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510(k) Data Aggregation
(104 days)
The CRS Fibrin Analysis Catheter Testing System (FACTS) is intended to collect and remove obstructing material from the internal lumen surface of an indwelling central venous catheter to restore or improve catheter flow rate, and to provide a biofilm or fibrin sample which is suitable for microbiological analysis.
The CRS Fibrin Analysis Catheter Testing System (FACTS) is an accessory to peripherally inserted central catheters (PICC). Each single use FACTS kit contains complete instructions for use, 2 pr nitrile powder free gloves (med), 2 each ear loop procedure face masks, 3 each alcohol swabs, 1 each BD Lure-Loc Access Device, 2 each vacutainer tube, 1 each test brush in sheath, 1 each over wrap drape, 1 each measure tape, 1 each clamp and 1 cach specimen transport bag. The testing brush consists of nylon bristles wound onto a flexible stainless steel wire. The testing brush is enclosed within a polysheath that is heat sealed at the distal end and again at the brush handle and is attached by color coded rings. The different rings indicate the diameter of the testing brush bristles.
The provided text is a 510(k) summary for a medical device (CRS Fibrin Analysis Catheter Testing System (FACTS)) but it does not contain details about specific acceptance criteria or a study proving that the device meets those criteria with numerical performance metrics.
The document states:
- "The results of bench and clinical testing indicates that the new device is as safe and effective as the predicate devices." (Page 1)
However, it does not provide any data, acceptance criteria, or study specifics such as:
- A table of acceptance criteria and reported device performance.
- Sample sizes for test sets, data provenance.
- Number/qualifications of experts for ground truth.
- Adjudication methods.
- MRMC comparative effectiveness study results (effect size).
- Standalone algorithm performance.
- Type of ground truth used.
- Sample size for training set or how its ground truth was established.
Therefore, I cannot fulfill the request to describe the acceptance criteria and the study that proves the device meets them based on the provided input. The document is primarily focused on the device's identification, indications for use, description, and its substantial equivalence to predicate devices for regulatory clearance.
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(142 days)
The CRS Endoluminal Brush is intended to collect a biofilm or fibrin sample, which is suitable for microbiological analysis, from the inner lumen surface of an in-dwelling central venous catheter
The CRS Endoluminal Brush product line is an accessory to central venous catheters. Each single use Endoluminal Brush kit contains 2 pairs of latex free gloves, 1- 70% isopropyl alcohol cleaning agent, 1 fibrin brush in transport bag, 1- 10 cc syringe, 2 patient labels, 1 medical drape, 1 over wrap, and Instructions for Use. The brush consists of nylon bristles wound into a flexible stainless steel wire, which is further wound into a tubular, metal, rigid handle. The Brush is enclosed within a no ratiner would at the distal end and is attached to a standard luer lock at its proximal end. The luer lock fitting complies with catheter manufacturers' requirement that only luer-lock connections be used with catheters. The various CRS Endoluminal Brush products defined by the product codes differ mainly in the length of the flexible wire and the diameter of the Brush bristles.
The provided text describes a 510(k) submission for the "CRS Endoluminal Brush" (K050889), which claims substantial equivalence to the "FAS Endoluminal Brush" (K993614). The core of the submission argues that the new device is "identical" to the predicate device. Therefore, the device's "performance" is implicitly considered to be the same as the predicate, and the "study" is a comparison to the predicate rather than a new clinical trial with specific performance metrics.
Here's an analysis based on the provided documents:
1. A table of acceptance criteria and the reported device performance
The submission does not define explicit "acceptance criteria" in terms of specific performance metrics (e.g., sensitivity, specificity, accuracy) for the device's intended function (collecting biofilm or fibrin samples). Instead, the acceptance criterion appears to be the demonstrate substantial equivalence to a predicate device.
The reported device performance, therefore, is its alleged identicality to the predicate device.
Characteristic | Acceptance Criteria (Implicit) | Reported Device Performance (Claimed) |
---|---|---|
Intended Use | Identical to predicate | Same |
Instructions for Use | Identical to predicate | Same |
Target Population | Identical to predicate | Same |
Anatomical Size | Identical to predicate | Same |
Area of Use | Identical to predicate | Same |
Design | Identical to predicate | Same (Per patent 5,405,755) |
Standards Met | Identical to predicate | Same (ANSI/AAMI, Biocompatibility, Non-pyrogenic) |
Materials | Identical to predicate | Same (Nylon bristles wound into a stainless steel flexible wire) |
Electrical Safety | Identical to predicate | Same (N/A) |
Chemical Safety | Identical to predicate | Same (N/A) |
Energy Used/Delivered | Identical to predicate | Same (N/A) |
Supplied items | Substantially similar to predicate | Different in specific items, but overall functionality not deemed to affect equivalence. |
Sterility | Similar method of sterilization and single-use | Provided packaged and sterile, EO (Predicate uses Gamma) |
2. Sample size used for the test set and the data provenance
The documents do not describe a specific "test set" or a clinical study conducted with human subjects or a defined sample size for the CRS Endoluminal Brush to evaluate its performance characteristics like sample collection efficacy.
The "testing" mentioned is bench and clinical testing to show the new device is "as safe and effective as the predicate devices," but specific details on sample sizes or data provenance (country of origin, retrospective/prospective) are not provided. The emphasis is on the substantial equivalence argument, which suggests that extensive new primary clinical data might not have been generated for this specific device, assuming its identicality to the predicate.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable. As no independent test set or clinical study with the CRS Endoluminal Brush is detailed with performance metrics, there is no mention of experts establishing ground truth for such a study. The "ground truth" for this submission would be the regulatory approval of the predicate device.
4. Adjudication method for the test set
Not applicable, as no described test set requiring expert adjudication.
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 physical medical tool (a brush for collecting samples), not an AI or imaging diagnostic device. Therefore, an MRMC study with human readers and AI assistance is entirely irrelevant to this submission.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This device is a physical medical tool and does not involve any algorithms.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
The "ground truth" for this 510(k) submission is the regulatory clearance of the predicate device (FAS Endoluminal Brush, K993614). The CRS Endoluminal Brush is asserting that it is "identical" to this already cleared device.
8. The sample size for the training set
Not applicable. This is a physical medical device, not a machine learning model, so there is no concept of a "training set."
9. How the ground truth for the training set was established
Not applicable, as there is no training set for a physical device.
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