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510(k) Data Aggregation

    K Number
    K200266
    Date Cleared
    2020-04-07

    (64 days)

    Product Code
    Regulation Number
    880.5200
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Bard Access Systems, Inc. (Bard has joined BD)

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Acute central venous catheters are indicated to provide short-term access (

    Device Description

    A family of power injectable central venous catheters constructed of medical grade polyurethane and is designed for insertion into the central venous system. BD power injectable acute central lines are radiopaque and have a soft tip that is more pliable than the catheter body. Each catheter is provided in a sterile package with applicable insertion kit accessories. The maximum pressure injector settings and maximum power injection flow rate are specified in the table below:

    Catheter LengthLumen(s)Power Injection Flow RateMaximum Power Injector Pressure Setting
    16 cm and 20 cmDistal10 mL/sec325 psi
    Proximal10 mL/sec
    AI/ML Overview

    This document is an FDA 510(k) Premarket Notification for a medical device: the BD CentroVena™ Acute Central Line (7 French Dual Lumen). It aims to demonstrate substantial equivalence to legally marketed predicate devices, not to prove clinical efficacy of a novel AI/software device. Therefore, the questions related to AI/software performance (e.g., sample size for test/training sets, number of experts for ground truth, MRMC studies, standalone performance, effect size of human improvement with AI) are not applicable to this type of submission.

    Instead, this submission focuses on demonstrating the physical and functional equivalence of a new iteration of an intravascular catheter to existing ones. The "acceptance criteria" here refer to standard performance and safety tests for such medical devices, rather than statistical thresholds for AI model performance.

    Here's an analysis of the provided text in the context of the requested information, highlighting what is (and isn't) present:

    Context of the Document: This submission seeks 510(k) clearance for a new version of an acute central line catheter. It compares the "subject device" (BD CentroVena™ Acute Central Line) to a "predicate device" (BD Acute Central Line) to argue that it is substantially equivalent, meaning it performs as safely and effectively as existing devices. This is achieved through detailed comparisons of specifications, materials, and comprehensive performance testing.

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

    The document mentions that "All testing passed the predetermined acceptance criteria." However, it does not provide a specific table detailing the numerical acceptance criteria alongside the quantitative results for each test. Instead, it lists the types of performance tests conducted and implicitly states that the outcomes met the necessary standards for substantial equivalence.

    Here's a summary of the mentioned tests and their purpose, which serves as a proxy for the acceptance criteria and implied "reported performance" (since they all passed):

    Acceptance Criteria (Measured by Test Purpose)Reported Device Performance (Implied by "All testing passed")
    Biocompatibility: Catheter is free from biological hazard.Confirmed (leveraged from predicate and reference device)
    Particulate Matter: Compliance with USP .Tested and confirmed (leveraged from predicate device)
    Clamp Engagement: Catheter assembly will not leak when clamp is engaged.Passed
    Leak Test: Catheter assembly will not leak when distal end is occluded.Passed
    Dimensional Test: OD, ID, and lumen area compliance with specifications.Passed
    Implantable Length: Useful length compliance with specifications.Passed
    Extension Leg Length: Compliance with dimensional specifications.Passed
    Burst Test (Catheter & Hydraulic): Catheter burst pressure exceeds peak pressure at max flow.Passed
    Power Injection Conditioning: Catheter does not leak or burst as a result of power injections at max flow rate.Passed
    Gravity Flow: Performance of a full-length catheter.Passed
    Tensile Tests (Luer to Leg, Leg to Trifurcation, Trifurcation to Shaft, Shaft, Tip): Peak tensile force exceeds minimum.Passed
    Radiopacity: Catheter radio-detectability.Passed
    Catheter Collapse Test: Flow rate of aspiration and no collapse under vacuum.Passed
    Suture Wing Integrity Test: Max force catheter junction suture wing can withstand prior to break.Passed
    OD Swell: Does not swell beyond twice the labeled OD during power injection.Passed
    Tip Stability Test: Tip remains in same orientation during power injection at max flow rate.Passed
    Guidewire Drag Test: Guidewire can be removed without difficulty.Passed
    Luer Testing (Stress Cracking, Separation from Axial Load/Unscrew Torque, Overriding, Dimensions, Leak): Compliance with ISO 80369-7.All Luer tests passed

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

    • Sample Size: The document does not specify numerical sample sizes for the performance tests conducted. It generally refers to "All testing," "each test piece," implying that appropriate sample sizes were used per industry standards, but the exact numbers are not disclosed.
    • Data Provenance: The tests were conducted internally by the manufacturer (Bard Access Systems, Inc. / BD) to demonstrate compliance with standards and equivalence. These are laboratory/bench tests performed on the physical device, not clinical data from patients. The data is prospective in the sense that the tests were specifically performed for this submission. The "country of origin of the data" would be where the tests were performed, presumably within the manufacturer's facilities, likely in the US (Salt Lake City, Utah is the submitter address).

    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. This is a physical device submission, not an AI/software submission. "Ground truth" in the AI sense (e.g., expert labels on medical images) does not apply here. The "ground truth" for the device's performance is established by the specified engineering and material standards (e.g., ISO, ASTM, USP) and the results of laboratory tests.

    4. Adjudication method for the test set:

    This question is not applicable. There is no "adjudication" in the sense of reconciling disagreements between multiple human readers or comparing AI outputs to human interpretations. Device performance is determined through objective, quantifiable physical tests.

    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, as this is a physical medical device and does not involve AI assistance for human readers.

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

    This question is not applicable, as this is a physical medical device and does not involve an algorithm.

    7. The type of ground truth used:

    The "ground truth" here is defined by:

    • Engineering Standards and Specifications: e.g., ISO 10993-1, USP , ISO 10555-1, ASTM F640-12, ISO 10555-3, ISO 80369-7, and FDA guidance documents.
    • Device Design Parameters: The specified dimensional requirements, material properties, and functional performance (e.g., flow rates, pressure resistance).
    • Objective Test Measurements: Quantifiable laboratory measurements from performance tests.

    8. The sample size for the training set:

    This question is not applicable. There is no "training set" in the context of a physical medical device submission.

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

    This question is not applicable. There is no "training set" or "ground truth" established for it in this context. The "ground truth" for proving substantial equivalence relies on adherence to established engineering standards and validated test methodologies.

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    K Number
    K190855
    Date Cleared
    2019-11-01

    (213 days)

    Product Code
    Regulation Number
    880.5200
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Bard Access Systems, Inc. (Bard has joined BD)

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Acute central venous catheters are indicated to provide short-term access (

    Device Description

    A family of power injectable central venous catheters constructed of medical grade polyurethane and is designed for insertion into the central venous system. BD power injectable acute central lines are radiopaque, and have a soft tip that is more pliable than the catheter body. Each catheter is provided in a sterile package with applicable insertion kit accessories.

    AI/ML Overview

    The provided text describes the BD Acute Central Line, a medical device, and its substantial equivalence to a predicate device, the Arrow Central Venous Catheter (K071538). The document outlines various performance tests conducted to establish this equivalence, along with the criteria used.

    Here's a breakdown of the requested information:

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

    The document does not explicitly provide a table listing "acceptance criteria" alongside "reported device performance" with specific numerical results for each test. Instead, it states that "All testing passed the predetermined acceptance criteria." The acceptance criteria are implicitly defined by the standards and the purpose of each test.

    Here’s a summary of the tests performed and their implied acceptance criteria:

    Test NameImplied Acceptance CriteriaReported Device Performance
    Biocompatibility Testing (ISO 10993-1:2009)Catheter free from biological hazard; materials acceptable for intended purpose (based on Cytotoxicity, Sensitization, Irritation, Acute Systemic Toxicity, Pyrogenicity, Subchronic Systemic Toxicity, Genotoxicity, Hemocompatibility, Implantation)Passed
    Clamp EngagementCatheter assembly will not leak when clamp is engaged.Passed
    Leak TestCatheter assembly will not leak when the distal end of the catheter is occluded.Passed
    Dimensional TestOD and ID/lumen area comply with dimensional specifications.Passed
    Implantable LengthUseful length complies with dimensional specifications.Passed
    Extension Leg LengthExtension leg length complies with dimensional specifications.Passed
    Burst TestCatheter burst pressure exceeds peak pressure in catheter at maximum flow conditions when distal end is occluded.Passed
    Hydraulic Catheter Burst TestCatheter burst pressure exceeds peak pressure in catheter at maximum flow conditions when distal end is occluded.Passed
    Power Injection ConditioningCatheter does not leak or burst as a result of power injections at maximum indicated flow rate.Passed
    Gravity FlowMeets specified gravity flow performance for a full-length catheter.Passed
    Luer to Extension Leg Tensile TestPeak tensile force exceeds minimum peak tensile force.Passed
    Extension Leg to Trifurcation Tensile TestPeak tensile force exceeds minimum peak tensile force.Passed
    Trifurcation to Shaft Tensile TestPeak tensile force exceeds minimum peak tensile force.Passed
    Shaft Tensile TestMaximum catheter strain and modulus at break meet specified criteria.Passed
    Radiopacity (ASTM F640-12)Catheter is radio-detectable.Passed
    Tip Tensile (ISO 10555-3:2013)Peak tensile force exceeds minimum peak tensile force.Passed
    Catheter Collapse TestDemonstrates aspiration flow rate and that catheter will not collapse under vacuum.Passed
    Suture Wing Integrity TestMaximum force catheter junction suture wing can withstand prior to break meets specified criteria.Passed
    Priming VolumeVolume required to prime full-length catheter meets specified criteria.Passed
    OD SwellCatheter does not swell beyond twice the size of the labeled OD during power injection.Passed
    Tip Stability TestCatheter tip remains in same orientation during power injection (tip pointing in direction of venous flow) at maximum indicated flow rate.Passed
    Guidewire Drag TestGuidewire can be removed without difficulty.Passed
    Luer Testing (ISO 594: Part 1 & 2)Luer connectors meet requirements for Leak, Leak Decay, Stress Cracking, Resistance to Separation from Axial Load, Resistance to Separation from Unscrewing, Resistance to Overriding, Gauging.Passed
    Particulate Testing (USP )Particulate matter on catheter post-manufacture does not exceed prescribed particle sizes.Passed
    MR SafetyDevice is safe for use in an MR environment.Passed

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

    The document does not explicitly state the specific sample sizes used for each of the performance tests. It mentions that testing was conducted "by or for BAS per guidance documents and standards in conjunction with in-house protocols." The data provenance (country of origin, retrospective/prospective) is also not specified.

    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)

    This section is not applicable. The device is a physical medical device (central venous catheter), not an AI or diagnostic imaging device that typically requires expert-established ground truth for performance evaluation in the context of diagnostic accuracy. The "ground truth" for this device's performance is established through physical and material property testing against engineering specifications and industry standards.

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

    This is not applicable for a physical medical device. Performance is determined by objective measurements against established standards, not by agreement among adjudicators.

    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 is not applicable. The BD Acute Central Line is a physical medical device and not an AI or diagnostic imaging device for which MRMC comparative effectiveness studies with human readers would be performed.

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

    This is not applicable. The device is a physical medical device and does not involve algorithms or AI.

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

    The "ground truth" for the BD Acute Central Line's performance is based on established industry consensus standards and in-house protocols for performance testing of medical devices, specifically intravascular catheters. This includes physical, chemical, and biological testing as outlined in standards like ISO 10993-1, ISO 10555, ASTM F640-12, USP , and FDA guidance documents. The acceptance criteria for these tests serve as the "ground truth" against which the device's performance is measured.

    8. The sample size for the training set

    This is not applicable. The device is a physical medical device, not an AI model that requires a training set.

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

    This is not applicable as there is no training set for a physical medical device.

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