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510(k) Data Aggregation
(245 days)
Becton, Dickinson and Company
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(66 days)
Becton, Dickinson and Company
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(90 days)
Becton, Dickinson and Company
The BD Plastipak™ Syringe is intended for use by health care professionals for general purpose fluid aspiration/injection.
The BD Plastipak™ Syringe is a three-piece, single use, sterile, hypodermic syringe with a 6% (Luer) male connector in 20 mL and 50 mL eccentric luer slip tip configurations. The BD Plastipak™ Syringe is intended for use by health care professionals for general purpose fluid aspiration/injection. The syringe assembly consists of a lubricated polypropylene barrel with a graduated scale, a lubricated synthetic rubber stopper and a polypropylene plunger rod. The plunger rod is pulled back to aspirate fluids or depressed to inject or expel fluids. The syringe barrel incorporates a male 6% (Luer) connector which is connectable to a compatible female 6% (Luer) connector. The BD Plastipak™ Syringe is provided sterile by Ethylene Oxide Gas (ETO) sterilization method.
The provided text is a 510(k) Clearance Letter for a medical device (BD Plastipak™ Syringe). It details the device's characteristics, intended use, and comparison to a predicate device. However, it does not describe an AI/ML-driven medical device or a study involving human readers or expert consensus for ground truth establishment.
The document discusses bench performance testing and biocompatibility tests for a physical device (syringe), not a software or AI-based diagnostic tool. Therefore, many of the requested criteria (like sample size for test/training set, number of experts, adjudication method, MRMC study, standalone performance, ground truth types) are not applicable to this specific submission.
Despite the irrelevance of some questions to the provided document, I will structure the answer based on the questions asked, indicating "Not Applicable" or providing the information that is present in the document.
Here's an analysis of the provided 510(k) clearance letter in the context of the requested information about acceptance criteria and study data:
This 510(k) clearance letter pertains to a physical medical device, the BD Plastipak™ Syringe, not an AI/ML-driven diagnostic or image analysis tool. As such, many of the typical acceptance criteria and study methodologies applicable to AI models (e.g., ground truth established by experts, MRMC studies, training/test set sizes for algorithms, human reader improvement with AI assistance) are not relevant or described in this document.
The "study" referenced in the document primarily consists of non-clinical performance and biocompatibility testing to demonstrate the substantial equivalence of the new syringe (with a changed barrel resin) to a previously cleared predicate syringe.
1. Table of Acceptance Criteria and Reported Device Performance
The document states, "The subject device met all the predetermined acceptance criteria for the above listed performance and biocompatibility tests." However, it does not explicitly list the quantitative acceptance criteria or the specific numerical performance results for each test. It only lists the tests performed and the standards they adhere to.
Test Category | Test | Purpose (as described) | Acceptance Criteria (Not Explicitly Stated Quantitatively) | Reported Performance (Not Explicitly Stated Quantitatively) |
---|---|---|---|---|
Performance Testing | Breakout Force | ISO 7886-1:2017- Performance evaluation of force to operate the piston. | Met predetermined criteria (implied by "met all") | Subject device performed equivalent to predicate (implied) |
Sustaining Force | ISO 7886-1:2017- Evaluation of force to operate the piston. | Met predetermined criteria (implied by "met all") | Subject device performed equivalent to predicate (implied) | |
Leakage Past Stopper | ISO 7886-1:2017- Evaluation of Freedom from air and liquid leakage past plunger stopper. | Met predetermined criteria (implied by "met all") | Subject device performed equivalent to predicate (implied) | |
Volumetric Accuracy | ISO 7886-1:2017- Evaluation of Volumetric Accuracy | Met predetermined criteria (implied by "met all") | Subject device performed equivalent to predicate (implied) | |
Dead Space | ISO 7886-1:2017- Evaluation of residual volume | Met predetermined criteria (implied by "met all") | Subject device performed equivalent to predicate (implied) | |
Luer Leakage | ISO 80369-7:2021 - Evaluation of the luer fittings for leakage | Met predetermined criteria (implied by "met all") | Subject device performed equivalent to predicate (implied) | |
Stress Cracking | ISO 80369-7:2021- Evaluation of the luer fittings for stress cracking | Met predetermined criteria (implied by "met all") | Subject device performed equivalent to predicate (implied) | |
Resistance to separation from axial load | ISO 80369-7:2021- Evaluation of the luer fitting for separation when subjected to axial force. | Met predetermined criteria (implied by "met all") | Subject device performed equivalent to predicate (implied) | |
Biocompatibility Testing | Cytotoxicity | ISO 10993-5:2009- Biological evaluation of medical devices - Part 5: Tests for in vitro cytotoxicity | Met predetermined criteria (implied by "met all") | Subject device performed equivalent to predicate (implied) |
Sensitization | ISO 10993-10:2021- Biological Evaluation of Medical Devices - Part 10: Tests for Skin Sensitization | Met predetermined criteria (implied by "met all") | Subject device performed equivalent to predicate (implied) | |
Intracutaneous Reactivity | ISO 10993-23:2021- Biological evaluation of medical devices- Test for Irritation | Met predetermined criteria (implied by "met all") | Subject device performed equivalent to predicate (implied) | |
Acute Systemic Toxicity | ISO 10993-11:2017- Biological evaluation of medical devices — Part 11: Tests for systemic toxicity | Met predetermined criteria (implied by "met all") | Subject device performed equivalent to predicate (implied) | |
Material Mediated Pyrogenicity | ISO 10993-11:2017- Biological evaluation of medical devices — Part 11: Tests for systemic toxicity USP43-NF38 Pyrogen Test (USP Rabbit Test) | Met predetermined criteria (implied by "met all") | Subject device performed equivalent to predicate (implied) | |
Hemocompatibility | ISO 10993-4:2017- Biological evaluation of medical devices Part 4: Selection of tests for interactions with blood ASTM F756-17- Standard Practice for Hemolytic Properties of Materials | Met predetermined criteria (implied by "met all") | Subject device performed equivalent to predicate (implied) |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size for Test Set: Not specified in the provided document. The tests are "bench performance testing" on various syringe units.
- Data Provenance: Not specified, but generally, bench testing for physical devices is conducted in a controlled lab environment by the manufacturer. It is non-clinical.
- Retrospective or Prospective: Not applicable for this type of physical device testing.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
- Not Applicable. Ground truth for this physical device testing is established through standardized laboratory test methods and measurements against international or internal specifications, not by human experts interpreting clinical data.
4. Adjudication Method for the Test Set
- Not Applicable. (See point 3)
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. This is not an AI/ML device. Therefore, no MRMC study or assessment of human reader improvement with AI assistance was conducted or is relevant.
6. If a Standalone (i.e. algorithm only without human-in-the loop performance) was done
- No. This is not an AI/ML device. Therefore, no standalone algorithm performance was assessed. The performance tests are for the physical syringe itself.
7. The Type of Ground Truth Used
- The "ground truth" for this device's performance is based on measurements against established engineering specifications and international standards (e.g., ISO, ASTM, USP) for physical and material properties (e.g., force, leakage, volume accuracy, biocompatibility reactions). It is not based on expert consensus, pathology, or outcomes data in the clinical sense.
8. The Sample Size for the Training Set
- Not Applicable. This is not an AI/ML device. There is no concept of a "training set" in the context of the reported non-clinical bench testing for a physical syringe.
9. How the Ground Truth for the Training Set was Established
- Not Applicable. (See point 8)
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(275 days)
Becton Dickinson and Company
The BD Vacutainer® Eclipse™ Blood Collection Needle is a sterile, single-use, medical device specifically intended to be used by healthcare professionals experienced with venipuncture on adults and children in accordance with the instructions for use for the collection of multiple venous blood samples into evacuated blood collection tubes, for the purpose of in vitro diagnostic testing. The needle is designed with an attached safety shield, which can be activated to cover the needle immediately after venipuncture to provide protection from accidental needlesticks.
The BD Vacutainer® Eclipse™ Blood Collection Needle includes a one-piece double-ended needle/cannula fixed to a plastic hub. One end of the cannula is the intravenous (IV) end, and the other is the non-patient (NP) end covered with a sleeve. The whole device is encased in two plastic covers; one at each end of the cannula to protect the device, with a tamper-evident seal placed around the plastic covers. The protective cover/cap is provided to prevent damage and maintain the needle sterility before the point of use. A safety shield is connected to a hinge on a collar attached to the hub. The safety shield is manually activated by locking over the needle after removal from the vein, providing protection from accidental needlestick injuries.
The BD Vacutainer® Eclipse™ BCN consists of:
- Double-ended hollow stainless-steel cannula
- Threaded polystyrene hub
- Polystyrene collar
- Protective needle sleeve that interrupts blood flow between filling multiple tubes
- Safety shield that can be activated to cover the needle immediately after venipuncture to protect against accidental needle sticks during normal handling and disposal
- Pre-attached holder (for user convenience in some models)
The BD Vacutainer® Eclipse™ Blood Collection Needle with Pre-Attached Holder (PAH) consists of a BD Vacutainer® Eclipse™ Blood Collection Needle threaded and bonded to a BD Vacutainer® One Use Holder. The Eclipse™ BCN with PAH allows for the immediate use of the product without the need for assembling the two components. This provides increased convenience to the user and is designed to help minimize the exposure of the user to the non-patient (NP) end of the needle.
The provided FDA 510(k) clearance letter and summary for the BD Vacutainer® Eclipse™ Blood Collection Needle confirm its clearance based on substantial equivalence to a predicate device. However, this document does not contain specific acceptance criteria, reported device performance data, detailed study designs, or ground truth information typical of a clinical performance study for an AI/ML medical device.
The document focuses on demonstrating that the new device is as safe and effective as a legally marketed predicate device, primarily through non-clinical performance testing and biocompatibility testing, rather than clinical trials comparing diagnostic accuracy or AI performance.
Therefore, many of the requested details for an AI/ML device study, such as sample sizes for test sets, data provenance, number of experts for ground truth, adjudication methods, MRMC studies, and training set details, are not applicable or not provided in this type of submission.
Here's a breakdown based on the information available in the document, acknowledging the limitations for an AI/ML device context:
Device: BD Vacutainer® Eclipse™ Blood Collection Needle
The submission is for a medical device (blood collection needle) and not an AI/ML driven diagnostic device. Therefore, the detailed breakdowns requested for AI/ML performance studies are largely not applicable. The provided document details non-clinical performance and biocompatibility studies to demonstrate substantial equivalence to a predicate device.
1. Table of Acceptance Criteria and Reported Device Performance
The document performs non-clinical (engineering and material) tests to demonstrate that the device meets design specifications and relevant standards. The "acceptance criteria" are implied by compliance with these standards and successful completion of the tests.
Acceptance Criteria (Implied by Standard/Test) | Reported Device Performance |
---|---|
Biocompatibility: | Conforms to ISO 10993-1, -2, -4, -5, -9, -10, -11, -12, -13, -15, -17, -18, -23. Cytotoxicity, Sensitization, Irritation, Acute Systemic Toxicity, Material-mediated Pyrogenicity and Hemocompatibility all demonstrated acceptable. |
Sterility: | Gamma Irradiation to Sterility Assurance Level (SAL) of 10⁻⁶. Compliant with ISO 556-1, ISO 11137-1, ISO 11137-2, ISO 11737-1, ISO 11737-2. |
Sharps Injury Protection: | Complies with ISO 23908:2013 and FDA Guidance "Medical Devices with Sharps Injury Prevention Features (August 2005)". Demonstrated by "Sharps Injury Protection Feature/ ISO 23908– Simulated Use testing". |
Needle Tubing Standards: | Complies with ISO 9626:2016 for Stainless steel needle tubing. Confirmed by "ISO 9626 - Stainless Steel Needle Tubing testing". |
Packaging/Sterile Barrier: | Complies with ANSI AAMI ISO 11607-1 and ISO 11607-2. Confirmed by "Sterile Barrier Performance" testing. |
Mechanical Performance: | Acceptable performance demonstrated for: Cannula-Hub Axial Pull Force, Safety Shield Engagement, Safety Shield Override, Cantilever Force to Break Hub, Sleeve Function, Torque to Break Hub, Torque to Unseat Holder, Holder Spinout from Needle Hub, IV and NP Shield Pull Force, IV and NP Label Torque. |
Shelf Life: | Demonstrated acceptable performance over 5 years (Eclipse™ BCN) and 3 years (Eclipse™ Pre-Attached) through shelf life testing. |
Specific AI/ML Study Details (Not Applicable for this Device)
As this is a traditional medical device (blood collection needle) and not an AI/ML driven diagnostic device, the following points are not applicable and therefore, no information is provided in the document:
- Sample sizes used for the test set and the data provenance: Not applicable. Performance was evaluated through non-clinical bench testing and material compatibility.
- Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. Ground truth for a physical device's performance is based on engineering specifications, material standards, and validated testing protocols.
- Adjudication method (e.g., 2+1, 3+1, none) for the test set: Not applicable.
- If a multi reader multi case (MRMC) comparative effectiveness study was done: No, not applicable. This is for an AI/ML comparative study, which this device is not.
- If a standalone (i.e., algorithm only without human-in-the-loop performance) was done: Not applicable.
- The type of ground truth used (expert consensus, pathology, outcomes data, etc): For this device, ground truth is established by engineering specifications, international standards (e.g., ISO, AAMI), material properties, and validated test methods.
- The sample size for the training set: Not applicable. There is no AI/ML model for this device that requires a training set.
- How the ground truth for the training set was established: Not applicable.
In summary, the provided document demonstrates the BD Vacutainer® Eclipse™ Blood Collection Needle meets its acceptance criteria through a comprehensive set of non-clinical performance tests and biocompatibility evaluations, ensuring it is safe and effective and substantially equivalent to a predicate device. The information requested regarding AI/ML specific study details is not part of this type of traditional device approval process.
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(181 days)
Becton, Dickinson and Company
The BD Veritor™ System for SARS-CoV-2 is a chromatographic digital immunoassay for the rapid, qualitative detection of SARS-CoV-2 nucleocapsid protein antigens directly in anterior nasal swab specimens from individuals with signs and symptoms of upper respiratory infection (i.e., symptomatic). The test is intended for use as an aid in the diagnosis of SARS-CoV-2 infections (COVID-19) in symptomatic individuals when either: tested at least twice over three days with at least 48 hours between tests; or when tested once, and negative by the BD Veritor™ System for SARS-CoV-2 and followed up with a molecular test.
A negative test result is presumptive and does not preclude SARS-CoV-2 infection; it is recommended these results be confirmed by a molecular SARS-CoV-2 assay.
Positive results do not rule out co-infection with other bacteria or viruses and should not be used as the sole basis for diagnosis, treatment, or other patient management decisions.
Performance characteristics for SARS-CoV-2 were established between April 2024 and August 2024 when SARS-CoV-2 Omicron was the predominant SARS-CoV-2 variant in circulation. Performance characteristics may vary with newly emerging SARS-CoV-2 virus variants.
The BD Veritor™ System for SARS-CoV-2 is a rapid (approximately 15 minutes) chromatographic digital immunoassay for the direct detection of the presence or absence of SARS-CoV-2 antigens in anterior nasal swab specimens taken from patients with signs and symptoms of upper respiratory infection (i.e., symptomatic) who are suspected of COVID-19 by their healthcare provider. The test is intended for use with an opto-electronic interpretation instrument, the BD Veritor™ Plus Analyzer Instrument and is not interpreted visually.
- When specimens are processed and added to the test device, SARS‑CoV‑2 antigens present in the specimen bind to biotinylated antibodies and antibodies conjugated to detector particles in the test strip.
- The biotinylated antibody‑antigen‑conjugate complexes migrate across the test strip to the reaction area and are captured by a line of streptavidin bound on the membrane.
- A positive result is determined by the BD Veritor™ Plus Analyzer when antigen‑conjugate is deposited at the Test "T" position and a control conjugate is deposited at the Control "C" position on the assay device.
- The instrument analyzes and corrects for non‑specific binding and detects positives not recognized by the unaided eye to provide an objective result.
Procedures to evaluate test devices depend on the BD Veritor™ Plus Analyzer workflow configuration chosen. In Analyze Now mode, the instrument evaluates assay devices after manual timing of their development. In Walk Away mode, devices are inserted immediately after application of the specimen, and timing of assay development and analysis is automated. Additionally, connection of a BD Veritor™ Plus Analyzer to a printer or IT system is possible if desired. Additional result documentation capabilities are possible with the integration of a BD Veritor™ barcode scanning enabled module.
The Analyzer uses a proprietary algorithm that subtracts the nonspecific signal at the negative control line from the signal present at the test line. If the resultant test line signal is above a preselected cutoff, the specimen is scored as positive. If the resultant test line signal is below or equal to the cutoff, the specimen is scored as negative. Use of the active negative control feature allows the BD Veritor™ Plus Analyzer to correctly interpret test results that cannot be scored visually because the human eye is unable to accurately perform the subtraction of the nonspecific signal. The Analyzer measures the amount of light reflected from various zones along the assay strip. The measurement of the assay background zone is an important factor during the test interpretation as the reflectance value is compared to that of the control and test zones.
The provided FDA 510(k) clearance letter and summary describe the BD Veritor System for SARS-CoV-2. Here's an analysis of the acceptance criteria and the study that proves the device meets those criteria:
1. Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria are not explicitly stated as distinct numerical targets in the document. However, based on the clinical study results and FDA clearance, the implicit acceptance criteria for clinical performance are related to the confidence intervals for Positive Percent Agreement (PPA) and Negative Percent Agreement (NPA). The reported device performance is presented below:
Performance Metric | Implicit Acceptance Criteria (based on 95% C.I. reported) | Reported Device Performance |
---|---|---|
PPA | Lower bound of 95% C.I. > 77.2% | 84.0% (C.I.: 77.2%, 89.1%) |
NPA | Lower bound of 95% C.I. > 99.0% | 99.7% (C.I.: 99.0%, 99.9%) |
Note: The document does not explicitly state numerical acceptance thresholds for PPA and NPA (e.g., "PPA must be > 80%"). Therefore, the "Implicit Acceptance Criteria" are inferred from the demonstrated performance and the fact that the device received clearance. The FDA typically evaluates these metrics within acceptable ranges for diagnostic tests.
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size for Test Set: 1,032 direct anterior nasal swabs.
- Data Provenance: The samples were prospectively collected from individual symptomatic patients across 15 geographically diverse areas across the United States between April and August 2024.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications
The document does not specify the number of experts used to establish the ground truth. The ground truth was established by an FDA-cleared SARS-CoV-2 RT-PCR test. For the false positive/negative re-testing, it broadly states "a second RT-PCR method," implying multiple tests might have been performed to confirm results without specifying expert involvement in interpreting these specific results beyond the RT-PCR outcome itself.
4. Adjudication Method for the Test Set
The primary ground truth for the clinical study was established by an FDA-cleared SARS-CoV-2 RT-PCR test without explicit mention of expert adjudication for every case. However, there was a form of adjudication for discordant results:
- False Positive Adjudication: The three BD Veritor System for SARS-CoV-2 false positive results were retested with a second RT-PCR method and were confirmed negative. This suggests a method where initial discrepancies against the reference method were independently verified.
- False Negative Adjudication: The 23 BD Veritor System for SARS-CoV-2 false negative results were retested with a second RT-PCR method in which 14 were confirmed positive and 9 were negative.
This indicates a process of re-testing or confirmation for discordant results, which serves as a form of adjudication.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No, a multi-reader multi-case (MRMC) comparative effectiveness study comparing human readers with and without AI assistance (or similar comparative effectiveness of human readers with vs. without the device) was not explicitly mentioned or described in the provided document. The BD Veritor System for SARS-CoV-2 uses an instrument (BD Veritor™ Plus Analyzer) for interpretation, replacing visual interpretation with an automated read. The comparison is between the device's performance and a reference RT-PCR, not between human readers with and without assistance from the device.
6. Standalone (Algorithm Only) Performance Study
Yes, a standalone study was done. The entire clinical performance study (Table 9 and 11) is a standalone study, as it evaluates the performance of the BD Veritor System for SARS-CoV-2 (algorithm/device only) compared to a reference RT-PCR without human interpretation of the lateral flow assay itself. The BD Veritor™ Plus Analyzer instrument is explicitly stated to read and interpret the results, and the device "is not interpreted visually."
7. Type of Ground Truth Used
The ground truth used for the clinical study was an FDA-cleared SARS-CoV-2 RT-PCR test (molecular test results).
8. Sample Size for the Training Set
The document does not specify a sample size for a training set. This submission is for a device, and the analytical and clinical studies described are for validation of the device's performance, not for developing or training an AI/ML algorithm in the context of a typical AI/ML development pipeline. The device uses a "proprietary algorithm" for signal subtraction and interpretation, but it's not presented as a machine learning model that requires a distinct training set in the typical sense.
9. How the Ground Truth for the Training Set Was Established
Since no specific training set and its ground truth establishment are discussed in the context of AI/ML model training, this information is not applicable/provided based on the document. The "proprietary algorithm" for the instrument is described in terms of processing reflectance data and applying a preselected cutoff, and its development process (including any data used for internal calibration or parameter setting) is not detailed here.
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(90 days)
Becton, Dickinson and Company
The BD Phoenix™ Automated Microbiology System is intended for in vitro quantitative determination of antimicrobial susceptibility by minimal inhibitory concentration (MIC) of most Gram-negative aerobic and facultative anaerobic bacteria isolates from pure culture for Enterobacterales and Non-Enterobacterales and most Gram-positive bacteria isolates from pure culture belonging to the genera Staphylococcus, Enterococcus, and Streptococcus.
This premarket notification is for the BD Phoenix Automated Microbiology System with Imipenem-relebactam at a concentration of 0.0625/4-16/4 µg/mL. Testing is indicated for Acinetobacter calcoaceticus-baumannii complex, Enterobacterales, and Pseudomonas aeruginosa, as recognized by the FDA Susceptibility Test Interpretive Criteria (STIC).
The BD Phoenix Automated Microbiology System - GN Imipenem-relebactam (0.0625/4 - 16/4 µg/mL) has demonstrated acceptable performance with the following organisms:
- Acinetobacter calcoaceticus-baumannii complex
- Enterobacterales (Citrobacter amalonaticus, Citrobacter braakii, Citrobacter farmeri, Citrobacter freundii, Citrobacter koseri, Citrobacter youngae, Enterobacter cloacae, Escherichia coli, Klebsiella aerogenes, Klebsiella oxytoca, Klebsiella pneumoniae, and Serratia marcescens)
- Pseudomonas aeruginosa
The Phoenix AST method is a broth-based microdilution test. The Phoenix panel is a sealed and self-inoculating molded polystyrene tray with 136 micro-wells containing dried reagents. The ID/AST combination panel includes an ID side (51 wells) with dried substrates for bacterial identification and an AST side (85 wells). The AST panel contains a wide range of two-fold doubling dilution concentrations of antimicrobial agents and growth and fluorescent controls at appropriate well locations. The AST panel does not include wells for isolate identification.
The Phoenix System utilizes a redox indicator for the detection of organism growth in the presence of an antimicrobial agent. The organism to be tested must be a pure culture and be preliminarily identified as Gram-positive or Gram-negative. Colonies are then suspended in ID broth and equated to a 0.5 McFarland suspension using a nephelometer device. A further dilution is made into AST broth (a cation-adjusted formulation of Mueller-Hinton broth containing 0.010% Tween 80), to which the redox-buffered oxidation-reduction AST indicator solution is added producing a blue color in the wells. The concentration of organisms in the final AST broth suspension is approximately 5 X 10^5 CFU/mL.
The Phoenix AST Broth is poured into the inoculation port of the AST panel and the inoculum flows into the panel, filling panel wells. Polyethylene caps are applied to seal the inoculation ports. An air admittance port is located in the panel lid to ensure adequate oxygen tension in the panel for the duration of the test. Inoculated panels are barcode scanned and loaded into the BD Phoenix Automated Microbiology System instrument where panels are continuously incubated at 35 °C ± 1 °C.
Continuous measurements of changes to the indicator as well as bacterial turbidity are used in the determination of bacterial growth. The instrument takes readings every 20 minutes. Organisms growing in the presence of a given antimicrobial agent reduce the indicator (changing it to a pink color). This signals organism growth and resistance to that antimicrobial agent. Organisms killed or inhibited by the antimicrobial agent do not cause reduction of the indicator and therefore do not produce a color change. The Phoenix instrument reads and records the results of the antimicrobial tests contained in the panel and interprets the reactions (based on the organism identification) to give a minimal inhibitory concentration (MIC) value and category interpretations (susceptible, intermediate, resistant, or not susceptible). AST results are available within 16 hours. This is an auto read result; no manual readings are possible with this system.
Additional comments concerning specific organism/antimicrobial combinations are provided from the software-driven expert system (BDXpert), using rules derived from CLSI documentation and/or the FDA-approved drug labeling.
The provided FDA 510(k) clearance letter describes the acceptance criteria and the study that proves the BD Phoenix™ Automated Microbiology System - GN Imipenem-relebactam (0.0625/4 - 16/4 µg/mL) device meets those criteria for Antimicrobial Susceptibility Testing (AST).
Here's a breakdown of the requested information:
1. Table of Acceptance Criteria and Reported Device Performance
The core acceptance criteria for AST devices are related to Essential Agreement (EA) and Category Agreement (CA) with a reference method. The study aims to demonstrate that the device's performance is substantially equivalent to the established reference method.
Performance Metric | Acceptance Criteria (from AST Special Controls Guidance document) | Reported Device Performance (Combined Clinical & Challenge Data) |
---|---|---|
Essential Agreement (EA) Rate | Overall EA and CA rates greater than 90% | Acinetobacter baumannii/calcoaceticus complex: 96.7% |
Enterobacterales: 93.0% | ||
Pseudomonas aeruginosa: 99.0% | ||
Category Agreement (CA) Rate | Overall EA and CA rates greater than 90% | Acinetobacter baumannii/calcoaceticus complex: 97.8% |
Enterobacterales: 98.6% | ||
Pseudomonas aeruginosa: 97.9% | ||
Major Discrepancies (Maj) | Should be minimized (no specific percentage stated for general acceptance, but ideally very low or 0%) | 0 (for combined clinical and challenge data) |
Very Major Discrepancies (Vmj) | Should be minimized (no specific percentage stated for general acceptance, but ideally very low or 0%) | 0 (for combined clinical and challenge data) |
Minor Discrepancies (Min) | Should be minimized (no specific percentage stated for general acceptance) | 19 (for combined clinical and challenge data across all organisms) |
Reproducibility | Greater than 95% (± 1 dilution) agreement when compared to the test mode | 100% (Manual PhoenixSpec Nephelometer) |
100% (Phoenix AP Instrument) | ||
Growth Failure Rate | Not explicitly stated an acceptance criterion, but 0% reported is excellent. | 0% |
Quality Control Testing (QC Organisms) | Results acceptable for greater than 95% of tests. | Met acceptance criteria (explicitly stated for QC results in document). |
Note: The document mentions "The performance of the BD Phoenix Imipenem-relebactam met the combined acceptance criteria for all tested organisms, with overall EA and CA rates greater than 90%." This implicitly sets the 90% for EA and CA as the acceptance threshold.
2. Sample Size Used for the Test Set and Data Provenance
-
Clinical Isolates (Test Set):
- Total: 1,111 isolates (862 fresh, 249 stock)
- Organisms:
- Acinetobacter baumannii/calcoaceticus complex (83 isolates)
- Citrobacter freundii (21 isolates)
- Citrobacter species (9 isolates)
- Citrobacter koseri (26 isolates)
- Enterobacter cloacae (60 isolates)
- Escherichia coli (359 isolates)
- Klebsiella aerogenes (58 isolates)
- Klebsiella oxytoca (47 isolates)
- Klebsiella pneumoniae (198 isolates)
- Pseudomonas aeruginosa (176 isolates)
- Serratia marcescens (74 isolates)
- Provenance: Conducted at three U.S. clinical sites. Data consists of fresh and stock isolates, implying a mix of retrospective (stock) and prospective (fresh) collection.
-
Challenge Isolates (Test Set):
- Total: 85 isolates (these are specific strains with known resistance mechanisms)
- Organisms:
- Acinetobacter baumannii (7 isolates)
- Citrobacter freundii (2 isolates)
- Citrobacter koseri (2 isolates)
- Enterobacter cloacae (12 isolates)
- Escherichia coli (19 isolates)
- Klebsiella aerogenes (4 isolates)
- Klebsiella pneumoniae (24 isolates)
- Pseudomonas aeruginosa (15 isolates)
- Provenance: Tested at "each study site" (implying the same three U.S. clinical sites as for clinical isolates). These are typically retrospective isolates chosen to challenge the system.
-
Reproducibility Isolates:
- Total: 15 on-scale isolates (tested in triplicate over three days at three sites, for 405 data points).
- Organisms: Enterobacter cloacae (2), Escherichia coli (5), Klebsiella aerogenes (1), Klebsiella pneumoniae (3) and Pseudomonas aeruginosa (4).
- Provenance: Conducted at three clinical sites (for manual method) and three internal BD sites (for Phoenix AP instrument).
3. Number of Experts Used to Establish Ground Truth and Qualifications
This type of medical device (automated microbiology system for AST) does not typically involve human experts to establish "ground truth" in the same way an imaging AI might.
- Ground Truth Establishment: The ground truth for antimicrobial susceptibility testing is established by a reference method, specifically the CLSI frozen broth microdilution reference panel, prepared according to CLSI M07 guidelines. This is a standardized, laboratory-based method, not dependent on expert visual interpretation.
- No "experts" in the human-reader sense are described as establishing ground truth for the test set. The expertise lies in adherence to CLSI standards and methodologies.
4. Adjudication Method for the Test Set
- No human adjudication method (e.g., 2+1, 3+1) is mentioned or applicable for this type of device.
- The comparison is directly between the result from the BD Phoenix system and the CLSI frozen broth microdilution reference panel. Discrepancies are categorized as minor, major, or very major based on established AST definitions (Essential Agreement and Category Agreement).
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
- No, an MRMC study was NOT done. This type of study is relevant for diagnostic imaging interpretation devices where human reader performance is a key metric. For an automated microbiology system, the comparison is to a "gold standard" laboratory method (CLSI microdilution), not to human interpretation or human improvement with AI assistance.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
- Yes, this is essentially a standalone (algorithm only) performance study. The BD Phoenix system is an automated device that reads and interprets the results without human subjective input in the interpretative step. The "human-in-the-loop" aspects are limited to initial inoculum preparation (though automated options are also available and validated) and loading the panel, not interpreting the results. The comparison is the device's output (MIC and category) against the reference method.
7. The Type of Ground Truth Used
- The ground truth used is the CLSI frozen broth microdilution reference panel, which serves as the gold standard reference method for antimicrobial susceptibility testing.
8. The Sample Size for the Training Set
- The document does not explicitly state a separate "training set" sample size. For this type of automated system, which uses a growth-based detection principle rather than a machine learning model trained on large datasets of examples, the concept of a distinct "training set" in the modern AI sense is typically not applicable.
- The system's "training" or development would involve extensive internal R&D, algorithm refinement, and validation using proprietary data over time, which precedes a 510(k) submission. The data provided in the 510(k) is for the validation/test set to demonstrate performance.
9. How the Ground Truth for the Training Set Was Established
- As a conventional, growth-based automated system rather than a machine learning device, there isn't a "training set" with ground truth established in the sense of human labeling or annotation.
- The system operates based on predefined biochemical reactions and growth kinetics, and its algorithms are built upon established microbiological principles and CLSI guidelines. Any internal development and testing would likewise use CLSI reference methods to establish expected outcomes for algorithm development and calibration.
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(115 days)
Becton Dickinson and Company
The BD Vacutainer® Multiple Sample Luer Adapter is a sterile, single-use, non-invasive medical device intended to be connected with BD Vacutainer® brand needle holders, to enable blood collection from venous access devices, such as needles and blood collection sets or catheters with female luer connectors into blood collection tubes or blood culture bottles for the purpose of in vitro diagnostic testing. These devices are intended to be used by healthcare professionals.
The BD Vacutainer® Multiple Sample Luer Adapter consists of a luer-slip fitting (male) which mates with the female Luer connector of venous access devices, and an NP (non-patient) cannula, which punctures the stopper of the evacuated tube(s), or the septum of a blood culture bottle(s) to collect blood.
The NP cannula of the device is lubricated and has a sleeve that recovers over the cannula to prevent leakage during blood collection in-between tubes and/or bottles.
Each end of the device is enclosed in a plastic shield, which join together to fully protect the device. A tamper evident label secures the two shields together and allows identification of whether the sterile barrier has been compromised.
The device consists of the following components:
- Non-patient (NP) Cannula
- Sleeve
- Luer Hub
- NP Shield
- IV Shield
- Epoxy
Note: the IV Shield is intended for maintaining sterility of the luer-slip of the device; there is no IV needle component.
This document is a 510(k) premarket notification for a medical device, the BD Vacutainer® Multiple Sample Luer Adapter (K243649). It details the device's characteristics, intended use, and a comparison to a predicate device (K991088) to establish substantial equivalence.
Based on the provided text, the device in question is a physical medical device (a luer adapter) used for blood collection, not an AI/software-based medical device that would typically involve acceptance criteria related to algorithmic performance metrics like sensitivity, specificity, or image analysis. Therefore, much of the requested information (e.g., number of experts, adjudication methods, MRMC studies, standalone algorithm performance, training set details) is not applicable to this type of device submission.
Instead, the "acceptance criteria" for a physical device like this are met through a series of non-clinical performance tests, biocompatibility testing, and sterilization validation. The "study that proves the device meets the acceptance criteria" refers to the entire battery of these tests.
Here's a breakdown of the applicable information:
1. A table of acceptance criteria and the reported device performance
The document does not provide a specific table with numerical acceptance criteria and corresponding reported device performance values for each test. Instead, it states that the tests were conducted to "verify that the subject device met all design specifications and performance standards" and "demonstrates acceptable performance." The acceptance criteria are implicitly defined by the relevant standards and internal design specifications, and the "reported device performance" is summarized as having met these.
However, we can list the types of tests performed, which serve as the basis for the performance evaluation:
Acceptance Criterion (Type of Test) | Reported Device Performance (Summary from Document) |
---|---|
Non-clinical Performance Testing | "met all design specifications and performance standards" |
Torque to Break | "demonstrates acceptable performance" |
NP Cannula Pull Test | "continues to perform as expected" |
Spinout Test | |
IV Shield Pull Force Test | |
NP Sleeve Pull-off Force Test | |
Tube Push Off Test | |
Leakage by Pressure Decay Test | |
Sub-Atmospheric Pressure Air Leakage Test | |
Stress Cracking Test | |
Resistance to Axial Separation Test | |
Sterile Barrier Microbial Challenge Test | |
Biocompatibility Testing | "demonstrates acceptable performance" |
Cytotoxicity | |
Sensitization | |
Intracutaneous Reactivity or Irritation | |
Material-mediated Pyrogenicity | |
Acute Systemic Toxicity | |
Hemocompatibility | |
Leachables/Extractables | |
Sterilization Testing | "demonstrates conformity to the following sterilization standards" |
Sterility (EN 556-1) | Sterility Assurance Level (SAL) of 10^-6 achieved |
Radiation Sterilization (EN ISO 11137-1/2) | |
Microbiological Methods (EN ISO 11737-1/2) | |
Packaging Validation | "demonstrates conformity to the following standards" |
Packaging for Terminally Sterilized Medical Devices (ISO 11607-1/2) |
2. Sample sized used for the test set and the data provenance
The document does not explicitly state the sample sizes used for each of the non-clinical performance tests. These types of tests often follow specific ISO or ASTM standards that prescribe minimum sample sizes for statistical confidence, but the exact numbers are not detailed in this summary.
- Data Provenance: The tests were conducted internally by Becton Dickinson and Company. The provenance would be the manufacturer's own testing facilities. No information regarding country of origin of data or retrospective/prospective status is relevant, as this concerns bench testing of physical prototypes/production samples, not patient data.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This question is not applicable as the device is a physical, mechanical medical device. "Ground truth" in this context is established through engineering and scientific measurements and adherence to recognized performance standards (e.g., ISO, EN standards), not through expert consensus on interpretation of data like medical images.
4. Adjudication method for the test set
This question is not applicable for the same reasons as point 3. No adjudication of expert opinions or subjective interpretations is involved.
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
This question is not applicable. The device is a physical blood collection adapter, not an AI-assisted diagnostic tool.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This question is not applicable. The device is a physical blood collection adapter, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
For a physical device, the "ground truth" is based on:
- Engineering specifications and tolerances: The physical dimensions, material properties, and functional capabilities must meet predefined engineering standards.
- Regulatory standards: Adherence to international standards (e.g., ISO, EN) for medical devices, manufacturing quality, biocompatibility, and sterilization.
- Predicate device performance: The new device must perform comparably to the predicate device in relevant tests.
8. The sample size for the training set
This question is not applicable. There is no "training set" as this is a physical device, not an AI algorithm that undergoes machine learning training.
9. How the ground truth for the training set was established
This question is not applicable for the same reasons as point 8.
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(28 days)
Becton, Dickinson and Company
The BD Phoenix Automated Microbiology System is intended for the in vitro rapid identification (ID) and the quantitative determination of antimicrobial susceptibility by minimal inhibitory concentration (MIC) of most Gram-positive bacteria from pure culture belonging to the genera Staphylococcus, other gram positive cocci and gram positive bacilli and of most Gram-negative aerobic and facultative anaerobic bacteria isolates from pure culture for Enterobacteriaceae and Non-Enterobacteriaceae.
BD Phoenix is an automated system for the rapid identification (ID) and antimicrobial susceptibility testing (AST) of clinically relevant bacterial isolates. The BD Phoenix System utilizes a redox indicator to detect organism growth in the presence of an antimicrobial agent. Measurements of changes to the indicator as well as bacterial turbidity are used in the determination of bacterial growth. Each AST panel configuration contains several antimicrobial agents with a wide range of two-fold doubling dilution concentrations. The Phoenix instrument reads and records of the antimicrobial tests contained in the panel and interprets the reactions (based on the organism identification) to give a minimal inhibitory concentration (MIC) value and category interpretations (susceptible, intermediate, resistant, or not susceptible).
The BDXpert™ System is a rule-based software tool that provides expert advice based on organism ID and AST results obtained by broth micro-dilution on the BD Phoenix Instruments. BDXpert rule development is based on published information available through standards organizations, current scientific literature, and FDA's STIC; custom rules may be user defined if desired. The BDXpert System rule logic is applied to the susceptible, intermediate, and resistant (SIR) result, which is based on the breakpoint table and interpretation rule set included either in the BDXpert System on the standalone Phoenix instruments or through the BDXpert System on the connected BD EpiCenter™ data management system (EpiCenter) or BD Synapsys™ Informatics Solution (Synapsys). The resulting instrument report contains information such as: MIC interpretation, BDXpert rules, special messaging, resistance markers, etc. The expert results can then be sent to the Laboratory Information System (LIS).
Synapsys is a browser-based software platform operating in the clinical lab setting, offering secure connectivity and data storage, integrated workflows, and analytics tools. Synapsys consists of software servers operating the application and database, securely networked through a facility IT infrastructure to diagnostic instrumentation, external healthcare IT systems such as the LIS, and browser-enabled client devices for operating the system. Synapsys connects BD lab automation and diagnostic instruments to a common database and provides a single user interface to integrate laboratory workflows. Synapsys provides bi-directional communication with BD Phoenix and is able to process ID and AST results received from a BD Phoenix instrument. The system will automatically associate a known organism ID result, regardless of source, to any ID/AST or AST only Phoenix panel(s) that have the same accession/isolate number and lack an organism ID.
While the provided text describes an FDA 510(k) premarket notification for the BD Phoenix™ Automated Microbiology System, it does not contain the detailed information necessary to answer your specific questions regarding acceptance criteria and the study that proves the device meets them.
The document primarily focuses on:
- Regulatory clearance: The FDA's determination of substantial equivalence to a predicate device.
- Device description: How the BD Phoenix system works for identification (ID) and antimicrobial susceptibility testing (AST).
- Comparison to predicate: Highlighting similarities and differences, particularly in data management connectivity (Synapsys vs. EpiCenter).
- General compliance: Mentioning adherence to standards like ISO 13485, IEC 62304, and ISO 14971, and FDA guidance on software functions.
Missing Information:
The document explicitly states under "V. Performance Characteristics (if/when applicable)": "Performance testing was conducted to verify compliance with specified design requirements... Software verification and validation activities demonstrate that BD Phoenix Instrument connected to Synapsys will perform as intended when used in accordance with device labeling." However, it does not provide the results of these performance tests, nor does it detail the specific acceptance criteria or the methodology of the study that generated those results.
Therefore, I cannot populate the table or answer the specific questions about the study design, sample sizes, ground truth establishment, or expert involvement based solely on the provided text. This type of detailed performance data is typically found in the full 510(k) submission, which is more extensive than this summary letter.
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(16 days)
Becton, Dickinson and Company
The BD Vaginal Panel is an automated qualitative in vitro diagnostic test for the direct detection of DNA targets from bacteria associated with bacterial vaginosis (qualitative results reported based on detection and quantitation of targeted organism markers), Candida species associated with vulvovaginal candidiasis, and/or Trichomonas vaginalis. The test utilizes real-time polymerase chain reaction (PCR) for the amplification of specific DNA targets and utilizes fluorogenic target-specific hybridization probes to detect and differentiate DNA from:
- · Bacterial vaginosis (BV) markers (Individual markers are not reported)
- o Lactobacillus spp. (L. crispatus and L. jensenii)
- o Gardnerella vaginalis
- o Atopobium vaginae
- o Bacterial Vaginosis Associated Bacteria-2 (BVAB-2)
- o Megasphaera-1
- · Vulvovaginal candidiasis (VVC) markers (Markers are reported in the following groups)
o Candida spp. (C. albicans, C. tropicalis, C. parapsilosis, C. dubliniensis)
- o Candida glabrata
- o Candida krusei
- · Trichomonas vaginalis (TV)
The assay may be used to detect DNA associated with BV, VVC, and TV, or a subset of these conditions per clinician order, in vaginal swab specimens collected from patients who are symptomatic for vaginitis/vaginosis. The BD Vaginal Panel is intended to aid in the diagnosis of vaginal infections in women with a clinical presentation consistent with bacterial vaginosis, vulvovaginal candidiasis and trichomoniasis.
The BD Vaginal Panel is available for use with the BD MAX™ System or the BD COR™ System.
The BD MAX™ Vaginal Panel performed on the BD MAX™ System is an automated qualitative in vitro diagnostic test for the direct detection of DNA targets from bacterial vaginosis (qualitative results reported based on detection and of targeted organism markers), Candida species associated with vulvovaginal candidiasis, and/or Trichomonas vaginalis. The test utilizes real-time polymerase chain reaction (PCR) for the amplification of specific DNA targets and utilizes fluorogenic target-specific hybridization probes to detect and differentiate DNA from:
- · Bacterial vaginosis markers (Individual markers not reported)
- o Lactobacillus spp. (L. crispatus and L. jensenii)
- o Gardnerella vaginalis
- o Atopobium vaginae
- o Bacterial Vaginosis Associated Bacteria-2 (BVAB-2)
- o Megasphaera-1
- · Vulvovaginal candidiasis (VVC) markers (markers are reported in the following groups)
- o Candida spp. (C. albicans, C. tropicalis, C. parapsilosis, C.dubliniensis)
- o Candida glabrata
- o Candida krusei
- • Trichomonas vaginalis (TV)
The assay may be used to detect BV, VVC, and/or TV, or a subset of these conditions per clinician order, in vaginal swab specimens collected from patients who are symptomatic for vaginitis/vaginosis. The BD MAX™ Vaginal is intended to aid in the diagnosis of vaginal infections in women with a clinical presentation consistent with bacterial vaginosis, vulvovaginal candidiasis and trichomoniasis.
The BD Vaginal Panel is an automated, qualitative in vitro diagnostic test for bacterial vaginosis markers. Candida species associated with vulyovaginal candidiasis, and Trichomonas vaginalis. From a single specimen, a vaginal swab collected from a patient who is symptomatic for vaginitis or vaginosis, the test provides qualitative (positive) results for the presence of the following conditions and/or organisms:
- Bacterial vaginosis (based on detection of Lactobacillus spp. (L. crispatus and L. . jensenii), Gardnerella vaginalis, Atopobium vaginae, Bacterial Vaginosis Associated Bacteria-2, and Megasphaera-1)
- Candida spp. (C. albicans, c. tropicalis, C. parapsilosis, and C. dubliniensis) .
- Candida glabrata ●
- Candida krusei ●
- Trichomonas vaginalis ●
The BD Vaginal Panel is available for use with the BD MAX™ System or the BD COR™ System under the trade names BD MAX™ Vaginal Panel and BD Vaginal Panel, respectively. The assay previously provided results for all five targets for every specimen run, regardless of whether the ordering clinician desires evaluation of all reported conditions. After clearance of this 510(k) submission, BD will release updates to the BD MAX™ and BD COR ™ software to allow users the versatility to mask results, per specimen, based on the order received from the clinician. This change allows a laboratory to use the BD Vaginal Panel to test a specimen for an individual target group (BV, VVC, or TV) or any two of the three targeted conditions, in addition to the current configuration that reports all three conditions simultaneously.
The provided text describes a 510(k) premarket notification for the BD Vaginal Panel, an in vitro diagnostic test. While the document details the device's intended use, technological principles, and comparison to a predicate device, it does not contain specific acceptance criteria and detailed study results in the format usually provided for device performance evaluation against such criteria. Instead, it states that "The clinical utility of the Vaginal Panel is unchanged from the clinical utility described in DEN160001" and that enabling a subset of results to be masked "has no clinical impact," implying that performance data was previously established and still applies.
Therefore, I cannot extract a table of acceptance criteria and reported device performance from the provided text, nor can I provide specific details on sample sizes, ground truth establishment, or expert involvement for the test set.
However, I can describe the basis for the claim of continued performance and what typically would be found in a complete submission to address these points.
Based on the provided text, here's what can be inferred and what information is missing:
Inferred Information Regarding Acceptance Criteria and Study to Prove Device Meets Them:
The core of the argument for "acceptance" in this submission (K243725) is that the changes to the BD Vaginal Panel (specifically, the ability to mask results for certain conditions based on clinician order) do not impact the analytical or clinical performance that was already established for the predicate device (BD Vaginal Panel, referenced by DEN160001, K191957, K201017, K223653).
The text states:
- "The clinical utility of the Vaginal Panel is unchanged from the clinical utility described in DEN160001."
- "BD has determined that introducing the capability to order a subset of the conditions evaluated by the Vaginal Panel while masking the results for those conditions that are not ordered has no clinical impact."
- "Enabling the assay to report results for only a subset of the conditions does not change the specimen type, the test conditions, or the logic that is used to determine whether a specimen is positive or negative for the associated condition: conditions that are not ordered are simply not reported to the user."
- "Therefore, analytical and clinical performance of the assays is not impacted."
This implies that the previous submissions (DEN160001, K191957, K201017, K223653) would contain the detailed study data that established the acceptance criteria and demonstrated the device's performance against them. The current submission is a modification where the manufacturer asserts that the modification does not alter the already proven performance.
Unavailable Information from the Provided Text:
Since this submission argues "no impact" on performance rather than providing new performance data, the following specific details are not present in the provided document:
- A table of acceptance criteria and the reported device performance: This information would be in the predicate device's summary (e.g., DEN160001). The current submission leverages the established performance.
- Sample sizes used for the test set and the data provenance: Not provided for this submission's changes, as it relies on previous data.
- Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not provided for this submission's changes.
- Adjudication method for the test set: Not provided for this submission's changes.
- 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: This is a molecular diagnostic test, not an AI-assisted diagnostic imaging device. Therefore, an MRMC study is not relevant here.
- If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: The device is described as an "automated qualitative in vitro diagnostic test," meaning its performance is its standalone performance without continuous human interpretation of raw data. The "human-in-the-loop" aspect here is the clinician receiving the final positive/negative result. The change highlighted in this 510(k) is masking results, not altering the fundamental detection algorithm.
- The type of ground truth used: Not explicitly stated for this submission's changes, but for molecular diagnostics, ground truth typically involves a combination of clinical diagnosis, other laboratory methods (e.g., microscopy, culture, or other validated molecular assays), and sometimes expert clinical assessment.
- The sample size for the training set: Not applicable as this is not an AI/ML device that requires a separate "training set" in that context. The "training" in molecular diagnostics refers to assay development and optimization, which isn't sample-size driven in the same way.
- How the ground truth for the training set was established: See point 8.
Summary of what is present in the document relevant to the assertion of continued performance:
The basis of acceptance for this 510(k) submission (K243725) is that the modifications to the BD Vaginal Panel (specifically, the software update to allow result masking) do not compromise the established performance of the predicate device. The detailed performance data, acceptance criteria, study designs, and ground truth methodologies would be found in the original and subsequent predicate device submissions (DEN160001, K191957, K201017, K223653). The current submission serves to inform the FDA that a software change introducing result masking does not require new efficacy studies because it does not alter the underlying test's analytical or clinical capability to detect the specified targets.
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(88 days)
Becton Dickinson and Company
The BD Vacutainer® One Use Holder is a single-use, non-sterile device used by healthcare professionals to attach and hold a BD Vacutainer® brand venous access device such as a blood collection needle, a blood collection set, or a luer adapter during venipuncture connected to a BD Vacutainer® blood collection tube(s). This device may also be used with a BD Vacutainer® blood collection set with a luer adapter to obtain blood samples into a BD BACTEC™ blood culture bottle.
The BD Vacutainer® One Use Holder is a non-sterile, single-use plastic device used during the blood collection process. It consists of a one piece plastic barrel with a female threaded connector at one end into which the non-patient end of the hub of a BD Vacutainer® blood collection device is screwed. The other end is open for the insertion of a BD Vacutainer® evacuated blood collection tube or BD BACTECTM Blood Culture Bottle This end also has flanges, which are intended to assist tube insertion. BD Vacutainer® One Use Holder is used to attach and hold a BD Vacutainer® Brand venous access device such as a blood collection needle, blood collection set or Multiple Sample Luer Adapter during venipuncture and to connect the subject device to a BD Vacutainer® blood collection tube or BD BACTEC™ blood culture bottle.
The provided document is a 510(k) Summary for the BD Vacutainer® One Use Holder, a blood specimen collection device. It describes the device, its intended use, and compares it to a predicate device (Greiner Vacuette® Blood Culture Holder).
Here's an analysis of the provided text in relation to acceptance criteria and supporting studies:
This document does not contain information about acceptance criteria and studies that prove a device meets those criteria in the context of an AI/ML medical device. This is a 510(k) Premarket Notification for a non-AI/ML medical device, specifically a blood specimen collection holder.
Here's why the requested information cannot be extracted from the provided text:
- Type of Device: The BD Vacutainer® One Use Holder is a physical, non-sterile, single-use plastic device. It is not an AI/ML-powered software device.
- Study Focus: The "Non-clinical Performance Summary" states that tests were conducted to "verify that the proposed devices met all design specifications and performance standards." This typically refers to mechanical, material, and functional testing for a physical device, not the evaluation of an AI algorithm's performance on a dataset.
- "Clinical Data - Not Applicable": This explicitly indicates that no clinical studies (which would be the source of test sets, ground truth establishment, expert adjudication, etc., for AI/ML devices) were required or performed for this device.
- Absence of AI/ML Specific Terminology: There is no mention of algorithms, machine learning, deep learning, models, training sets, test sets, inference, sensitivity, specificity, AUC, or any other terminology associated with AI/ML device evaluation.
Therefore, I cannot provide the requested information. The document focuses on demonstrating substantial equivalence based on indications for use, design, materials, and non-clinical performance characteristics relevant to a conventional medical device.
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