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510(k) Data Aggregation

    K Number
    K180375
    Manufacturer
    Date Cleared
    2018-05-18

    (95 days)

    Product Code
    Regulation Number
    870.5900
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Brain Cool AB

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

    The IQoolTM Warm System is a temperature regulating system indicated for monitoring and controlling patient temperature.

    Device Description

    The IQool™ Warm System is a non-invasive, thermal regulating system that monitors and controls patient temperature within a range of 32°C to 38.5°C (89.6°F to 101.3°F). The IQooL™ Warm System consists of: ECU 100 – refrigeration and control unit – an integrated control system operated via a touch screen monitor. BC COOL– a cooling liquid consisting of diluted monopropylene glycol (MPG5). The dilution is made by BrainCool AB to optimally serve the IQool TM Warm System. Five liters of BC COOL are delivered with the system. Cooling Pads – the single use pads are the only skin contacting component and can be fitted to the head/neck, torso, and thigh. Liquid coolant is circulated from the tank through the pads to control patient temperature. The pads are designed and molded to give a good fit during treatment and are intended for single patient use. Stabilization insulation – the patented stabilization insulation is made of insulating and moisture-absorbing neoprene which supports the cooling pads and insulates against the ambient environment condensation. The elasticity of the stabilization insulation keeps the cooling pads in place during treatment and ensures maximum contact between the skin and the surface of the cooling pad. The stabilizing insulation is intended for single use only. Accessories: BC Stick – a USB flash drive used to save system configurations, specifically prepared to communicate with the program of the IQoolTM Warm System. The BC stick does not store or capture any user identifying information. It can also be used to save a log file for system troubleshooting or to update the software. Filling pitcher – for refilling the tank with BC COOL (coolant). Fill the tank with coolant before or directly after start to avoid damage to the system.

    AI/ML Overview

    This document is a 510(k) Premarket Notification from Brain Cool AB for their IQool™ Warm System (K180375), seeking to demonstrate substantial equivalence to a predicate device, the Arctic Sun® Temperature Management System (K101092). The information provided focuses on the device's characteristics and a comparison to the predicate, rather than a clinical study establishing acceptance criteria through human performance or expert consensus.

    Therefore, many of the requested elements for describing "acceptance criteria and the study that proves the device meets the acceptance criteria" in terms of AI/algorithm performance (e.g., sample size for test set, number of experts for ground truth, MRMC study, standalone performance, training set details) are not applicable to this type of device submission. This is a medical device regulation document, not a clinical study report for an AI-powered diagnostic tool.

    The "study" referenced in this document is primarily bench testing and a comparison of technical specifications to a predicate device to demonstrate substantial equivalence under regulatory guidelines. The acceptance criteria are therefore focused on the device's ability to perform its core function (temperature regulation) within specified ranges, as well as adherence to safety and design standards already established by the predicate device.

    Here's an breakdown based on the provided document, addressing the applicable points:


    Device Name: The IQool™ Warm System
    Regulatory Submission: 510(k) Premarket Notification (K180375)

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

    Since this is a 510(k) submission for a thermal regulating system, the acceptance criteria are based on demonstrating comparable performance to a legally marketed predicate device (Arctic Sun® Temperature Management System, K101092) and adhering to established engineering and safety standards. The "reported device performance" is framed in terms of its technical characteristics matching or being similar to the predicate.

    Characteristic / Acceptance Criteria (Implied by equivalence to predicate)Reported IQool™ Warm System Performance (K180375)
    Intended UseTemperature regulating system indicated for monitoring and controlling patient temperature. (Identical to predicate)
    Temperature RangeControl patient temperature within a range of 32°C to 38.5°C (89.6°F to 101.3°F). (Identical to predicate)
    Cooling Rate1.38 to 1.61 °C/hour. (Comparable to predicate's 1.2 to 2.0 °C/hour)
    Heating CapabilityYes (Identical to predicate)
    Heating Capacity2500 BTU/hr / 750 Watts (Identical to predicate)
    Cooling MediumDiluted monopropylene glycol. (Predicate uses water; considered a minor difference and acceptable through testing)
    Reservoir Capacity4.0 liters. (Predicate: 3.5 liters; Reference IQool™ System: 4.0 liters)
    Water Flow Rate1.5 – 6 liters per minute. (Predicate: 5 liters per minute)
    Patient Temperature Measurement Accuracy±0.4°C (10°C to 32°C), ±0.2°C (32°C to 38°C), ±0.4°C (38°C to 44°C), includes ±0.1°C external probe. (Identical to predicate)
    Temperature Control & MonitoringAutomates temperature control based on set point, uses third-party temperature probes, provides monitoring and safety alarms. Simulated testing demonstrated cooling patients to hypothermia, maintaining patient temperature, and rewarming patients to normothermia comparably to the Predicate device and according to general therapeutic hypothermia practice. (Demonstrated through bench testing and comparison to predicate/literature)
    Safety AlarmsMonitoring and safety alarms present. Includes an additional alarm if the patient begins warming too quickly. (Comparable to predicate, with an additional safety feature)
    Patient Contacting Materials/PadsSingle-use pads for head/neck, torso, thigh. Identical in design and material to previously cleared IQool system (K162523), ensuring biocompatibility.
    SterilizationNot Sterilized. (Consistent with predicate and reference device)
    Software ValidationNew software testing and package provided appropriate to the identified level of concern. (Validated according to FDA's Guidance for Software Contained in Medical Devices)

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

    • This submission relies primarily on bench testing (simulated testing) rather than a clinical human subject test set for proving device performance. The specific "sample size" is not quantitated as it would be for a clinical trial with human subjects.
    • Data Provenance: The testing is laboratory-based ("simulated testing"). No information on geographical origin (country) or retrospective/prospective nature of a human data set is provided, as it's not a clinical study involving patients.

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

    • Not applicable. The "ground truth" for this device's performance is its ability to accurately control temperature, which is verified through engineering principles, bench testing, and comparison to the known performance of the predicate device and established medical literature on therapeutic hypothermia. This does not involve expert readers establishing ground truth on medical images or diagnoses.

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

    • Not applicable. This pertains to expert review and potential disagreement resolution in studies involving subjective assessment (e.g., image interpretation). The evaluation here is based on objective physical measurements and comparisons.

    5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:

    • Not applicable. This device is a thermal regulating system, not an AI-assisted diagnostic tool for human readers. No MRMC study was performed.

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

    • Not applicable in the context of an AI algorithm. However, the device's automated temperature control function can be thought of as "standalone" in that it performs its function without continuous human intervention to manually control temperature once set. Its performance was assessed through engineering and bench testing.

    7. The type of ground truth used:

    • The "ground truth" for this device's effectiveness is its ability to accurately and reliably regulate temperature within specified ranges, as determined by physical measurements, engineering specifications, and comparison to the established performance characteristics of the legally marketed predicate device (Arctic Sun® Temperature Management System) and general therapeutic hypothermia practice.

    8. The sample size for the training set:

    • Not applicable. This is not an AI/machine learning device that requires a training set.

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

    • Not applicable. This is not an AI/machine learning device.

    Summary of the Study Proving Acceptance Criteria (Substantial Equivalence):

    The IQool™ Warm System's acceptance criteria are met by demonstrating substantial equivalence to the predicate device (Arctic Sun® Temperature Management System, K101092). The "study" proving this involved:

    • Comparative analysis: Detailed comparison of the IQool™ Warm System's indications for use, technological characteristics, and performance specifications against the predicate device.
    • Bench Testing / Simulated Testing: The sponsor submitted "simulated testing" for the new rewarming features. This testing demonstrated the device's ability to cool patients to hypothermia, maintain patient temperature, and rewarm patients to normothermia comparably to the predicate device, based on published cooling times for the predicate and general therapeutic hypothermia practice.
    • Cross-referencing to a previously cleared device (K162523): Information regarding cooling pads, accessories, shelf-life, sterilization, and biocompatibility was referenced from a prior 510(k) submission for a related IQool system, as these components were identical.
    • Software Validation: New software testing was conducted and submitted, adhering to FDA guidance for software in medical devices, to ensure appropriate level of concern was addressed for the added rewarming capability.

    The conclusion is that the differences between the IQool™ Warm System and the predicate are minor and do not raise new questions of safety and effectiveness, thus meeting the requirements for 510(k) clearance by demonstrating substantial equivalence.

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    K Number
    K162523
    Device Name
    The IQool System
    Manufacturer
    Date Cleared
    2017-05-03

    (236 days)

    Product Code
    Regulation Number
    870.5900
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    BRAIN COOL AB

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

    Temperature reduction for adult patients where clinically indicated, e.g. in hyperthermic patients.

    Device Description

    The IQool™ System is a surface cooling device that sustains and monitors patient temperature within a range of 33°C to 37°C. The IQool™ System consists of: ECU 100 – refrigeration and control unit – The ECU 100 is a refrigerator unit with an integrated control system operated via a touch screen monitor. BC COOL- BC COOL is a cooling liquid consisting of diluted monopropylene glycol (MPG5). The dilution is made by BrainCool AB to optimally serve the IQool™ System. Five liters of BC COOL are delivered with the system. Cooling Pads – the single use cooling pads are the only skin contacting component and can be fitted to the head/neck, torso, and thigh. Liquid coolant is circulated from the tank through the pads to cool patients. The cooling pads are designed and molded to give a good fit during treatment and are intended for single patient use. Stabilization insulation – The patented stabilization insulation is made of insulating and moisture-absorbent neoprene. The stabilization insulation supports the cooling pads and insulates against the ambient environment condensation. The elasticity of the stabilization insulation keeps the Cooling Pads in place during treatment and ensures maximum cooling between the skin and the surface of the Cooling Pad. The stabilizing insulation is intended for single use only. Accessories: BC STICK — The BC STICK is a USB flash drive used to save system configurations, specifically prepared to communicate with the program of the IQool™ System. The BC stick does not store or capture any user identifying information. It can also be used to save a log file for system troubleshooting or to update the software. Filling pitcher – The filling pitcher is for refilling the tank with BC COOL (coolant). Fill the tank with coolant before or directly after start to avoid damage to the system. The ECU 100 pushes temperature-controlled BC COOL ranging between 4°C and 30°C through the Cooling Pads at approximately 1.2 liter per minute per pad. This results in heat exchange between the BC COOL and the patient. Patient temperature is monitored by one or two commercially available third-party temperature probes. The IQool™ System maintains a controlled patient temperature during the entire treatment period. Any deviations from the default temperature are automatically adjusted by the system. The default treatment settings for temperature and time can be changed through the touchscreen monitor. Alarms and notifications are activated if any errors are detected. Temperature graphs for each treatment are shown on the touchscreen display for visual monitoring.

    AI/ML Overview

    The provided text describes a medical device, "The IQool System," and its claim of substantial equivalence to a predicate device. However, it does not contain information about acceptance criteria or a study that proves the device meets specific performance criteria in the format typically used for AI/ML device evaluations (e.g., sensitivity, specificity, AUC).

    Instead, the document focuses on regulatory submission (510(k)) for a thermal regulating system and its comparison to a predicate device. The performance data section broadly states that "Testing was completed for the IQool™ System which demonstrated intended, labeled device performance," and lists various functional, temperature, software, and safety tests, as well as adherence to standards.

    Therefore, I cannot populate the table or answer most of your specific questions based on the provided text, as this document type typically doesn't contain that level of detail for performance metrics, study design, or ground truth establishment relevant to AI/ML device evaluations.

    Here's what can be inferred or stated about the device based on the provided text, recognizing its limitations regarding your specific questions:


    Device: The IQool System (Thermal Regulating System)

    Intended Use: Temperature reduction for adult patients where clinically indicated, e.g., in hyperthermic patients.


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

    Acceptance CriteriaReported Device Performance
    Cooling mechanism: Automated, controlled temperature"The IQool™ System maintains a controlled patient temperature during the entire treatment period. Any deviations from the default temperature are automatically adjusted by the system."
    Patient Temperature Range: 33°C to 37°C (91.4°F to 98.6°F)"The IQool System is a surface cooling device that sustains and monitors patient temperature within a range of 33°C to 37°C."
    Patient Temperature Measurement Accuracy: ± 0.4°C (10°C to 32°C), ± 0.2°C (32°C to 38°C), ± 0.4°C (38°C to 44°C) (Includes ± 0.1C external probe)The IQool System reports this as its capability, directly matching the predicate device.
    Cooling Rates: (Not explicitly stated as an "acceptance criterion" but reported)1.38 to 1.61 °C/hour
    Electrical Safety: Conformance to IEC/EN 60601-1"All testing confirmed that the IQool™ System operates as described and is substantially equivalent to the predicate device."
    Electromagnetic Compatibility: Conformance to IEC/EN 60601-1-2"All testing confirmed that the IQool™ System operates as described and is substantially equivalent to the predicate device."
    Usability: Conformance to IEC/EN 60601-1-6"All testing confirmed that the IQool™ System operates as described and is substantially equivalent to the predicate device."
    Alarm Systems: Conformance to IEC/EN 60601-1-8"All testing confirmed that the IQool™ System operates as described and is substantially equivalent to the predicate device."
    Software Life-Cycle Processes: Conformance to IEC/EN 62304"All testing confirmed that the IQool™ System operates as described and is substantially equivalent to the predicate device."
    Biocompatibility: Testing for patient contacting parts"biocompatibility testing for patient contacting parts" was performed, and "All testing confirmed that the IQool™ System operates as described..."
    Functional Testing: (General)"Performance testing included functional testing... All testing confirmed that the IQool™ System operates as described..."
    Temperature Control Testing: (General)"Performance testing included... temperature testing, temperature control… All testing confirmed that the IQool™ System operates as described..."

    Note: The document broadly states "All testing confirmed that the IQool™ System operates as described and is substantially equivalent to the predicate device" in lieu of specific numerical performance outcomes for many criteria.

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

    This information is not provided in the document. The document describes general performance testing and standards compliance, not a clinical trial or specific test set with patient data.

    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 information is not provided in the document. The device is a thermal regulating system, not an AI diagnostic tool requiring expert ground truth for interpretation of outputs like images.

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

    This information is not provided in the document. Not applicable for this type of device and 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

    This information is not provided in the document. This is not an AI/ML diagnostic device with human reader interaction.

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

    The device is a physical thermal regulating system. Its "performance" is based on its ability to control temperature as per its design. The document states it was functionally tested and meets standards, implying a standalone performance assessment of the device's physical and software functions. The "algorithm" in this context refers to its internal control system for temperature regulation, not an AI for interpretation.

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

    For a thermal regulating system, "ground truth" would typically refer to:

    • Reference temperature measurements: Calibrated temperature probes would act as the ground truth for measuring the patient's core temperature.
    • System set points: The desired temperature set by the clinician would be the target "ground truth" for the device to achieve and maintain.
    • Engineering specifications: Conformance to design specifications for cooling rates, fluid parameters, and safety elements.

    The document states "Patient temperature is monitored by one or two commercially available third-party temperature probes." These probes would serve as the reference for patient temperature.

    8. The sample size for the training set

    This information is not provided in the document. This concept (training set) is typically relevant to AI/ML models, not purely electro-mechanical medical devices with control system software.

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

    This information is not provided in the document. Not applicable given the type of device.

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