducted on cadavers to verify function, intended use, and design specifications. Packaging and IFU also assessed.

    2. Sample Size for Test Set and Data Provenance:

    The document mentions "bench testing" and "simulated use testing on cadavers." However, specific sample sizes for these tests are not provided. The provenance of the data is implied to be from the manufacturer's internal testing as part of their 510(k) submission, and it is retrospective (performed before the submission). There is no mention of country of origin for the data; it is assumed to be part of the manufacturer's internal development and testing.

    3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications:

    The document describes "simulated use testing on cadavers" where "packaging and instructions for use were also successfully assessed by evaluators." However, the number of experts and their qualifications used to establish ground truth for these tests are not mentioned.

    4. Adjudication Method:

    The document does not specify an adjudication method for the "simulated use testing" or any other performance evaluation involving human assessment.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:

    A MRMC comparative effectiveness study was not conducted or reported. The submission explicitly states "Clinical data was not necessary for the TruDi™ Probe. The performance data demonstrated that the device performs as intended." This indicates no study was done to assess human reader improvement with or without AI assistance.

    6. Standalone Performance Study (Algorithm Only):

    The document describes the standalone performance of the device concerning its navigational accuracy:

    • A mean bench accuracy of 0.43 mm (Standard deviation 0.15 mm) was measured for the device.
    • With 95% confidence, measured devices have a location accuracy of ≤ 2 mm RMS over the entire navigation volume.
      This indicates algorithm-only performance testing for its core functionality (localization).

    7. Type of Ground Truth Used (for standalone performance):

    For the navigational accuracy, the ground truth would have been established by a highly precise engineering and metrology setup (e.g., using a known reference system or precision measurement tools) to determine the true position, against which the device's reported position was compared. This is typical for such electromagnetic navigation systems.

    8. Sample Size for the Training Set:

    The TruDi™ Probe is an electromagnetic navigation instrument, not an AI or machine learning algorithm in the typical sense that would require a "training set" of data to learn from. Its performance is based on physical principles and sensor technology. Therefore, a training set size is not applicable in this context.

    9. How the Ground Truth for the Training Set Was Established:

    As mentioned above, the concept of a "training set" and associated ground truth is not applicable to this device, which relies on direct physical measurement and not a learning algorithm.

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    K Number
    K190525
    Manufacturer
    Date Cleared
    2019-05-03

    (60 days)

    Product Code
    Regulation Number
    874.4420
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The RELIEVA ULTIRRA® Sinus Balloon Catheter is an instrument intended to dilate sinus ostia and spaces within the paranasal sinus cavities for diagnostic procedures. It is also intended to irrigate from within a target sinus for therapeutic procedures and to facilitate diagnostic procedures.

    For children aged 17 and under, the balloon catheter system is intended to dilate sinus ostia and spaces associated with the maxillary sinus for diagnostic and therapeutic procedures. It is also intended to irrigate from within a target sinus for therapeutic procedures and to facilitate diagnostic procedures.

    The RELIEVA ULTIRRA® Sinus Balloon Catheter may be utilized in conjunction with TruDi™ NAV Wire and TruDi™ Navigation System to provide access to nasal and sinus spaces, and to confirm placement in the accessed anatomy. It is NOT intended to irrigate from within a target sinus for therapeutic procedures nor to facilitate diagnostic procedures with TruDi™ NAV Wire.

    Device Description

    The RELIEVA ULTIRRA® Sinus Balloon Catheter is a flexible catheter that is intended to dilate sinus ostia. The shaft allows for inflation of the sinus balloon and permits the passage of an electromagnetic navigable sinus guidewire or sinus illumination system to facilitate access to the target sinus ostia. A hypotube is incorporated on the proximal end to provide rigidity during insertion through a sinus guide catheter.

    AI/ML Overview

    Here's an analysis of the acceptance criteria and the study that proves the device meets them, based on the provided text.

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance CriterionReported Device Performance
    Simulated Use TestingMet all performance acceptance criteria
    Dimensional SpecificationsMet all performance acceptance criteria
    Balloon Burst PressureMet all performance acceptance criteria
    Joint Separation ForceMet all performance acceptance criteria
    Deflation TimeMet all performance acceptance criteria
    Balloon Cycle FatigueMet all performance acceptance criteria
    Shelf LifeEstablished per ASTM F1980-07, ASTM F88/F88M-09, ISTA 2A, and ASTM F2096-11 requirements.
    BiocompatibilityBiocompatible per ISO 10993-1.
    Sterilization Assurance Level (SAL)10^-6, validated per AAMI/ANSI/ISO 11135:2014 (overkill/half-cycle approach in a fixed chamber).
    Ethylene Oxide ResidualsMet ISO 10993-7:2008 requirements.
    Packaging Shelf LifeEstablished per ASTM F1980-07.

    2. Sample Size for Test Set and Data Provenance

    The document states, "Clinical data was not necessary for the RELIEVA ULTIRRA® Sinus Balloon Catheter." This indicates that no clinical test set was used, and therefore no sample size or data provenance for a clinical test set is applicable. The evaluation was based on non-clinical performance testing.

    3. Number of Experts and Qualifications for Ground Truth

    Since no clinical data or human-in-the-loop performance was performed for this 510(k) submission, the concept of "experts used to establish ground truth" is not applicable in the context of evaluating diagnostic accuracy or clinical decision-making. The ground truth for the non-clinical performance tests would be the established engineering and materials standards and specifications. Engineers and technicians with expertise in medical device testing would have established and verified these.

    4. Adjudication Method for Test Set

    Not applicable, as no clinical test set requiring adjudication was used.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    No MRMC comparative effectiveness study was mentioned or performed. The submission explicitly states "Clinical data was not necessary."

    6. Standalone (Algorithm Only) Performance Study

    Not applicable. This device is a manual surgical instrument (catheter), not an algorithm or AI system. The performance studies conducted were non-clinical, evaluating the physical and mechanical properties of the device.

    7. Type of Ground Truth Used

    The ground truth for the non-clinical performance data was based on established engineering standards, material specifications, and regulatory requirements (e.g., ISO, ASTM standards) for medical device performance (e.g., burst pressure, fatigue, biocompatibility, sterilization).

    8. Sample Size for Training Set

    Not applicable. As a physical medical device, there is no "training set" in the context of machine learning or AI. The device's design and manufacturing processes are developed and refined through engineering principles and iterative testing, not through data-driven training sets as understood in AI systems.

    9. How Ground Truth for Training Set Was Established

    Not applicable, as there is no training set in this context. The "ground truth" for the device's development and manufacturing would be its intended function, design specifications, and relevant industry standards.

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    K Number
    K190532
    Device Name
    TruDi NAV Wire
    Manufacturer
    Date Cleared
    2019-05-03

    (60 days)

    Product Code
    Regulation Number
    882.4560
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The TruDi™ NAV Wire is intended for use as an electromagnetically navigable guidewire to provide access and confirmation of placement in the patient anatomy. The device is intended for use during ENT procedures where reference to a rigid anatomical structure can be identified relative to a CT-based model of the anatomy.

    Device Description

    The subject device, TruDi™ NAV Wire, is a single-use electromagnetically (EM) navigated, flexible guidewire, which is compatible for use with the TruDi™ Navigation System to provide access and confirmation of placement in patient anatomy during intranasal and paranasal surgeries. The TruDi™ NAV Wire is intended to provide real-time tracking at the distal tip of the guidewire in the nasal anatomy and is intended to be used during ENT procedures where reference to a rigid anatomical structure can be identified relative to a CT-based model of the anatomy. The subject device, TruDi™ NAV Wire, may be used with compatible non-ferromagnetic instruments that have a lumen of greater than 1mm in diameter and a luer lock mechanism to fix the wire onto the instrument.

    AI/ML Overview

    The provided text describes the "TruDi™ NAV Wire," an electromagnetically navigable guidewire. Here's a breakdown of the acceptance criteria and study information:

    1. Acceptance Criteria and Reported Device Performance

    The document does not explicitly provide a table of acceptance criteria with numerical targets and the device's reported performance against those targets in a readily digestible format for certain tests. Instead, it states that "Bench testing has been performed and met all acceptance criteria for attributes..." and then lists the attributes. For sterility, it mentions a specific level.

    Here's a table based on the provided text, outlining the tests performed and the general statement of performance:

    Test/AttributeAcceptance CriteriaReported Device Performance
    Simulated Use TestingMet acceptance criteria"met all acceptance criteria"
    Dimensional SpecsMet acceptance criteria"met all acceptance criteria"
    Insertion DurabilityMet acceptance criteria"met all acceptance criteria"
    Rotational DurabilityMet acceptance criteria"met all acceptance criteria"
    Suction DurabilityMet acceptance criteria"met all acceptance criteria"
    Joint Separation ForceMet acceptance criteria"met all acceptance criteria"
    StiffnessMet acceptance criteria"met all acceptance criteria"
    Swivel Functional Perf.Met acceptance criteria"met all acceptance criteria"
    Frictional ForceMet acceptance criteria"met all acceptance criteria"
    Location Accuracy (Sensor Sensitivity)Met acceptance criteria"met all acceptance criteria"
    SterilizationSterility Assurance Level (SAL) of 10^-6 (per ISO 11135:2014)"demonstrated a sterility assurance level of 10-6"
    Ethylene Oxide ResidualsMeet ISO 10993-7:2008 requirements"meet ISO 10993-7:2008 requirements"
    BiocompatibilityBiocompatible per ISO 10993-1"successfully completed to determine...is biocompatible"
    Packaging Shelf LifeMeet ASTM F1980-07, ASTM F88/F88M-09, and ASTM F2096-11 requirements for 3 months"confirmed to meet a shelf life of three months"

    2. Sample Size Used for the Test Set and Data Provenance

    The document does not specify the sample size used for the test set for any of the bench tests (simulated use, durability, etc.).
    The data provenance is not explicitly stated as retrospective or prospective, nor is the country of origin. Since these are bench tests, they are typically conducted in a laboratory setting.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications

    This information is not applicable as the studies described are bench tests on the device's physical and functional properties, not clinical studies requiring expert ground truth for interpretation of outcomes.

    4. Adjudication Method for the Test Set

    This information is not applicable as the studies described are bench tests and do not involve human interpretation or adjudication in the way clinical studies with ground truth establishment would. The tests would likely have pre-defined pass/fail criteria.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was Done

    No, an MRMC comparative effectiveness study was not done. The document explicitly states: "Clinical data was not necessary for the TruDi™ NAV Wire." The studies described are non-clinical bench tests.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was Done

    This question is not directly applicable as the TruDi™ NAV Wire is a physical medical device, not an algorithm, and its performance relies on interaction with a navigation system. The "Location Accuracy (Sensor Sensitivity)" test implicitly assesses the standalone performance of the guidewire's electromagnetic tracking capability, but it's not an algorithm in the typical sense of AI.

    7. The Type of Ground Truth Used

    For the bench tests, the "ground truth" would be established by engineering specifications, industry standards (e.g., ISO, ASTM), and design requirements. For example, a specified durability threshold or a precise dimensional measurement.

    8. The Sample Size for the Training Set

    This information is not applicable as the device is a physical guidewire and the studies described are bench tests, not machine learning studies that require a training set.

    9. How the Ground Truth for the Training Set Was Established

    This information is not applicable as there is no training set for a machine learning model.

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    K Number
    K183090
    Manufacturer
    Date Cleared
    2019-04-19

    (164 days)

    Product Code
    Regulation Number
    874.4420
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The RELIEVA TRACT™ Balloon Dilation System is an instrument intended to provide increased intranasal space to facilitate access for endonasal and transnasal procedures and/or temporarily address nasal obstruction by displacing the inferior turbinate and lower nasal septum. The RELIEVA TRACT™ Balloon Dilation System is intended for use in ages 17 years or older.

    Device Description

    The RELIEVA TRACT™ Balloon Dilation System is a single-use, sterile device, which is intended to provide increased intranasal space to facilitate access for endonasal and transnasal procedures and/or temporarily address nasal obstruction by displacing the inferior turbinate and lower nasal septum. It is intended for use in ages 17 years or older. The RELIEVA TRACT™ Balloon Dilation System is composed of:

    • A RELIEVA TRACT™ Balloon Catheter, which consists of an integrated shaft system and a high-pressure balloon near the distal tip. The shaft is a coaxial catheter. The outer lumen is used for inflation of the balloon with sterile water or saline via the ACCLARENT® Balloon Inflation Device (K090660). The inner lumen permits the use of the RELIEVA TRACT™ Stylet to facilitate advancement of the balloon catheter to the target location, such as the nasal passage in the region of the inferior turbinate and nasal septum. The proximal end of the RELIEVA TRACT™ Balloon Catheter consists of a luer that is used for inflation of the balloon and a secondary luer that is used for stylet access. The balloon is inflated by injecting sterile water or saline through the inflation luer.
    • A RELIEVA TRACT™ Stylet, which is an optional accessory and intended to facilitate advancement of the Balloon Dilation Catheters. The proximal end has a luer connector that allows the stylet to lock into the stylet port of the balloon catheter. The distal end consists of an atraumatic tip.
    AI/ML Overview

    This document is a 510(k) Summary for a medical device, the RELIEVA TRACT™ Balloon Dilation System. The request is to describe the acceptance criteria and the study that proves the device meets those criteria, specifically concerning data validation (e.g., test set, experts, ground truth).

    However, this document does not contain information about the performance of a software or AI-based medical device, nor does it detail a study involving a test set, expert consensus for ground truth, or MRMC studies.

    This 510(k) is for a physical medical device (a balloon dilation system) and focuses on demonstrating substantial equivalence to predicate devices through non-clinical performance data (e.g., sterilization validation, biocompatibility, simulated use testing on cadavers).

    Therefore, many of the requested bullet points, which are typically relevant for the validation of AI/software medical devices, cannot be answered from the provided text. The document explicitly states:

    • "Clinical data was not necessary for the RELIEVA TRACT™ Balloon Dilation System." (Page 6)

    Below is an attempt to answer the questions based on the available information, highlighting where the requested details are not present in the document.


    Acceptance Criteria and Device Performance Study (RELIEVA TRACT™ Balloon Dilation System)

    This 510(k) summary focuses on demonstrating substantial equivalence through non-clinical performance and simulated use testing, rather than a clinical study or a study specifically validating a data-driven AI/software component with a test set and ground truth.

    1. Table of acceptance criteria and the reported device performance:

    The document broadly states that the device "met all performance acceptance criteria," and then lists types of testing performed. Specific numerical acceptance criteria for each test are not detailed in this summary.

    Acceptance Criteria Category (Implied)Reported Device Performance
    Packaging Shelf LifeMet a shelf life of 24 months in accordance with ASTM F1980-07, ASTM F88/F88M-09, and ASTM F2096-04 requirements.
    SterilizationValidated per ISO 11135:2014, demonstrating a sterility assurance level of 10^-6 (overkill, half-cycle approach). Ethylene oxide residuals met ISO 10993-7:2008 requirements.
    BiocompatibilitySuccessfully completed testing to determine the device is biocompatible per ISO 10993-1.
    Simulated Use TestingSuccessfully conducted on cadavers, verifying function according to intended use and design specifications in a simulated clinical setting. Packaging and instructions for use were also assessed.

    2. Sample size used for the test set and the data provenance:

    • Sample Size: Not specified. The document mentions "simulated use testing on cadavers." The number of cadavers or specific test instances is not provided.
    • Data Provenance: "Cadavers" are mentioned for simulated use testing. No information on country of origin or whether the testing was retrospective or prospective. Given it's simulated use, it would typically be prospective for the purpose of the study.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    • Number of Experts: Not specified.
    • Qualifications of Experts: Not specified. The simulated use testing included "evaluators" who assessed the packaging and instructions for use, but their number and qualifications (e.g., medical professionals, engineers) are not detailed.

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

    • Adjudication Method: Not specified.

    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:

    • MRMC Study: No, this type of study was not performed. This device is a physical medical instrument, not an AI/software. The document explicitly states "Clinical data was not necessary."

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

    • Standalone Performance: Not applicable. This is not an algorithm or AI device.

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

    • For the simulated use testing, the "ground truth" would implicitly be the successful navigation, deployment, and dilation of the device as per its design specifications and intended use in the cadaveric model. This would likely be assessed by professional evaluators (e.g., engineers, medical device specialists, or potentially clinicians), but the specific method (e.g., visual inspection, measurement, functional assessment against a defined standard) is not detailed, nor is it based on expert consensus in the sense of diagnostic image interpretation.

    8. The sample size for the training set:

    • Training Set: Not applicable. This is a physical device, not an AI/machine learning model that requires a training set.

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

    • Ground Truth for Training Set: Not applicable.
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    K Number
    K180948
    Manufacturer
    Date Cleared
    2018-07-20

    (100 days)

    Product Code
    Regulation Number
    882.4560
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    TruDi™ NAV Suction Instruments are intended for use with the TruDi™ Navigation System during surgical procedures in ENT medicine and skull base surgery to provide navigation of the instruments to the targeted anatomy, and evacuation of gases, liquids, and fragments.

    TruDi™ NAV Suction Instruments are intended to be used by ENT surgeons or support staff.

    Device Description

    TruDi™ NAV Suction Instruments (0°, 70°, 90°) are electromagnetically- navigated reusable devices intended to be used in conjunction with the TruDi™ Navigation System. When used with the TruDi™ Navigation System, the TruDi™ NAV Suction Instruments provide navigation of the devices to targeted anatomy and evacuate gases, liquids, and fragments. The TruDi™ Navigation System is the trade name for the ACCLARENT® ENT Navigation System cleared in K173628.

    TruDi™ NAV Suction Instrument Set consists a 0° suction instrument, 70° suction instrument, 90° suction instrument, and a single-use sterile cable called the TruDi™ NAV Cable. The TruDi™ NAV Cable may be used to connect the suction instruments to the TruDi™ Navigation System.

    The TruDi™ NAV Suction Instruments include an EM trackable single axis sensor, which is integrated at the distal tip of the device. The TruDi™ Navigation System acquires the position and orientation of the distal tip of the device and displays it in real-time view over the patient's pre-operative CT scan to confirm access of target anatomy. Following confirmation, the physician operates the surgical instrument at the target anatomical structure.

    AI/ML Overview

    The provided text is a 510(k) Premarket Notification for the TruDi™ NAV Suction Instruments. It outlines the regulatory process, device description, comparison to predicate devices, and non-clinical performance data.

    However, it does not contain information related to a study proving the device meets acceptance criteria regarding clinical performance or a Multi-Reader Multi-Case (MRMC) comparative effectiveness study, or details about the training and test sets as typically found in submissions for AI/ML-based medical devices.

    The document explicitly states: "Clinical data was not necessary for the TruDi™ NAV Suction Instruments." and "The performance data demonstrated that the device performs as intended." This indicates that substantial equivalence was primarily established through non-clinical testing and comparison to predicate devices, rather than a clinical trial involving human performance assessment with the device.

    Therefore, many of the requested details, such as sample sizes for test and training sets, expert qualifications for ground truth, adjudication methods, MRMC study results, and specifics on AI algorithm ground truth establishment, are not present in the provided text because the device is a navigation suction instrument and not an AI/ML diagnostic tool.

    I can, however, extract the acceptance criteria related to the device's physical and functional performance, along with the reported outcomes from the non-clinical tests.

    Acceptance Criteria and Reported Device Performance (Non-Clinical)

    Acceptance Criteria CategoryAcceptance CriteriaReported Device Performance
    Dimensional SpecificationsNot explicitly stated in quantitative terms but implied to be within design specifications.Met all performance acceptance criteria including dimensional specifications.
    Suction Flow PerformanceNot explicitly stated in quantitative terms but implied to be sufficient for intended use.Met all performance acceptance criteria including suction flow performance. Simulated use testing successfully tested suction performance.
    DeflectionNot explicitly stated in quantitative terms.Met all performance acceptance criteria including deflection.
    Location Accuracy (Sensor Sensitivity)≤ 2mm RMS over the entire navigation volume (as stated under "System or Instrument Accuracy Requirements"). The predicate device also provided 1.54 mm at 95% confidence and 99% reliability in controlled environment and 1.73 mm at 5% confidence and 99% reliability in simulated surgical environment.Met all performance acceptance criteria including location accuracy (sensor sensitivity). Testing was performed to verify the navigation accuracy of the subject device when used with the TruDi™ Navigation System (K173628). Performance data demonstrated the device performs as intended. Specific quantitative results matching the ≤ 2mm RMS acceptance criteria are implied to have been met.
    Reprocessing ReliabilityCapable of thorough cleaning and sterilization via specified methods, demonstrating sterility assurance level of 10⁻⁶.Reprocessing and sterilization testing was conducted and met all acceptance criteria. Sterilization process validated per AAMI/ANSI/ISO 11135:2014, demonstrating a sterility assurance level of 10⁻⁶ via steam or STERRAD methods (overkill/half-cycle).
    Electrical FunctionalityNot explicitly stated in quantitative terms.Met all performance acceptance criteria including electrical functionality.
    EEPROM VerificationNot explicitly stated in quantitative terms.Met all performance acceptance criteria including EEPROM verification.
    BiocompatibilityBiocompatible per ISO 10993-1.Biocompatibility testing was successfully completed to determine that the TruDi™ NAV Suction Instruments are biocompatible per ISO 10993-1.
    Mechanical AspectsFunctions in accordance with design specifications.Simulated use testing successfully tested the mechanical aspects of the subject device.
    Clinical Accuracy (Simulated Use)Functions in accordance with design specifications and intended use.Simulated use testing was performed with ENT surgeons and support staff, which successfully tested the clinical accuracy of the subject device. The testing demonstrated that the subject device functions in accordance with design specifications and intended use.
    TruDi™ NAV Cable FunctionalityFunctions as intended with the suction instruments.Simulated use testing successfully tested the functionality of the TruDi™ NAV cable. Testing included sensitivity and connectivity verification.
    Packaging Shelf Life (TruDi™ NAV Cable)Meet a shelf life of two months.Established through accelerated aging via ASTM F1980-07, ASTM F88/F88M-09, and ASTM F2096-04 requirements and confirmed to meet a shelf life of two months.

    Here's an analysis of the requested information based on the provided document, highlighting what is not applicable (N/A) given the nature of the device and the submission:

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

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

      • Test Set Sample Size: Not explicitly stated for specific non-clinical tests (e.g., number of instruments tested for accuracy, deflection, etc.). The mention of "simulated use testing with ENT surgeons and support staff" doesn't provide the number of participants or simulated cases.
      • Data Provenance: Not specified. As these are non-clinical tests, country of origin is less relevant than for clinical data. This was a premarket notification (510(k)) based on non-clinical performance and substantial equivalence.
    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):

      • N/A. Ground truth in the context of AI/ML diagnostic devices (e.g., disease presence/absence) is not relevant here. For the "simulated use testing," the "experts" were "ENT surgeons and support staff," who were evaluating the device's functional and mechanical performance, not establishing a diagnostic ground truth. No specific number or qualifications beyond "ENT surgeons and support staff" are provided.
    4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:

      • N/A. Adjudication methods are typically used to resolve discrepancies in expert labeling a dataset for AI/ML ground truth. This is not applicable to the non-clinical and simulated use testing described.
    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:

      • No. The document explicitly states: "Clinical data was not necessary for the TruDi™ NAV Suction Instruments." This means no MRMC study was conducted. This device is a surgical instrument, not an AI-based diagnostic tool.
    6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:

      • N/A. There is no standalone AI algorithm discussed for this device. The device itself is an instrument that works with a navigation system. Its "performance" (accuracy) is a standalone measurement of the physical system (instrument + navigation system), but this is not an AI algorithm's standalone performance in the typical sense.
    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

      • N/A. For the non-clinical tests, "ground truth" was established through engineering measurements, validated test methods (e.g., AAMI/ANSI/ISO for sterility, ASTM for packaging), and design specifications. For "clinical accuracy" in simulated use, it implies the device performed as expected by the ENT surgeons and support staff based on its design and intended function, not against a medical ground truth (like a biopsy result or patient outcome).
    8. The sample size for the training set:

      • N/A. This device does not involve a training set for an AI/ML algorithm.
    9. How the ground truth for the training set was established:

      • N/A. This device does not involve a training set for an AI/ML algorithm.
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    K Number
    K173628
    Manufacturer
    Date Cleared
    2018-03-10

    (106 days)

    Product Code
    Regulation Number
    882.4560
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The ACCLARENT® ENT Navigation System is intended for use during intranasal and paranasal image-guided navigation procedures for patients who are eligible for sinus procedures.

    Device Description

    The ACCLARENT® ENT Navigation System is intended to be used during intranasal and paranasal surgical procedures to help ENT physicians to track and display the real-time location of the tip of navigated instruments relative to pre-acquired reference images, such as CT.

    The ACCLARENT® ENT Navigation System enables ENT physicians to access sphenoid, frontal, and maxillary sinuses by using the system magnetic tracking technology, identical to the predicate device.

    The system incorporates a Navigation Console, Field Ring, Instrument Hub, Patient Tracker, Registration Probe, Field Ring and Holder, Workstation and accessories. A magnetic field generated by the Field Ring induces a current in the magnetic sensor embedded in the tip of the flexible navigated tool, which helps to accurately calculate the tool tip position. A CT image is imported and registered to the patient coordinates and a tool tip icon is displayed on top of the registered

    AI/ML Overview

    The provided document is a 510(k) premarket notification for the Acclarent® ENT Navigation System. It primarily focuses on demonstrating substantial equivalence to a predicate device (CARTO® ENT Navigation System, K161701) rather than presenting a standalone study with a novel AI model's performance.

    Therefore, many of the requested details regarding acceptance criteria, sample sizes for AI model training/testing, expert ground truth establishment, and MRMC studies are not applicable or not explicitly detailed in this type of regulatory submission. This document describes a medical device, not an AI/ML diagnostic or prognostic algorithm.

    However, I can extract the relevant information regarding the performance testing that was conducted:

    Here's a breakdown of the available information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly present a table of "acceptance criteria" for an AI model's performance in terms of metrics like sensitivity, specificity, or AUC, as it's a navigation system. Instead, it describes non-clinical tests performed to ensure the system functions according to design specifications and demonstrates safety and effectiveness.

    Acceptance Criterion (Type of Test)Reported Device Performance / Outcome
    Proof of Design electrical testsVerified all hardware modules perform within specifications.
    Location Accuracy testsElectromagnetic locations compared to a very accurate robot system over the entire navigation volume. Verified the system precision claim.
    Software functional testsCovered complete system functionality, including error handling, usability, and time performance (latency).
    Safety, EMC, and mechanical testsPerformed by a nationally recognized testing laboratory. Verified compliance with safety and EMC standards for medical devices.
    Simulated use accuracy testA complete CT image registration and instrument navigation workflow was performed. Verified the overall accuracy of the system.
    Pre-clinical (cadaver) testsDesigned to mimic surgical procedures using the device in a simulated clinical environment. Assessed execution of a complete sinuplasty procedure workflow and qualitatively estimated system clinical accuracy.
    Overall ConclusionThe proposed ACCLARENT® ENT Navigation System passed all tests in accordance with appropriate test criteria and standards. The modified device did not raise new questions of safety or effectiveness.

    2. Sample Size Used for the Test Set and Data Provenance

    • Test Set Sample Size: Not explicitly stated in terms of number of cases or patients. For the "Location Accuracy tests," it refers to "the entire navigation volume," suggesting a comprehensive evaluation within the system's operational space. For "Simulated use accuracy test" and "Pre-clinical (cadaver) tests," the number of cadavers or simulated procedures is not specified.
    • Data Provenance: The tests are "nonclinical" and "pre-clinical (cadaver) tests." This suggests controlled laboratory and cadaveric environments, which do not typically involve patient data from specific countries in the way an AI model would. There's no indication of retrospective or prospective patient data collection for these specific performance tests.

    3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications

    • Number of Experts: Not applicable, as the "ground truth" for a navigation system's performance is established through physical measurements (e.g., comparison to a robot system for location accuracy) and functional assessments, not subjective expert annotations of medical images for diagnostic purposes.
    • Qualifications of Experts: Not specified or applicable in the context of hardware/software functional and accuracy testing.

    4. Adjudication Method for the Test Set

    • Adjudication Method: Not applicable. Performance is measured against engineering specifications and physical accuracy metrics, not through expert consensus on AI outputs.

    5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study Was Done

    • MRMC Study: No, an MRMC comparative effectiveness study was not performed. This type of study is typically done for diagnostic imaging AI algorithms to assess their impact on human reader performance. The Acclarent ENT Navigation System is a surgical navigation device.
    • Effect Size of Human Readers Improvement with AI vs. Without AI Assistance: Not applicable, as this is not an AI diagnostic assistance tool.

    6. If a Standalone (i.e., Algorithm Only Without Human-in-the-Loop Performance) Was Done

    • Standalone Performance: The non-clinical tests (electrical, location accuracy, software functional, safety, EMC, mechanical) represent standalone performance of the device's components and system accuracy against established engineering parameters. The "Pre-clinical (cadaver) tests" involved human interaction but were qualitative assessments of workflow and clinical accuracy, not a comparative "human-in-the-loop" study in the AI sense.

    7. The Type of Ground Truth Used

    • Ground Truth:
      • Engineering Specifications: For electrical, software functional, safety, EMC, and mechanical tests, the ground truth is defined by the device's design specifications and relevant industry/regulatory standards.
      • Precise Robotic Measurements: For "Location Accuracy tests," the ground truth was provided by a "very accurate robot system."
      • Simulated Clinical Workflows: For "Simulated use accuracy test" and "Pre-clinical (cadaver) tests," the ground truth involves assessing the system's ability to accurately guide instruments relative to pre-acquired CT images within a controlled, mimicked surgical environment. This is less about a single "ground truth" label and more about functional validation.

    8. The Sample Size for the Training Set

    • Training Set Sample Size: Not applicable. This document describes a medical device, not an AI model that undergoes a training phase with a specific dataset.

    9. How the Ground Truth for the Training Set Was Established

    • Ground Truth for Training Set: Not applicable, as this is not an AI model.
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