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510(k) Data Aggregation
(266 days)
Bridge to Life Ltd
The OrganProtex™ HTK Solution is indicated for perfusion and flushing of donor kidneys, liver, pancreas and heart prior to removal from the donor or immediately after removal from the donor. The solution is left in the organ vasculature during hypothermic storage and transportation to the patient. OrganProtex™ HTK Solution is not indicated for continuous machine perfusion of donor organs.
OrganProtex™ HTK Solution is a clear, colorless to pale yellow colored solution, sterile, nonpyrogenic electrolyte and amino acid aqueous solution for organ perfusion and preservation. OrganProtex™ HTK Solution is indicated for perfusion and flushing of donor kidneys, liver, pancreas and heart prior to removal from the donor or immediately after removal from the donor. The solution is left in the organ vasculature during hypothermic storage and transportation to the patient. OrganProtex™ HTK Solution is not indicated for continuous machine perfusion of donor organs.
Histidine-tryptophan-ketoglutarate or HTK solution is a high-flow, low-potassium preservation solution used for organ transplantation. The solution was initially developed by Hans-Jurgen Bretschneider.
HTK solution is based on the principle of inactivating organ function by withdrawal of extracellular sodium and calcium, together with intensive buffering of the extracellular space by means of histidine hydrochloride, so as to prolong the period during which the organs will tolerate interruption of oxygenated blood. The composition of HTK is similar to that of extracellular fluid. All of the components of HTK, with the exception of mannitol, occur naturally in the body. The solution should be used only by medical healthcare staff, adequately trained according to established operating protocols.
The document describes the OrganProtex™ HTK Solution
, which is an organ preservation solution. This device is applying for 510(k) clearance based on substantial equivalence to a predicate device, Custodiol® HTK Solution
(K192408).
Here's an analysis based on your request:
1. Table of Acceptance Criteria and Reported Device Performance
Since this is a 510(k) submission for a medical solution, the "acceptance criteria" and "reported device performance" are primarily focused on demonstrating equivalence in composition, function, and safety to a legally marketed predicate device, rather than a quantifiable performance metric against a specific clinical outcome.
The main acceptance criterion for a 510(k) is demonstrating substantial equivalence to an existing predicate device. This is achieved by showing that the new device has the same intended use, and either the same technological characteristics or, if different, that these differences do not raise new questions of safety and effectiveness.
The document provides a detailed comparison table (Table 6.0 in the original document, reproduced below as "Comparison of Technological Characteristics") that serves as the reported device performance against the predicate.
Comparison of Technological Characteristics
Characteristic | Subject Device (OrganProtex™ HTK Solution) | Predicate Device (Custodiol® HTK Solution) | Comparison / Reported Performance |
---|---|---|---|
Device Manufacturer | Rusoma Laboratories Pvt. Ltd. (India) | Dr. Franz Kohler Chemie GmBH (Germany) | - |
510(k) Number | K241239 | K192408 | - |
Classification & Product Code | 876.5880; KDL, MSB | 876.5880; KDL, MSB | Same |
Device Regulation Description | Isolated kidney perfusion and transport system and accessories | Isolated kidney perfusion and transport system and accessories | Same |
Common Name | HTK Solution | HTK Solution | Same |
Device Description | Clear, colorless to pale yellow colored solution, sterile, non-pyrogenic electrolyte and amino acid aqueous solution for organ perfusion and preservation. Available in 1000ml bag. Sterile and intended for one single and continuous administration. | Clear, colorless to pale yellow colored solution, sterile, non-pyrogenic electrolyte and amino acid aqueous solution for organ perfusion and preservation. Available in 1000mL, 2000mL and 5000ml bags. Sterile and intended for one single and continuous administration. | Same. Used as organ preservation solutions in the procurement and transplant process. |
Indications for Use | Indicated for perfusion and flushing of donor kidneys, liver, pancreas and heart prior to removal or immediately after removal. Solution left in organ vasculature during hypothermic storage and transportation. Not for continuous machine perfusion. | Indicated for perfusion and flushing of donor kidneys, liver, pancreas and heart prior to removal or immediately after removal. Solution left in organ vasculature during hypothermic storage and transportation. Not for continuous machine perfusion. | Same. Used at cold temperatures to slow biological deterioration. |
Intended Use | Perfusion and flushing of donor kidney, liver, pancreas and heart prior to removal or immediately after removal. Solution left in organ vasculature during hypothermic storage and transportation. | Perfusion and flushing of donor liver, kidney, heart, and pancreas prior to removal and for preserving these organs during hypothermic storage and transport. | Same. Used at cold temperatures to slow biological deterioration. |
Storage Temperature | 2° to 8° C | 2° to 8° C | Same |
Pre-Cooling | Pre-cool solution prior to use (2° to 4° C) | Pre-cool solution prior to use (2° to 4° C) | Same |
In-Situ Organ Cooling | Surface cooling of organs (heart, kidney, liver, pancreas). | Surface cooling of organs (heart, kidney, liver, pancreas). | Same |
Maintain Cold Organ Temperature During Storage and Transport | Directly cools the organ vasculature during hypothermic storage and transportation (not for continuous perfusion). | Directly cools the organ vasculature during hypothermic storage and transportation (not for continuous perfusion). | Same |
Product State | Liquid - Solution | Liquid - Solution | Same |
Composition | Identical quantitative composition of Sodium chloride, Potassium chloride, Potassium hydrogen 2-Oxopentandioate, Magnesium chloride·6H2O, Histidine HCl·H2O, Histidine, Tryptophan, Mannitol, Calcium chloride·2H2O, Water for Injection. | Identical quantitative composition of Sodium chloride, Potassium chloride, Potassium hydrogen 2-Oxopentandioate, Magnesium chloride·6H2O, Histidine HCl·H2O, Histidine, Tryptophan, Mannitol, Calcium chloride·2H2O, Water for Injection. | Same |
Osmolality | 310 mOsmol/kg | 310 mOsmol/kg | Same |
pH | 6.5-7.5 | 7.02-7.20 at 25°C, 7.4-7.45 at 4°C | Equivalent. Both within set specifications. The difference in pH range (6.5-7.5 vs. 7.02-7.20) does not impact safety and efficacy as histidine buffers tissue pH. |
Fluid Volume | 1,000 ml | 1,000 ml, 2,000 ml, 5,000 ml | Equivalent. Subject device in a subset of available volumes of the predicate. |
Single Use Only | Yes | Yes | Same |
Primary Container | Polypropylene PVC-Free Bag | Polypropylene PVC-Free Bag | Equivalent |
Protecting Overwrap Bag | Yes | Yes | Same |
Shelf Life | 12 Months | 12 Months | Same |
Pyrogenicity | Non-Pyrogenic | Non-Pyrogenic | Same |
Sterility | Sterile solution | Sterile solution | Same |
Sterilization | Terminal steam sterilization | Terminal steam sterilization | Same |
Biocompatibility | Biocompatible in accordance with ISO 10993-1/2/5/10/12. | Biocompatible in accordance with ISO 10993-1/2/5/10/12. | Equivalent. |
Sterile Dispensing | Fluid is dispensed via sterile port on bag. | Fluid is dispensed via sterile port on bag. | Same |
Bag Connections | Fluid delivery and drug administration ports | Fluid delivery and drug administration ports | Same |
2. Sample Size Used for the Test Set and Data Provenance
This is a submission for a medical solution, not typically a device that undergoes "test set" evaluation in the same way an AI/software device would. The "test set" here refers to the data and testing used to demonstrate the solution's properties (sterility, pH, osmolality, shelf life, biocompatibility).
- Sample Size for Test Set: The document doesn't specify a numerical "sample size" in terms of how many units of
OrganProtex™ HTK Solution
were tested for each non-clinical performance category (biocompatibility, sterilization, shelf-life). These are standard laboratory tests typically performed on a statistically relevant batch size for manufacturing quality control and regulatory submission. - Data Provenance: The manufacturing entity is Rusoma Laboratories Pvt. Ltd. in India. The studies performed (biocompatibility, sterilization, shelf-life) were conducted to demonstrate the properties necessary for substantial equivalence. The document doesn't specify if the underlying data/tests were conducted retrospectively or prospectively, but typically, these are prospectively planned tests to support the submission.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts
This type of information (number of experts, qualifications, and ground truth establishment) is typically relevant for studies involving human interpretation, such as image analysis for diagnosis. For a medical solution like OrganProtex™ HTK Solution
, there isn't a "ground truth" established by human experts in the same way. The ground truth for its properties (like sterility, pH, composition) is established through analytical chemistry, microbiology, and physical property testing performed by qualified laboratory personnel following validated methods.
4. Adjudication Method for the Test Set
Not applicable for this type of device. Adjudication methods (e.g., 2+1, 3+1) are common in clinical trials or human performance studies where multiple experts evaluate cases and discrepancies are reconciled. The non-clinical performance data for OrganProtex™ HTK Solution
relies on objective laboratory measurements.
5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
Not applicable. This is a medical solution (a liquid for organ preservation), not an AI-powered diagnostic or assistive device. Therefore, MRMC studies and the concept of "human readers" or "AI assistance" are not relevant here.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This is a medical solution and does not involve any algorithms or software for standalone performance.
7. The Type of Ground Truth Used
The ground truth for the non-clinical performance data is based on:
- Analytical Chemistry: For composition, pH, osmolality.
- Microbiology Testing: For sterility and pyrogenicity.
- Biocompatibility Testing: In accordance with ISO 10993 standards.
- Stability Studies: To determine shelf life.
8. The Sample Size for the Training Set
Not applicable. This product is a medical solution, not a machine learning model, so there is no "training set."
9. How the Ground Truth for the Training Set was Established
Not applicable, as there is no training set for this device.
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(238 days)
Bridge to Life Ltd.
Cannula for Organ Perfusion is a single-use device indicated for hypothermic flushing and replacement of residual blood in donor organs with a legally marketed organ preservation solution at the time of organ removal from the donor during the preparation of these organs for transplantation. This device is indicated for use with gravity flow; no testing has been provided for use with pump systems, such as mechanical perfusion devices.
The Cannula for Organ Perfusion is a device designed and intended as a component to an organ perfusion and transport system / organ preservation solution, used in an organ transplantation procedure. The device is a cannula (available in several different sizes) intended for flushing and replacement of residual blood in donor organs with organ preservation solution during the preparation processes of these organs for transplantation. The cannulas are single use, sterile, non-toxic and nonpyrogenic devices. As a component to an organ perfusion and transport system / organ preservation solution, the Cannula for Organ Perfusion is also a Class II medical device, subject to Product Code KDN and MSB, 21 CFR 876.5880: "This generic type of device may include tubing, catheters, connectors, an ice storage or freezing container with or without bag or preservatives, pulsatile or nonpulsatile hypothermic isolated organ perfusion apparatus with or without oxygenator, and disposable perfusion set." (21 CFR 876.5880(a)).
The Cannulas come in multiple sizes, according to the French catheter scale, including 8F, 10F, 12F, 16F (adjustable to 18F with a slidable ring), 20F (adjustable to 28F with a slidable ring), 25F (adjustable to 34F with a slidable ring). In addition, there is a configuration of the cannula that is intended for "back table" procedures, which is available in a 16F size.
This FDA 510(k) submission describes the "Cannula for Organ Perfusion" device. The document primarily focuses on establishing substantial equivalence to predicate devices rather than providing a detailed study of the device's performance against specific acceptance criteria.
Here's an analysis based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The submission does not provide a table of acceptance criteria with corresponding performance metrics for the device in the manner typically seen for algorithmic or diagnostic devices. Instead, it relies on bench testing results and biocompatibility testing to demonstrate safety and effectiveness.
Here's a re-interpretation of "acceptance criteria" based on the performed tests:
Acceptance Criteria (Inferred from tests) | Reported Device Performance |
---|---|
Tensile strength (ISO 10555-1) | Pass |
Leakage and tightness (ISO 10555-1) | Pass |
Flow rate (ISO 10555-1) | Adequate flow of liquid |
Sterility (SAL 1 x 10^-6) | Achieved via ETO sterilization |
Shelf life | Established via real-time aging testing |
Biocompatibility: Cytotoxicity | Complies with EN ISO 10993-1 |
Biocompatibility: Sensitizing effect | Complies with EN ISO 10993-1 |
Biocompatibility: Intracutaneous reactivity | Complies with EN ISO 10993-1 |
Biocompatibility: Systemic (acute) toxicity | Complies with EN ISO 10993-1 |
Biocompatibility: Blood compatibility | Complies with EN ISO 10993-1 |
Biocompatibility: Rabbit pyrogenicity | Complies with EN ISO 10993-1 |
2. Sample Size Used for the Test Set and Data Provenance
This information is not provided in the document. The tests performed are bench tests (tensile strength, leakage, flow rate) and biocompatibility tests, which typically do not involve a "test set" in the context of patient data. The "samples" would be individual units of the cannula. There is no mention of country of origin for any data or whether it was retrospective or prospective.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of Those Experts
This information is not applicable/not provided. The device is a physical medical device (cannula) and the tests performed are physical and biological evaluations, not diagnostic or image-based assessments requiring expert ground truth establishment.
4. Adjudication Method for the Test Set
This information is not applicable/not provided as there is no "test set" requiring adjudication in the context of this submission. The tests are laboratory-based and measure physical properties or biological responses.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done, and the effect size of human readers improve with AI vs without AI assistance
This information is not applicable. The device is a physical cannula for organ perfusion, not an AI-powered diagnostic or assistive tool. Therefore, an MRMC study related to AI assistance is irrelevant to this submission.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done
This information is not applicable. The device is a physical cannula, not an algorithm.
7. The Type of Ground Truth Used
This information is not applicable in the traditional sense of a diagnostic device. For the bench tests, the "ground truth" would be the established engineering and ISO standards against which the device performance is measured (e.g., specific tensile strength values for a "Pass"). For biocompatibility, the "ground truth" is compliance with documented biological safety standards like EN ISO 10993-1, which dictate acceptable levels of biological response.
8. The Sample Size for the Training Set
This information is not applicable/not provided. There is no "training set" as this is not an AI/machine learning device.
9. How the Ground Truth for the Training Set was Established
This information is not applicable as there is no training set.
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(161 days)
Bridge to Life Ltd.
EasiSlush™ slushed solution is intended for topical cooling of in-situ, abdominal donor organs during intraoperative recovery from the donor. It is also intended to maintain organ hypothermia during storage and transport to the transplant recipient.
EasiSlush™ slushed solution is used to establish, and maintain hypothermia of donor organs during recovery, storage, and transport.
Organ Recovery
Prior to organ recovery, EasiSlush™ slushed solution is delivered to the open peritoneal cavity of the donor to assist in creating hypothermia by topically cooling external surfaces of organs for recovery.
During organ recovery, if ice crystals are no longer visible, the temperature of the saline solution will begin to rise and additional EasiSlush slushed solution may be delivered per established transplant team procedures. (Temperature rise may be assessed with temperature probes, being careful that the probe is measuring the solution and is not in contact with the organ).
Organ Storage/Transport
For organ storage/transport, EasiSlush™ slushed solution may be used to topically cool external surfaces of a sterile, sealed, primary organ bag containing chilled preservation solution and the organ. In this application, EasiSlush may be added to a secondary bag or to a tertiary hard container to surround the primary organ bag. Once bagged, the organ can be placed in a bed of non-sterile ice in an insulated transport container, which is then closed. Actual use should follow standard practices of the OPO or hospital for transporting and storing specific types of donor organs using sterile, slush solutions.
EasiSlush (Sodium Chloride Solution for Sterile Slush Preparation) is 1.25L sterile 0.9% Sodium Chloride Solution in a 2L bag. It meets the USP 34 monograph for Sodium Chloride Irrigation. It is a sterile, nonpyrogenic, isotonic solution that is chilled for the preparation of slushed solution.
The provided text is a 510(k) summary for EasiSlush™ (Sodium Chloride Solution for Sterile Slush Preparation). It describes the device, its intended use, and a comparison to predicate devices, focusing on the concept of substantial equivalence.
However, the summary does not contain the information requested in points 1, 2, 3, 4, 5, 6, 7, 8, and 9 of your prompt. The document explicitly states:
- "No clinical testing has been performed on this device." (Page 10)
This means there was no multi-reader multi-case (MRMC) study, no standalone algorithm performance, and no test or training sets with associated ground truth established by experts.
The acceptance criteria and performance data discussed are limited to non-clinical performance testing (biocompatibility, leachables, sterility, and performance bench tests related to temperature and USP standards).
Therefore, I cannot provide a detailed response to your request, as the necessary information regarding clinical study design, acceptance criteria based on clinical outcomes, sample sizes for test/training sets, expert involvement, and ground truth establishment from such studies is absent from this document.
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