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510(k) Data Aggregation
(300 days)
Fresenius Kabi AG
The freetlex@+ Transfer Adapter is indicated for reconstituting a drug in a vial with a 20mm closure and the transfer of the drug into the freeflex®+ IV Bag prior to administration to the patient. The device may be used for pediatric (newborn to 21 years) and adult populations.
The freeflex®+ Transfer Adapter is a single use, fluid transfer device that allows for the reconstitution and transfer of powdered or liquid drugs from drug vials into the freeflex + IV Bag (NDA BN070012) through the IV bag medication port. The device consists of a body, male Luer lock and a safety ring. The device is provided as a sterile, non-pyrogenicproduct. The device is intended to be used with standard drug vials with a seal diameter of 20mm. with an elastomeric membrane. The device does not contain any medicinal substances and there are no additional accessories needed or provided with the freeflex®+ Transfer Adapter for the device to meet its intended purpose.
The Fresenius Kabi AG freeflex®+ Transfer Adapter (K212445) is a single-use fluid transfer device intended for reconstituting drugs in a vial with a 20mm closure and transferring them into a freeflex®+ IV Bag prior to administration.
Here's an analysis of its acceptance criteria and the study that proves the device meets them:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria & Test | Reported Device Performance |
---|---|
ISO 22413:2013 Transfer sets for pharmaceutical preparations | Successfully passed. |
Fragmentation | Successfully passed. |
USP Particulate Matter in Injections Test method 1 | Successfully passed. |
Particulate Testing | Successfully passed. |
ISO 80369-20:2015 Small-bore connectors for liquids and gases in healthcare applications - Part 20: Common test methods | Successfully passed. |
Luer Connector Leakage | Successfully passed. |
Stress Cracking Resistance Testing | Successfully passed. |
ISO 11607-1 (2019-02) Packaging for terminally sterilized medical devices - Part 1: Requirements for materials, sterile barrier systems | Successfully passed. |
Sterile Barrier Systems Validation | Successfully passed. |
Internal device performance test methods | Successfully passed. |
Visual Inspection | Successfully passed. |
Penetration Force | Successfully passed. |
Force to Remove Safety Ring | Successfully passed. |
Separation under Tensile Force | Successfully passed. |
Residual Volume in Adapter-Vial-System | Successfully passed. |
Biocompatibility Testing | Successfully passed. |
Hemolysis | Successfully passed. |
Cytotoxicity | Successfully passed. |
Irritation | Successfully passed. |
Skin Sensitization | Successfully passed. |
Acute Systemic Toxicity | Successfully passed. |
Chemical Characterization | Successfully passed. |
Material Mediated Pyrogenicity | Successfully passed. |
Particulate Testing (re-listed, but part of biocompatibility section) | Successfully passed. |
Sterilization Validation | Successfully passed. |
Ethylene oxide sterilization (DIN EN ISO 11135:2014) | Achieved a Sterilization Assurance Level (SAL) of 10-6. |
2. Sample Size Used for the Test Set and Data Provenance
The document does not explicitly state the specific sample sizes for each individual test or the data provenance (e.g., country of origin, retrospective/prospective). It generally mentions "functional performance bench testing was conducted." Without specific numbers, it's impossible to provide these details accurately.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
Not applicable. This device is a physical medical device, not an AI/ML algorithm requiring expert human interpretation for ground truth establishment. The performance testing is based on objective, quantifiable measurements according to established international and internal standards.
4. Adjudication Method for the Test Set
Not applicable, for the same reason as 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
Not applicable. This is not an AI/ML device that involves human reader interpretation.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This is a physical medical device, not an algorithm.
7. The Type of Ground Truth Used
The ground truth for the performance testing is based on the objective criteria defined by the cited international standards (e.g., ISO 22413, USP , ISO 80369-20, ISO 11607-1) and internal test methods. These standards define measurable thresholds for attributes like leakage, fragmentation, particulate matter, etc. For biocompatibility, the ground truth is the absence of adverse biological reactions as defined by ISO 10993-1.
8. The Sample Size for the Training Set
Not applicable. This is a physical device and presumably does not involve a "training set" in the context of an AI/ML algorithm.
9. How the Ground Truth for the Training Set was Established
Not applicable, for the same reason as point 8.
Study Proving Acceptance Criteria are Met:
The study proving the device meets the acceptance criteria is a series of bench testing and biocompatibility testing as detailed in Section 9 of the 510(k) Summary.
- Bench Performance Testing: The device was subjected to various functional tests based on international standards (ISO 22413, USP , ISO 80369-20, ISO 11607-1) and internal test methods. These tests evaluated properties such as freedom from fragmentation, particulate matter, Luer connector leakage, stress cracking resistance, sterile barrier integrity, visual inspection, penetration force, force to remove the safety ring, separation under tensile force, and residual volume.
- Biocompatibility Testing: Following FDA guidance (ISO 10993-1), a comprehensive suite of biocompatibility tests was performed, including hemolysis, cytotoxicity, irritation, skin sensitization, acute systemic toxicity, chemical characterization, material mediated pyrogenicity, and particulate testing.
- Sterilization Validation: Ethylene oxide sterilization was validated to meet DIN EN ISO 11135:2014, achieving an SAL of 10-6.
All these tests were successfully conducted, and their aggregated results are deemed to demonstrate that the freeflex®+ Transfer Adapter performs as intended and supports a substantial equivalence determination to the predicate device (Vial2Bag Advanced™ 20mm Admixture Device, K201415). The conclusion explicitly states: "The freeflex®+ Transfer Adapter, has met all established acceptance criteria for performance testing and design verification testing. Results of functional performance and biocompatibility testing conducted with the freeflex + Transfer Adapter, demonstratethat the subject device supports a substantial equivalence determination to the predicate device."
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(413 days)
Fresenius Kabi AG
The Agilia SP Infusion System is intended for adult and pediatric care for the intermittent or continuous delivery of parenteral fluids, medication, blood derivatives through clinically accepted parenteral routes of administration. These routes of administration include intravenous, intra-arterial, subcutaneous, and intraosseous using dedicated administration sets.
The Agilia SP Infusion System is also intended for neonatal care for the intermittent or continuous delivery of parenteral fluids for hydration and nutrition, blood, and blood derivatives through clinically accepted parenteral routes of administration and critical drugs under specific conditions. These routes of administration include intravenous, intraarterial, and subcutaneous using dedicated administration sets.
It is intended for use by trained healthcare professionals in healthcare facilities
The Agilia SP Infusion System includes the Agilia SP MC WiFi Syringe Infusion Pump which is a programmable electronic medical system dedicated to administering a predetermined volume of an infusion product at a programmed rate, in combination with compatible third-party syringes and extension sets along with optional accessories. The optional accessories are identified as follows:
- Agilia Link 4, 6 and 8 Stacking rack system intended to power and organize 4, 6 or 8 pumps at the patient bedside.
- Agilia Duo - two-channel accessory designed to power two Agilia infusion pumps.
- Agilia USB Cable - intended to connect the Agilia SP infusion pump to a PC for serial communication.
The provided document describes the FDA 510(k) clearance for the Agilia SP Infusion System. This document focuses on demonstrating substantial equivalence to a predicate device, primarily through non-clinical testing and comparison of technical specifications, rather than a clinical study evaluating the device's performance against specific acceptance criteria for diagnostic or clinical outcomes.
Therefore, many of the requested detailed points regarding acceptance criteria and performance against a test set (especially those related to AI/MRMC studies, ground truth establishment, and expert adjudication) are not applicable directly to this type of device clearance and the information provided in this document.
However, I can extract information related to the acceptance criteria for the non-clinical performance of the infusion pump and the methods used to prove that performance.
Here's a breakdown based on the provided text:
1. Table of acceptance criteria and the reported device performance
The document primarily focuses on demonstrating equivalence in technical specifications and safety/performance characteristics. The most direct mention of a performance criterion is for flow rate accuracy.
Characteristic | Acceptance Criterion (Predicate Device) | Reported Device Performance (Subject Device) | Comment/Comparison |
---|---|---|---|
Flow Rate Accuracy | ±5% for 1-999 mL/h; ±5.5% for |
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(413 days)
Fresenius Kabi AG
Vigilant Master Med is part of a Dose Error Reduction System (DERS) for use with Adults, Pediatrics, and Neonates. It is intended to create, customize, and manage drug library data and device configurations to be uploaded to compatible Fresenius Kabi infusion devices which may reduce the risk of drug administration errors. It enhances safety by preventing infusion errors with the use of Dose Error Reduction System (DERS) in combination with the infusion devices.
Vigilant Master Med is a drug library software that is used by pharmacists to create and identify limits according to policy and procedure of the institution. The infusion devices will notify and clearly indicate to a clinician if the dose for the medication is beyond the limits entered by the pharmacist and provided by Vigilant Master Med in the drug library.
Vigilant Master Med is one component of Vigilant Software Suite (VSS) a multifunction device product. VSS Vigilant Master Med the subject of this submission, is also referred to as Drug Library Software. VSS Vigilant Master Med is drug library software that creates, customizes and manages drug lists, therapies, drug libraries, device configurations, profiles and data sets which are uploaded into compatible infusion pumps.
The provided text describes the 510(k) premarket notification for the "Vigilant Software Suite - Vigilant Master Med" and its comparison to a predicate device, "Vigilant Drug' Lib Agilia." However, the document primarily focuses on demonstrating substantial equivalence based on non-clinical testing and technological comparison. It explicitly states that "Clinical evaluation is not required for this submission to support substantial equivalence." and "no further clinical investigation or testing is needed."
Therefore, I cannot provide details on the acceptance criteria or a study that proves the device meets specific performance criteria in a clinical context, as such data is not included in the provided text. The submission relies on verification and validation of product requirements, human factors engineering testing, interoperability testing, performance testing at maximum capacity, and cybersecurity testing to demonstrate safety and effectiveness, and thus substantial equivalence.
Based on the information provided in the document, here's what can be extracted:
1. A table of acceptance criteria and the reported device performance:
The document implicitly defines "acceptance criteria" through the comparison to the predicate device and the findings of non-clinical tests. The "reported device performance" is essentially the determination of "Similar," "Same," or "Different" with supporting statements that these differences do not affect safety or effectiveness, or that verification/testing found no new issues.
Feature | Predicate (K121613) | Proposed (K210075) | Acceptance Criteria (Inferred from "Substantial Equivalence Analysis") | Reported Device Performance |
---|---|---|---|---|
Software Name | Vigilant Drug' Lib Agilia | Vigilant Software Suite - Vigilant Master Med | Consistency in core function (drug library software) | Similar – Both products are drug library software. |
Regulation Number | 21 CFR 880.5725 (Infusion Pump), Product Code: 80-FRN | 21 CFR 880.5725 (Infusion Pump), Product Code: 80-PHC | Alignment with infusion pump regulation, acceptable product code change | Similar – Predicate was an accessory under 80-FRN. No new safety/effectiveness issues with PHC. |
Indications for Use (Key Aspects) | Create drug libraries for patients (250g-250kg). Used by Pharmacists, IT Specialists, etc. | Create, customize, manage drug library data and device configurations for Adults, Pediatrics, and Neonates; reduce risk of drug administration errors via DERS. Pharmacists create limits. Infusion devices notify clinicians of limits. | Expanded patient populations (Neonates) and explicit mention of DERS; no adverse effect on safety/effectiveness. | Similar - Descriptive information in the indications for use provides more detailed information about use of the device with specific patient populations and how specific users interact with the device. The modified intended use does not affect the safety and effectiveness of the subject device. |
Supported Pumps | Volumat MC Agilia | Agilia SP MC WiFi, Agilia VP MC WiFi | Compatibility with current pump designs without new safety issues. | Similar - Pump compatibility matches the proposed pump design. Verification, human factors, performance (stress/load) and interoperability testing found no new issues of safety or effectiveness. |
Software Requirements (OS) | Windows XP SP2, Vista, 7 | Microsoft Windows Server 2016 | Updated OS compatibility without new safety issues. | Similar - Compatible operating systems with more recent version has been expanded to match those currently in use and available. Verification testing found no new issues of safety or effectiveness. |
.NET Framework | 4.0 or Higher | 4.8 or Higher | Updated framework without new safety issues. | Similar - Software development framework with recent version. Verification testing found no new issues of safety or effectiveness. |
SQL Server Platform | ITTIA DB SQLTM | Microsoft SQL Server 2016 | Different database, but no new safety/effectiveness issues. | Similar. Verification testing found no new issues of safety or effectiveness. |
Pump Data Transmission | USB cable (single pump) | Wireless (multiple pumps) | Wireless transmission without new safety/effectiveness issues, verified through testing. | Similar - The same drug library data is transmitted wirelessly instead of through a cable. Verification, performance, and interoperability testing found no new issues of safety or effectiveness. |
Type of Application | Desktop | Web Based | Application type change without new safety/effectiveness issues. | Similar - The application type (web based versus desktop) is secondary to the function of the software. Verification, human factors, performance and interoperability testing found no new issues of safety or effectiveness. |
Interfacing Software Applications | Single Stand Alone Software System | Multi-Function Software System (Vigilant Master Med, Centerium, Insight, Agilia Partner) | Broader system integration with no new safety/effectiveness issues. | Similar - Although the function of the drug library software is similar, the change to the architecture supports more functions (...) and has been broken into separate sub-systems. Verification, human factors, performance and interoperability testing found no new issues of safety or effectiveness. |
User Rights and Privileges | Single User | Multiple User (approval for drug library release, multi-factor authentication) | Enhanced user control and security consistent with guidance. | Similar - Multiple user approval (...) and multi-factor authentication (...) permit the healthcare facility more control of user rights, access, privileges, and permissions. This is consistent with updated guidance on software in medical devices and cybersecurity. Verification and human factors testing found no new issues of safety or effectiveness. |
Total Number of Drugs/Therapy in Drug Library System | Based on memory (approx. 600) | 10,000 | Increased capacity without new safety/effectiveness issues. | Similar - The increase gives users the ability to configure a larger number of drugs and therapies in the library. Safety and effectiveness concerns are the same. Verification and performance testing found no new issues of safety or effectiveness. |
Total Number of Drug Entries per Pump | 3800 | 3800 | Identical. | Same. |
Number of Drug Libraries | Limited by Available Memory | 50 | Increased number of libraries without new safety/effectiveness issues. | Similar - The increase gives users the ability to configure a larger number of drug libraries. Verification testing found no new issues of safety or effectiveness. |
Max Number of Drug/Therapy Entries per Individual Drug Library | 200 | 200 | Identical. | Same. |
Drug Name Length (max characters) | 19 | 24 | Extended length, no new safety/effectiveness issues. | Similar - The extended drug name field length is enabled by software differences in the newer operating systems. Safety and effectiveness concerns are the same. Verification and human factors testing found no new issues of safety or effectiveness. |
Number of Therapies per Drug | 0 | 30 | New feature: ability to configure multiple therapies per drug, no new safety/effectiveness issues. | Different - This feature gives users the ability to configure multiple therapies per drug. Verification testing found no new issues of safety or effectiveness. |
Number of Device Configurations | Limited by Available Memory | 50 | Increased number of configurations without new safety/effectiveness issues. | Similar - The increase gives users the ability to configure a larger number of device configurations. Verification testing found no new issues of safety or effectiveness. |
Number of Profiles/Care Area | Limited by Available Memory | 50 | Increased number of profiles without new safety/effectiveness issues. | Similar - The increase gives users the ability to configure a larger number of profiles/care areas. Verification testing found no new issues of safety or effectiveness. |
Number of Drug Categories | 0 | 50 | New feature: organizes drugs by category, no new safety/effectiveness issues. | Different - This feature gives users the ability to organize drugs within the drug library by drug category. Verification testing found no new issues of safety or effectiveness. |
Drug Library Report | Yes | Yes | Identical. | Same. |
Clinical Advisories/Remarks per Drug Entry | Yes | Yes | Identical. | Same. |
Clinical Reminder / Allowed per Drug Entry | No | Yes | New feature: additional clinical info, no new safety/effectiveness issues. | Different - The clinical reminder is a new feature that provides users with additional clinical information. Verification and human factors testing found no new issues of safety or effectiveness. |
Clinical Advisories Length (max characters) | 149 | 149 | Identical. | Same. |
Max Number of Drug Libraries per Dataset | 19 | 19 | Identical. | Same. |
Data Set Naming | Yes | Yes | Identical. | Same. |
Dose/Concentration Settings (Key Aspects) | Standard parameters (dilution, conc., hi/lo limits, rates, units); Fixed conc./dil. up to 5; Dose 0.01-9999; Volume 1-2000mL; Flow Rate 0.1-1000mL/h. Lower hard limit: No. | Standard parameters; Fixed conc./dil. up to 5 per Therapy, 20 per Drug; Dose 0.01-70000; Agilia VP Vol. 1-9999mL, SP Vol. 1-60mL; Agilia VP Flow 0.1-1500mL/h, SP Flow 0.1-1200mL/h. Lower hard limit: Yes. | Enhanced flexibility for fixed concentrations, expanded range for dose, volume, and flow, and added lower hard limit. All changes verified to cause no new safety/effectiveness issues. | Similar - Concentration/dilutions can now be configured at both the Therapy and Drug level. Verification testing found no new issues of safety or effectiveness. Similar - Greater range of dose (concentrations/dilutions) for patient care. Verification testing found no new issues of safety or effectiveness. Similar - Greater range for volumetric pump provides more flexibility in patient care. Addition of syringe pump range. Verification testing found no new issues of safety or effectiveness. Different - Addition of lower hard limit risk control. Verification testing found no new issues of safety or effectiveness. Similar - Greater range for volumetric pump provides more flexibility in patient care. Addition of syringe pump range. Verification testing demonstrated found no new issues of safety or effectiveness. |
Dose or Volume over Time Upper/Lower Limits (Agilia SP Specific Feature) | No | Yes | New syringe pump feature for setting limits based on protocol, no new safety/effectiveness issues. | Different - Feature for syringe pump that allows users to set dose or volume limits based on a facilities protocol. Verification and human factors testing found no new issues of safety or effectiveness. |
Direct Bolus (Key Aspects) | Enable/disable, Volume Upper hard limit, Max Volume 1-60mL; Flow Rate 200-600 mL/h. | Enable/disable, Volume Upper hard limit, Max Volume 1-60mL; Agilia VP Flow 50-1500 mL/h, Agilia SP Flow 50-1200 mL/h. | Wider flow rate range for pumps, no new safety/effectiveness issues. | Same (for Bolus Enable, Volume, Max Volume). Similar - Greater range for volumetric pump provides more flexibility in patient care. Addition of syringe pump range. Verification and human factors testing found no new issues of safety or effectiveness. |
Programmed Bolus (Key Aspects) | Enable/disable, Default volume/dose, Upper Volume/Dose Hard Limit; Volume 0.1-1000mL; Dose 0.01-9999. Upper/Lower Hard Duration Limit, Dose/Volume Upper/Lower soft limit, Dose/Volume Lower hard limit: No. | Enable/disable, Default volume/dose, Upper Volume/Dose Hard Limit; Agilia VP Vol. 0.1-1000mL, SP Vol. 0.1-99.9mL; Dose 0.01-9999. Upper/Lower Hard Duration Limit, Dose/Volume Upper/Lower soft limit, Dose/Volume Lower hard limit: Yes. | Added limits for duration, volume, and dose for programmed bolus, and expanded volume range for SP, no new safety/effectiveness issues. | Same (for Bolus Enable, Default/Upper Volume/Dose, Dose Unit). Similar - Addition of syringe pump range. Human factors testing found no new issues of safety or effectiveness. Different - Addition of duration, volume, and dose limits for programmed bolus feature. Verification and human factors testing found no new issues of safety or effectiveness. |
Loading Dose (Key Aspects) | Enable/disable, Duration Lower hard limit, Default duration, Dose Upper/Lower soft limit, Default Dose, Dose Upper hard limit, Dose Range: 0.01-9999. Duration Upper hard limit and Dose Lower hard limit: No. | Enable/disable, Duration Lower hard limit, Default duration, Dose Upper/Lower soft limit, Default Dose, Dose Upper hard limit, Dose Range: 0.01-9999. Duration Upper hard limit and Dose Lower hard limit: Yes. | Added duration and dose limits, no new safety/effectiveness issues. | Same (for Bolus Enable, Lower Hard Limit, Default Duration, Upper/Lower soft, Default Dose, Upper Hard Limit, Dose Range). Different - Addition of duration and dose limits for loading dose feature. Verification and human factors testing found no new issues of safety or effectiveness. |
Profile/Category/Profile Management (Key Aspects) | Max profiles per Dataset: 20; Drug Libraries per Profile: 1; Device Config Capabilities: Yes; Device Configs per profile: 1; Profile Name max: 19 characters. | Max profiles per Dataset: 20; Drug Libraries per Profile: 1; Device Config Capabilities: Yes; Device Configs per profile: 1; Profile Name max: 24 characters. | Extended profile name length, no new safety/effectiveness issues. | Same (for Max Profiles, Drug Libraries, Device Config Capabilities/per profile). Similar - Additional profiles provide users with more options. Verification and Human Factors testing were performed which found no new issues of safety or effectiveness. |
General Configuration Options (Key Aspects) | Pressure Alarm Threshold, Type (3 levels), Near end of infusion alarm, KVO Enable/Disable; Pressure Limits (Low, Medium, High); Near end of infusion alarm Volume: 0-50mL, Duration: 2-30min; KVO Rate: 0-20mL/h. | Pressure Alarm Threshold, Type (3 levels), Near end of infusion alarm, KVO Enable/Disable; Agilia VP High Pres: 250-750mmHg/Range, SP High Pres: 250-900mmHg/Range; Near end of infusion alarm Volume: 1-50mL, Duration: 1-30min; Agilia SP KVO: 0.1-5mL/h, VP KVO: 1.0-20 mL/h. | Extended pressure limits and alarm ranges for SP/VP pumps, no new safety/effectiveness issues. | Same (for Alarm Threshold, Type, Near End Alarm, KVO Enable/Disable, Low/Medium Pressure Limits). Similar - Addition of pressure limit range for syringe pump. Verification and human factors testing found no new issues of safety or effectiveness. Similar - Change to minimum near end of infusion alarm volume range. Verification and human factors testing found no new issues of safety or effectiveness. Similar - Change to minimum near end of infusion alarm duration range. Verification and human factors testing demonstrated found no issues of safety or effectiveness. Similar - Change to minimum range for KVO rate and addition of range for syringe pump. Verification and human factors testing demonstrated found no issues of safety or effectiveness. |
Pressure Management (per drug) | No | Yes | New feature: pressure management for specific clinical needs, no new safety/effectiveness issues. | Different - Pressure management for specific clinical needs. Verification and human factors testing found no issues of safety or effectiveness. |
Air in Line Management (per drug) | No | Yes | New feature: air in line management for specific clinical needs, no new safety/effectiveness issues. | Different - Air in line management for specific clinical needs. Verification and human factors testing found no issues of safety or effectiveness. |
Near end of infusion alarm Volume Default/Range | 5mL/Default, 0-50mL/Range | N/A/Default, 1-50mL/Range | Changed default, no new safety/effectiveness issues. | Similar - Change to near end of infusion alarm volume range. Verification and human factors testing found no issues of safety or effectiveness. |
2. Sample sizes used for the test set and the data provenance:
- Sample Size: The document does not specify exact "sample sizes" in terms of number of cases or data points for the non-clinical tests (verification, human factors, interoperability, performance, cybersecurity testing). It refers to the sufficiency of these tests to conclude safety and effectiveness.
- Data Provenance: Not specified in terms of country of origin. The data is generated from non-clinical (laboratory/engineering) testing rather than patient data. The studies are prospective in the sense that they are specifically conducted for the regulatory submission to verify and validate the new device.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Number of Experts: Not explicitly stated. The "ground truth" for this device (software for managing infusion pump drug libraries) would primarily be established by:
- Engineers/Developers: Defining correct software functionality and performance.
- Quality Assurance personnel: Verifying adherence to requirements.
- Human Factors Specialists: Assessing usability and safety in simulated clinical tasks.
- Pharmacists and Clinicians (as users): Participating in human factors evaluations to ensure the software's design supports their workflow and safety goals. The document states "Human Factors studies have been conducted on the subject device demonstrating passing results," implying clinical domain experts were involved in a user capacity.
- Qualifications of Experts: Not explicitly stated for specific roles. However, given the context of medical device regulation, these would be qualified professionals in their respective fields (e.g., software engineers, human factors engineers, clinical experts - likely pharmacists and nurses for an infusion pump system).
4. Adjudication method for the test set:
- Since no multi-reader or multi-expert assessment of clinical "cases" is described (as it's a software substantial equivalence submission based on non-clinical tests), there is no mention of an adjudication method like 2+1 or 3+1. The "adjudication" is implicitly the outcome of the comprehensive verification and validation processes and the safety assurance case.
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 MRMC study was done. This is not an AI-assisted diagnostic device where human reader improvement would be measured. The device is a software for drug library management for infusion pumps, not a medical image analysis or similar AI tool.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- The software's core function is to create and manage drug libraries, which is "algorithm only" in its processing of data and rules. However, its purpose is to be used with human-in-the-loop (pharmacists inputting data, clinicians interacting with the infusion pump).
- Standalone algorithmic verification: Yes, this is implied by "Verification testing of product requirements," "Performance testing at maximum capacity," and "Cybersecurity penetration testing." These tests assess the software's inherent functionality and robustness independent of user interaction, but within the context of its overall intended use.
7. The type of ground truth used:
- The primary "ground truth" used for this submission is:
- Pre-defined product requirements and specifications: The software must perform according to these.
- Safety standards and regulatory guidance: Adherence to these is the "truth" for demonstrating safety and effectiveness.
- Usability goals derived from human factors analysis: The software's design must support safe and effective use by intended users.
- Functionality of the predicate device: The new device's functions are compared to the legally marketed predicate.
- It is not based on expert consensus for clinical diagnosis, pathology, or outcomes data, as this is not a diagnostic device.
8. The sample size for the training set:
- Not applicable/Not provided. This is a traditional software engineering development and a 510(k) submission based on substantial equivalence, not a machine learning/AI model that requires a "training set" for its development. The "learning" here is human engineering and design, not algorithmic learning from data.
9. How the ground truth for the training set was established:
- Not applicable. As stated above, there is no "training set" in the machine learning sense.
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(413 days)
Fresenius Kabi AG
The Agilia VP Infusion System is intended for adult and pediatric care for the intermittent or continuous delivery of parenteral fluids, medications, blood derivatives through clinically accepted parenteral routes of administration. These routes of administration include intravenous, intra-arterial, subcutaneous and intraosseous using dedicated administration sets.
The Agilia VP Infusion System is also intended for neonatal care for the intermittent or continuous delivery of parenteral fluids for hydration and nutrition, blood derivatives through clinically accepted parenteral routes of administration. These routes of administration include intravenous, intra-arterial, and subcutaneous using dedicated administration sets.
It is intended for use by trained healthcare professionals in healthcare facilities.
The Agilia VP Infusion System includes the Agilia VP MC WiFi Volumetric Infusion Pump, which is a programmable electronic medical system dedicated to administering a pre-determined volume of an infusion product at a programmed rate, in combination with Volumat Line administration sets and optional accessories. The optional accessories are identified as follows:
- Agilia Link 4, 6 and 8 Stacking rack system intended to power and organize 4, 6 or 8 pumps at the patient bedside.
- Agilia Duo two-channel accessory designed to power two Agilia infusion pumps.
- Agilia USB Cable - intended to connect the Agilia VP infusion pump to a PC for serial communication.
The provided document is a 510(k) summary for the Fresenius Kabi Agilia VP Infusion System. This document focuses on demonstrating substantial equivalence to a predicate device (Agilia Infusion System (K121613)), rather than proving the device meets specific acceptance criteria based on a clinical study evaluating its diagnostic or therapeutic performance (like an AI/CADe device).
Therefore, the requested details specific to a study that proves the device meets acceptance criteria (especially for AI/CADe devices, such as sample size, ground truth, expert adjudication, MRMC studies, standalone performance, training set details) are not applicable (N/A) in this context.
This submission relies on non-clinical testing and comparison to a predicate device to establish safety and effectiveness.
Here's an analysis of the document regarding acceptance criteria and the methods used to prove substantial equivalence:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not present a formal table of quantitative acceptance criteria with reported numerical performance values in the way one would for a diagnostic AI device (e.g., sensitivity, specificity thresholds). Instead, it relies on demonstrating similarity to a predicate device and showing conformance to industry standards and internal design verification/validation testing.
The "acceptance criteria" are implied by:
- Substantial Equivalence: The primary "acceptance criterion" for a 510(k) submission is to demonstrate that the new device is as safe and effective as a legally marketed predicate device.
- Conformance to Standards: Meeting the requirements of relevant electrical safety, EMC, and usability standards (e.g., IEC 60601-1, IEC 62366-1).
- Verification and Validation Testing: This implicitly means the device performs according to its design specifications.
- Reliability Goals: The device met its internal reliability goals.
Implied Acceptance Criteria and Reported Performance (from comparison table and non-clinical testing section):
Acceptance Criteria (Implied) | Reported Device Performance |
---|---|
Infusion Accuracy | Agilia VP Infusion System: ± 5% under most conditions. (Stated as "Similar" to predicate which also had ± 5%). Detailed flow rate accuracy disclosed in labeling. Flow rate and bolus accuracy testing conducted per AAMI TIR101 2021. |
Safety (Electrical & EMC) | Agilia VP Infusion System: Complies with IEC 60601-1: 2005 +A1:2012 (3rd edition) for Electrical Safety and IEC 60601-1-2: 2014 for EMC testing. ("Similar" due to application of state-of-the-art standards). |
Usability/ Human Factors | Agilia VP Infusion System: Human factors evaluation conducted to validate effectiveness of use-related features/functionality and use error-related mitigations, following IEC 62366-1 Edition 1.0 2015. ("Passing results"). |
Software Verification & Validation | Agilia VP Infusion System: Performed per FDA Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices (May 11, 2005). |
Cybersecurity | Agilia VP Infusion System: Cybersecurity testing performed confirmed the system is effective in addressing cybersecurity threats, referencing FDA guidances (Management of Cybersecurity, Oct 2014; Postmarket Management of Cybersecurity, Dec 2016). |
Reliability | Agilia VP Infusion System: Device reliability activities, testing and statistical analysis confirmed the system met its reliability goal at the system, device subsystem, and subsystem component levels. |
Risk Assessment | Agilia VP Infusion System: Residual risks analyzed and determined to be acceptably low using industry-standard risk analysis practices and regulatory guidance. |
Performance of New Features (Ramp-up/down, Sequential modes, WIFI, auto-restart) | Agilia VP Infusion System: Performance testing demonstrates these additional modes/features do not introduce any new issues of safety or effectiveness. ("Similar" or "Similar" in comments of Table 2). The document states: "Results of verification and validation activities demonstrate that the Agilia VP Infusion System is substantially equivalent to the predicate Agilia Infusion System (K121613)." and "Design verification and validation testing confirmed the Agilia VP Infusion System met user needs and design inputs. Testing results conformed with acceptance criteria." |
The following points are N/A for this type of 510(k) submission which is for an infusion pump, not an AI/CADe device.
2. Sample size used for the test set and the data provenance: N/A (No clinical test set for diagnostic performance)
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: N/A (No ground truth establishment for diagnostic performance)
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set: N/A
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: N/A
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: N/A
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.): N/A (Ground truth in this context would refer to engineering specifications and performance measurements against those specifications, rather than clinical ground truth for diagnostic accuracy)
8. The sample size for the training set: N/A (Not an AI/ML device in the context of diagnostic algorithms; "training set" would relate to internal engineering development and testing, not a formal clinical data training set for an AI model)
9. How the ground truth for the training set was established: N/A
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(29 days)
Fresenius Kabi AG
The CATSmart System by Fresenius Kabi is an autotransfusion device indicated for the processing of autologous shed blood collected intraoperatively and postoperatively to obtain washed red blood cells for reinfusion. Additionally, it can be used for perioperative separation of blood into Packed Red Cells (PRC), Plasma (PLS) and Platelet Rich Plasma (PRP).
The Fresenius Kabi CATSmart device is an intraoperative autotransfusion system for intra- and/or postoperative processing of blood lost through surgery or trauma. The CATSmart device operates on the principle of a continuous flow centrifuge, comparable to continuous systems for hemapheresis which, for decades, have been widely used in blood banks.
In a typical CATSmart procedure, the shed blood, which is anticoagulated and collected in a sterile reservoir, is processed in a continuous washing process to obtain washed packed red cells for reinfusion to the patient. During this process all plasmatic and nonerythrocytic cellular components of the collected blood, and thus activated coagulation factors, products of fibrinolysis and cell trauma as well as the anticoagulant are removed. The packed red cells are collected in a reinfusion bag from which they can be reinfused to the patient via a transfusion set when needed.
The system includes disposable sets and accessories previously cleared by FDA in respective 510(k)'s.
This document is a 510(k) summary for the Fresenius Kabi CATSmart device, an autotransfusion system. It is a notification of intent to market a device that the manufacturer believes is substantially equivalent to legally marketed predicate devices.
The document does not contain detailed acceptance criteria for a study showing device performance. Instead, it describes general claims of substantial equivalence based on the device's design, materials, specifications, technological characteristics, and function being unchanged from previously cleared devices, and that manufacturing and sterilization methods at a new site remain the same.
Therefore, the requested information for acceptance criteria and a study proving the device meets them, including specific details about sample size, data provenance, expert qualifications, adjudication methods, MRMC studies, standalone performance, ground truth establishment, and training set details, is not available in the provided text.
The document specifically states: "No clinical data was required to support the changes described in this submission." This indicates that a study demonstrating performance against specific criteria was not conducted for this particular submission. The substantial equivalence is based on the device being inherently the same as a previously cleared one.
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(193 days)
Fresenius Kabi AG
Depending on the AMICUS Separator System disposable used in the therapeutic apheresis procedure, the AMICUS Separator System has been cleared for the following:
The AMICUS Separator System is an automated blood cell separator indicated to perform therapeutic plasma exchange (TPE). (K111702)
The AMICUS Exchange Kit is indicated for use in therapeutic plasma exchange (TPE). The kit is for use with the AMICUS separator. (K111702)
The AMICUS Separator System is an automated blood component separator indicated to perform red blood cell exchange (RBCX), including exchange and depletion/exchange procedures, for the transfusion management of sickle cell disease in adults and children. (K180615)
The AMICUS Exchange Kit – Therapeutics is indicated for use in therapeutic plasma exchange (TPE) and red blood cell exchange (RBCX). The kit is for use with the AMICUS separator. (K111702, K180615)
The waste transfer set is indicated for use in red blood cell exchange (RBCX). The set is for use with the AMICUS separator. (K180615)
The Blood Component Filter Set with Vented Spike and Luer Adapter is indicated for the administration of blood and blood components during a therapeutic plasma exchange (TPE) or red blood cell exchange (RBCX) therapeutic apheresis procedure. The set is for use with the AMICUS separator. (K111702, K180615)
The AMICUS Separator System is an automated blood cell separator indicated for the collection of blood components and mononuclear cells.
Depending on the AMICUS Separator System apheresis kit used in the collection of products, the AMICUS Separator System has been cleared to collect:
- Platelets Pheresis, Leukocytes Reduced (single, double, or triple units)(BK960005, BK990009)
- Platelets Pheresis, Leukocytes Reduced, Platelet Additive Solution (InterSol)(single, double or triple units) (BK090065)
- Red Blood Cells, Leukocytes Reduced (by apheresis) (BK000039)
- Mononuclear Cells (BK000047)
- Plasma (BK960005, BK120041)
- Fresh Frozen Plasma
- Must be prepared and placed in a freezer at -18° C or colder within eight hours after phlebotomy.
- Plasma Frozen Within 24 Hours After Phlebotomy (PF24)
- Must be stored at 1-6°C within eight hours after phlebotomy and placed in a freezer at -18° C or colder within 24 hours after phlebotomy.
- Indicated for replacement of non-labile clotting factors. This product is not equivalent to Fresh Frozen Plasma.
- Plasma Frozen Within 24 Hours After Phlebotomy (PF24) Held at Room Temperature Up to 24 Hours After Phlebotomy (PF24RT24)
- Can be stored at room temperature for up to 24 hours after phlebotomy. Product must be placed in a freezer at -18° C or colder within 24 hours after phlebotomy.
- Indicated for replacement of non-labile clotting factors. This product is not equivalent to Fresh Frozen Plasma.
- Source Plasma
The device is designed to collect products while maintaining an extracorporeal volume at or below 10.5ml/kg and a donor post-platelet count greater than or equal to 100,000 platelets/microliter.
Platelet Pheresis (single, double, or triple units) may be manufactured from products that do not meet leukocyte reduction product standards. This does not apply to Platelet Additive Solution (InterSol) (single, double or triple units).
The AMICUS platelet storage container is cleared to store Platelets Pheresis, Leukocytes Reduced in 100% plasma for up to seven days. Additionally, for platelet units stored past five days and through seven days, every product must be tested with a bacterial device cleared by FDA and labeled as a "safety measure."
The AMICUS Separator System is comprised of the AMICUS separator instrument and a disposable apheresis kit specific to the procedure being performed. The instrument is a continuous-flow, centrifugal device that draws whole blood from a donor/patient, separates the blood into its components, collects one or more of the blood components, and returns the remainder of the blood components to the donor/patient. The instrument operates using pumps, clamps and valves that move donor/patient blood through a singleuse, sterile fluid path disposable kit. The cells are centrifugally separated within the kit by density differences.
The operator is responsible for connecting and monitoring the donor/patient and operating and monitoring the AMICUS separator during the procedure. The operator controls the separator through a touch screen. When necessary, the operator is warned of problems with messages on the screen and corresponding audible alerts.
Once the cell separation is complete, the operator disconnects the donor/patient, dismantles the kit, and disposes of the kit in a safe manner. The kit is packaged in a recyclable plastic tray.
The provided document is a 510(k) Premarket Notification from the FDA for the Fresenius Kabi AMICUS Separator System. This document is a regulatory approval letter and a summary of the device and its modifications, not a study report. As such, it does not contain the detailed performance study data, acceptance criteria, ground truth establishment methods, or sample sizes typically found in a clinical study report or a pre-market approval application for a novel device or a significant new indication.
The document states that the primary changes to the AMICUS device are:
- Replacement of obsolete controller circuit boards and associated redesign of other internal boards.
- Modification to the rear door design to accommodate new USB ports, Ethernet port, serial port, and Wi-Fi antenna.
- An update to the 6.0 software, including a change in the operating system from pSOS to QNX, to run on the proposed device with the new hardware.
- Qualification of a new off-the-shelf USB barcode scanner.
It explicitly states: "The software changes do not involve changes to the core blood component collection or therapeutic procedure functionality." and "The AMICUS disposable apheresis kits remain the same as the currently cleared kits, including design, materials and manufacturing methods."
The conclusion section states: "Software and systems verification testing of impacted requirements were performed with the replacement hardware components and updated 6.0 software. Regression testing was performed including paired testing with the predicate device on key product quality and performance characteristics. Results from the software and systems verification testing indicate that the subject device is as safe and performs as well as the predicate device."
Therefore, based on the provided text, I cannot extract the specific information requested in the prompt regarding acceptance criteria tables, sample sizes, expert involvement, adjudication methods, MRMC studies, standalone performance, or detailed ground truth methodologies, because these types of studies were not conducted or reported in this 510(k) summary for a device modification, where the manufacturer is claiming substantial equivalence to a previously cleared predicate device due to hardware and software updates that do not alter core functionality. The "performance data" section primarily refers to verification testing (software and systems verification, regression testing compared to predicate, and electrical safety/EMC testing) rather than clinical performance studies with human subjects or expert readers that would typically involve the criteria you've listed.
In summary, the document describes a device modification rather than a new device or significant new indication. The approval relies on demonstrating substantial equivalence to existing, cleared devices, primarily through engineering verification and validation testing, and not necessarily new extensive human-based performance studies as would be the case for an AI/ML algorithm with diagnostic capabilities.
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(96 days)
Fresenius Kabi AG
Depending on the AMICUS Separator System disposable used in the therapeutic apheresis procedure, the AMICUS Separator System has been cleared for the following:
The AMICUS Separator System is an automated blood cell separator indicated to perform therapeutic plasma exchange (TPE). (K111702)
The AMICUS Exchange Kit is indicated for use in therapeutic plasma exchange (TPE). The kit is for use with the AMICUS separator. (K111702)
The AMICUS Separator System is an automated blood component separator indicated to perform red blood cell exchange (RBCX), including exchange and depletion/exchange procedures, for the transfusion management of sickle cell disease in adults and children. (K180615)
The AMICUS Exchange Kit – Therapeutics is indicated for use in therapeutic plasma exchange (TPE) and red blood cell exchange (RBCX). The kit is for use with the AMICUS separator. (K111702, K180615)
The waste transfer set is indicated for use in red blood cell exchange (RBCX). The set is for use with the AMICUS separator. (K180615)
The Blood Component Filter Set with Vented Spike and Luer Adapter is indicated for the administration of blood and blood components during a therapeutic plasma exchange (TPE) or red blood cell exchange (RBCX) therapeutic apheresis procedure. The set is for use with the AMICUS separator. (K111702, K180615)
The AMICUS Separator System is an automated blood cell separator indicated for the collection of blood components and mononuclear cells.
Depending on the AMICUS Separator System apheresis kit used in the collection of products, the AMICUS Separator System has been cleared to collect:
- · Platelets Pheresis, Leukocytes Reduced (single, double, or triple units) (BK960005) (BK990009)
- · Platelets Pheresis, Leukocytes Reduced, Platelet Additive Solution (InterSol) (single, double or triple units) (BK090065)
- · Red Blood Cells, Leukocytes Reduced (by apheresis) (BK000039)
- Mononuclear Cells (BK000047)
- · Plasma (BK960005, BK120041)
- o Fresh Frozen Plasma
· Must be prepared and placed in a freezer at -18° C or colder within 8 hours after phlebotomy.
- o Plasma Frozen Within 24 Hours After Phlebotomy (PF24)
- Must be stored at 1-6℃ within 8 hours after phlebotomy and placed in a freezer at -18° C or colder within 24 hours after phlebotomy.
· Indicated for replacement of non-labile clotting factors. This product is not equivalent to Fresh Frozen Plasma.
o Plasma Frozen Within 24 Hours After Phlebotomy (PF24) Held at Room Temperature Up to 24 Hours After Phlebotomy (PF24RT24)
-
· Can be stored at room temperature for up to 24 hours after phlebotomy. Product must be placed in a freezer at -18° C or colder within 24 hours after phlebotomy.
-
· Indicated for replacement of non-labile clotting factors. This product is not equivalent to Fresh Frozen Plasma.
o Source Plasma
The device is designed to collect products while maintaining an extracorporeal volume at or below 10.5ml/kg and a donor post platelet count greater than or equal to 100,000 platelets/microliter. (BK080018)
Platelet Pheresis (single, double, or triple units) may be manufactured from products that do not meet leukocyte reduction product standards. This does not apply to Platelet Additive Solution (InterSol) (single, double, or triple units). (BK090065)
The AMICUS platelet storage container is cleared to store Platelets Pheresis, Leukocytes Reduced in 100% plasma for up to 7 days. Additionally, for platelet units stored past 5 days and through 7 days, every product must be tested with a bacterial device cleared by FDA and labeled as a "safety measure." (BK040059, BK150242)
The AMICUS Separator System is comprised of the AMICUS separator instrument and a disposable apheresis kit specific to the procedure being performed. The instrument is a continuous-flow, centrifugal device that draws whole blood from a donor/patient, separates the blood into its components, collects one or more of the blood components, and returns the remainder of the blood components to the donor/patient. The instrument operates using pumps, clamps and valves that move donor/patient blood through a single-use, sterile fluid path disposable kit. The cells are centrifugally separated within the kit by density differences.
The operator is responsible for connecting and monitoring the donor/patient and operating and monitoring the AMICUS separator during the procedure. The operator controls the separator through a touch screen. When necessary, the operator is warned of problems with messages on the screen and corresponding audible alarms.
Once the cell separation is complete, the operator disconnects the donor/patient, dismantles the kit, and disposes of the kit in a safe manner. The kit is packaged in a recyclable plastic tray.
The document provided describes a 510(k) premarket notification for the AMICUS Separator System, focusing on a software update (version 6.0). A 510(k) submission generally claims substantial equivalence to a predicate device, rather than providing extensive de novo clinical studies to establish new acceptance criteria and prove performance against those criteria in a traditional sense.
Therefore, the information requested, which typically relates to clinical studies establishing performance against defined acceptance criteria for a novel device, is not directly available in this type of FDA submission.
However, I can extract the information provided about the verification and validation activities for the software update and explain why some of the requested information is not applicable to a 510(k) for a software modification.
Here's a breakdown based on the provided text:
1. Table of acceptance criteria and the reported device performance:
The document states that "Software and systems verifications were performed in support of this submission. The results of the testing were acceptable." However, it does not explicitly list specific acceptance criteria (e.g., in terms of sensitivity, specificity, accuracy for a diagnostic device, or specific performance metrics for a therapeutic device's outcome) and then report quantified performance against those criteria. This type of detailed breakdown is not typically required or provided in a 510(k) for a software enhancement to an already cleared device. The "acceptance criteria" here would be that the software performs its intended functions correctly and safely, as per the design specifications and referenced standards.
The performance is implicitly reported as "acceptable" based on the verification and validation, implying that the software modification did not negatively impact the previously established performance of the AMICUS Separator System, and likely improved the listed enhancements.
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective):
The document does not specify a "test set" in the context of clinical data for performance assessment. The "testing" mentioned refers to software and system verification, which would typically involve testing new functionalities, ensuring existing functionalities are preserved, and assessing system stability. The number of test cases run, or the number of simulated or actual apheresis procedures performed during verification, is not disclosed. Data provenance in this context would refer to the details of the testing environment rather than patient data.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
This information is not applicable. For a software update to an existing apheresis system, "ground truth" as established by medical experts (e.g., radiologists, pathologists) is not relevant in the same way it would be for a diagnostic AI device. Software verification focuses on functional correctness, safety, and adherence to design specifications.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
Not applicable for software verification. Adjudication methods are typically used in clinical studies where multiple experts assess cases and their opinions need to be reconciled to establish a ground truth.
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 an automated blood cell separator, not a diagnostic AI device that assists human readers. No MRMC study would be performed for this type of device.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
The device (AMICUS Separator System) is inherently a "human-in-the-loop" system, as an operator connects and monitors the donor/patient and operates the separator. The software is part of this system. Therefore, the concept of "standalone" algorithm performance as typically applied to AI for diagnosis is not directly relevant here. The software verification assesses the behavior and functionality of the software within the context of the overall system and its intended use.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc):
Not applicable. The "ground truth" for software verification typically involves the design specifications and expected behavior of the software functions. For example, if a new feature is added to calculate a specific parameter, the "ground truth" is that the calculation is correct according to the mathematical formula and clinical parameters.
8. The sample size for the training set:
Not applicable. This is a software update for a control system, not a machine learning model that requires a training set of data.
9. How the ground truth for the training set was established:
Not applicable. See point 8.
Summary of what is known from the document regarding meeting acceptance criteria:
The document emphasizes that "Software and systems verifications were performed in support of this submission. The results of the testing were acceptable."
The study (or rather, the verification and validation activities) that proves the device meets (implicitly defined) acceptance criteria is described as compliant with recognized standards and guidance documents:
- IEC 62304 Ed. 1.0, "Medical device software Software life cycle processes": This standard outlines requirements for the software development life cycle of medical device software, ensuring safety and quality.
- ISO 14971:2012 Medical Devices – Applications of Risk Management to Medical Devices: This standard specifies a process for a manufacturer to identify the hazards associated with medical devices, including in vitro diagnostic medical devices, to estimate and evaluate the associated risks, to control these risks, and to monitor the effectiveness of the controls.
- FDA/CDRH "General Principles of Software Validation; Final Guidance for Industry and FDA Staff." Issued January 11, 2002: This guidance outlines the FDA's current thinking on general principles of software validation for medical devices.
- ES 60601-1:2005/(R)2012 and A1:2012, C1: 2009/(R)2012 and A2:2010/(R)2012. Medical electrical equipment - Part 1: General requirements for basic safety and essential performance: This standard addresses the basic safety and essential performance requirements for medical electrical equipment.
The conclusion states: "Based on the verification activities performed, the AMICUS Separator System modified with software 6.0 provides a device system that is substantially equivalent to the currently marketed AMICUS Separator System." This indicates that the software enhancements were verified to perform as intended and not introduce new safety or performance concerns, thus maintaining substantial equivalence to the predicate device.
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(28 days)
Fresenius Kabi AG
The CATSmart System by Fresenius Kabi is an autotransfusion device indicated for the processing of autologous shed blood collected intraoperatively and postoperatively to obtain washed red blood cells for reinfusion. Additionally, it can be used for perioperative separation of blood into Packed Red Cells (PRC), Plasma (PLS) and Platelet Rich Plasma (PRP).
The Fresenius Kabi CATSmart device is an intraoperative autotransfusion system for intra- and/or postoperative processing of blood lost through surgery or trauma.
The CATSmart device operates on the principle of a continuous flow centrifuge, comparable to continuous systems for hemapheresis which, for decades, have been widely used in blood banks.
In a typical CATSmart procedure, the shed blood, which is anticoagulated and collected in a sterile reservoir, is processed in a continuous washing process to obtain washed packed red cells for reinfusion to the patient. During this process all plasmatic and non-erythrocytic cellular components of the collected blood, and thus activated coagulation factors, products of fibrinolysis and cell trauma as well as the anticoagulant are removed. The packed red cells are collected in a reinfusion bag from which they can be reinfused to the patient via a transfusion set when needed.
In the Plasma Sequestration (PSQ) procedure, the patient's blood is separated into packed red cells (PRCs), plasma (PLS) and Platelet Rich Plasma (PRP). The principle of separation during plasma sequestration is the same as it is for autotransfusion i.e. physical separation of cellular components in the centrifugal field based on the differences in density and particle size.
The system includes disposable sets and accessories previously cleared by FDA.
The provided text describes updates to an autotransfusion device, the Fresenius Kabi CATSmart, specifically focusing on the addition of two new wash factors. The document, a 510(k) summary, aims to demonstrate substantial equivalence to a previously cleared version of the same device (predicate device K180831).
Here's an analysis of the acceptance criteria and the study that proves the device meets them, based only on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria | Reported Device Performance |
---|---|
Performance of two additional wash factors | Results passed the acceptance criteria (tested in vitro in comparison to existing wash factors). |
Software changes did not impact other functions | Full system verification testing confirmed the changes did not impact other functional areas of the device. |
2. Sample size used for the test set and the data provenance
The text states that the performance of the two additional wash factors was tested by "in vitro studies." No specific sample size (e.g., number of blood samples, runs) is provided for these in vitro studies. 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
The document makes no mention of experts being used to establish ground truth for the test set. The evaluation relies on in vitro studies and system verification, which typically involve laboratory measurements against established standards for blood processing performance.
4. Adjudication method for the test set
No adjudication method is mentioned, as the evaluation is based on in vitro measurements and system verification, not on human interpretation or diagnosis 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
The device described is an autotransfusion apparatus, not an AI-assisted diagnostic imaging device that would involve human readers. Therefore, an MRMC comparative effectiveness study involving human readers and AI assistance is not applicable and was not performed.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
The device itself is an automated system. The "in vitro studies" and "software verification" described are inherently standalone assessments of the device's functionality without human intervention in the processing itself, only in setting up and monitoring the tests.
7. The type of ground truth used
The ground truth for the performance of the wash factors would be based on laboratory measurements of parameters such as the purity of washed red blood cells, removal of plasma and cellular components, and retention of red blood cells. These measurements would be compared against established scientific and regulatory standards for autotransfusion devices. For the software changes, the ground truth would be defined by the expected functional behavior of the device as per its design specifications.
8. The sample size for the training set
The document does not describe a "training set" in the context of an AI or machine learning algorithm. The device is an automated blood processing system, not a learning algorithm. Therefore, this question is not applicable.
9. How the ground truth for the training set was established
As there is no training set mentioned for this device, this question is not applicable. The device's functionality is based on its engineering design and validated through performance testing against pre-defined specifications.
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(255 days)
Fresenius Kabi AG
The CATSmart System by Fresenius Kabi is an autotransfusion device indicated for the processing of autologous shed blood collected intraoperatively and postoperatively to obtain washed packed red blood cells for reinfusion. Additionally, it can be used for perioperative separation of blood into Packed Red Cells (PRC), Plasma (PLS) and Platelet Rich Plasma (PRP).
The Fresenius Kabi CATSmart device is an intraoperative autotransfusion system for intra- and/or postoperative processing of blood lost through surgery or trauma. This version of CATSmart is also capable of perioperative separation of blood into PRP and PLS. The CATSmart device operates on the principle of a continuous flow centrifuge, comparable to continuous systems for hemapheresis which for decades, have been widely used in blood banks. In a typical CATSmart procedure, the shed blood, which is anticoagulated and collected in a sterile reservoir, is processed in a continuous washing process to obtain washed packed red cells for reinfusion to the patient. During this process all plasmatic and non-erythrocytic cellular components of the collected blood, and thus activated coagulation factors, products of fibrinolysis and cell trauma as well as the anticoagulant are removed. The packed red cells are collected in a reinfusion bag from which they can be reinfused to the patient via a transfusion set when needed. In the Plasma Sequestration (PSQ) procedure, the patient's blood is separated into packed red cells (PRCs), plasma (PLS) and platelet rich plasma (PRP). The principle of separation during plasma sequestration is the same as it is for autotransfusion i.e. physical separation of cellular components in the centrifugal field based on the differences in density and particle size. There is no change to system hardware or disposable sets described previously in K160735. The system includes the disposables AT1. AT3. ATS. ATY. ATO. ATR40 and ATR120. ATV-70 and ATV-180, ATF40 and ATF120. An ATV-F140 disposable set has been created (Class I 510(k) exempt). Also, PSQ disposable cleared under K971274 has also been qualified for use with the CATSmart System for the PSQ procedure. An additional wash program has been developed and added to the software to manage the PSO procedure.
The provided text describes the 510(k) summary for the Fresenius Kabi CATSmart Autotransfusion System, but it does not contain a detailed study section with acceptance criteria and device performance information.
Based on the available text, here's what can be inferred and what information is missing:
1. Table of acceptance criteria and the reported device performance:
This information is not explicitly stated in the provided text. The text mentions "in vitro blood quality studies in direct comparison to the predicate device C.A.T.S." and that "the validation tests passed for the new PSQ wash program on the CATSmart device with the PSQ set and AT3 tubing set." However, it does not detail the specific acceptance criteria (e.g., target ranges for red cell recovery, platelet removal, etc.) or the quantitative results from these studies.
2. Sample size used for the test set and the data provenance:
This information is not provided. The text only mentions "in vitro blood quality studies."
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
This information is not provided. Given that this is an autotransfusion device primarily processing blood, the "ground truth" would likely be laboratory measurements of blood component quality, not expert consensus on images or diagnoses.
4. Adjudication method for the test set:
This information is not applicable/provided. Adjudication methods like 2+1 or 3+1 typically refer to expert review processes for qualitative data (e.g., imaging interpretation), which is not the primary focus for validating an autotransfusion device.
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. An MRMC study is relevant for AI-powered diagnostic devices that assist human readers. The CATSmart system is an autotransfusion apparatus, not a diagnostic AI device.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
This is not applicable. The CATSmart system itself is a device that processes blood, not an algorithm that performs a standalone diagnostic or interpretive function.
7. The type of ground truth used:
Based on the context of "in vitro blood quality studies," the ground truth likely involved laboratory measurements of various blood parameters (e.g., hematocrit, red cell recovery percentage, plasma volume, platelet count, etc.) obtained through standard analytical techniques.
8. The sample size for the training set:
This information is not provided. The device uses a continuous flow centrifuge principle, and typically such devices are validated through engineering and in vitro performance studies, rather than "training" on a dataset in the way a machine learning algorithm would be. The "new PSQ wash program" implies software, but the document does not specify if it involves machine learning.
9. How the ground truth for the training set was established:
This information is not provided and is likely not applicable in the context of this device as it's not a machine learning-based system that requires a "training set" in the conventional sense. The "ground truth" for evaluating the performance of the wash program would be established through laboratory analysis of the processed blood.
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(183 days)
FRESENIUS KABI AG
The CATSmart (Continuous Autotransfusion System) device by Fresenius is an autotransfusion device indicated for the processing of autologous shed blood collected intraoperatively to obtain washed packed red blood cells for reinfusion.
The Fresenius Kabi CATSmart device is an intraoperative autotransfusion system for intraand/or postoperative processing of blood lost through surgery or trauma. The CATSmart device operates on the principle of a continuous flow centrifyge, comparable to continuous systems for hemapheresis which, for decades, have been widely used in blood banks. The shed blood, which is anticoagulated and collected in a sterile reservoir, is processed in a continuous washing process to obtain washed packed red cells for reinfusion to the patient. During this process all plasmatic and non-erythrocytic cellular components of the collected blood, and thus activated coagulation factors, products of fibrinolysis and cell trauma as well as the anticoagulant are removed. The packed red cells are collected in a reinfusion bag from which they can be reinfused to the patient via a transfusion set when needed.
This document describes the CATSmart (Continuous Autotransfusion System) device and its substantial equivalence to its predicate device, C.A.T.S., as per the FDA 510(k) submission. Below is the requested information regarding acceptance criteria and the supporting study:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly present a table of acceptance criteria with numerical targets. Instead, it states that "All three wash programs (emergency wash program, low volume wash, smart wash) were tested. Overall it was judged that all validation tests were passed for all wash programs on the CATSmart device with the AT3 tubing set. A separate in vitro evaluation demonstrated that fat and heparin were almost completely removed from the processed blood."
Based on this, the implied acceptance criteria are the successful execution and performance of the device's core functions (blood washing programs) to a similar or acceptable level as the predicate device, particularly concerning the removal of plasma, non-erythrocytic cellular components, activated coagulation factors, fibrinolysis products, cell trauma products, anticoagulant, fat, and heparin, all leading to washed packed red blood cells suitable for reinfusion.
Acceptance Criteria (Implied) | Reported Device Performance |
---|---|
Successful processing of autologous shed blood | "Overall it was judged that all validation tests were passed for all wash programs on the CATSmart device with the AT3 tubing set." The device processes anticoagulated shed blood in a continuous washing process to obtain washed packed red blood cells for reinfusion. |
Effective removal of plasmatic and non-erythrocytic components | "During this process all plasmatic and non-erythrocytic cellular components of the collected blood, and thus activated coagulation factors, products of fibrinolysis and cell trauma as well as the anticoagulant are removed." This statement implies successful removal of these components, meeting a performance standard judged to be acceptable. |
Effective removal of fat and heparin | "A separate in vitro evaluation demonstrated that fat and heparin were almost completely removed from the processed blood." This explicitly states the successful removal of these specific impurities. |
Electrical safety compliance | "The electrical safety of the CATSmart device was tested according to the general requirements for basic safety and essential performance directive of IEC 60601-1-2:2007." The successful completion of this testing implies compliance with these safety standards. |
Durability and resistance to vibration/shock | "Furthermore, vibration and shock resistance was tested as well as the durability." The successful completion of these tests implies the device meets internal durability and resistance standards. |
Performance comparable to predicate device | "The performance of the CATSmart device was tested by in vitro blood quality studies in direct comparison to the predicate device C.A.T.S." The context suggests that the CATSmart performed comparably to the predicate, leading to the conclusion of substantial equivalence. The main functions of CATSmart and the underlying methodology remained unchanged compared to its predecessors. The only functional difference is the monitoring of the hematocrit value for informational purposes, not diagnostic. Electrical safety, vibration, shock, and durability also tested. |
2. Sample Size Used for the Test Set and Data Provenance
The document does not explicitly state the specific sample size (e.g., number of blood samples or test runs) used for the in-vitro performance testing. It only mentions "in vitro blood quality studies."
There is no information about data provenance in terms of country of origin or whether it was retrospective or prospective. Given it was "in vitro blood quality studies," it would inherently be a prospective experimental setup.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications
This information is not provided in the document. The document states "Overall it was judged that all validation tests were passed," implying internal assessment. There is no mention of external experts or their qualifications for establishing ground truth for the in-vitro studies.
4. Adjudication Method
The document does not specify an adjudication method. The statement "Overall it was judged that all validation tests were passed" suggests an internal evaluation without detailing a formal adjudication process involving multiple parties.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No, an MRMC comparative effectiveness study was not conducted. The CATSmart device is an autotransfusion apparatus, not an image-reading or diagnostic device that would involve human readers. Its primary function is blood processing, and the "hematocrit monitoring function" is specifically noted as "only used to monitor the wash process for informational purposes and is not intended for diagnostic or quality control purpose." Therefore, there is no discussion of human reader improvement with or without AI assistance.
6. Standalone (Algorithm Only) Performance Study
The performance testing described is for the device as a whole, including its operational algorithms embedded in the software. The study focuses on the device's ability to process blood and remove impurities. While the document mentions a software update that includes the hematocrit function and touch screen control, it doesn't separate the "algorithm only" performance from the integrated system performance. However, since it's an automated system, its performance inherently represents an "algorithm only" or "device only" performance in its operational context. There is no human-in-the-loop interaction for the core blood processing function itself.
7. Type of Ground Truth Used
The ground truth for the device's performance (i.e., effective blood washing, removal of impurities) would have been established through analytical testing of the processed blood samples. This would likely involve laboratory measurements of various blood components, contaminants (e.g., plasma proteins, anticoagulants, fat, heparin), and red blood cell recovery, probably using established clinical laboratory standards and methods. The document mentions "in vitro blood quality studies," which supports this interpretation.
8. Sample Size for the Training Set
The document does not mention any "training set" or machine learning model development in the context of device performance testing. The main functional difference, the hematocrit monitoring, is an "additional technical feature" and its values are explicitly stated as "not a substitute for the hematocrit check on the product before it is reinfused... The sensors are not calibrated measuring instruments." This suggests that any algorithms related to hematocrit monitoring are rather simple estimations for informational display and are not based on complex machine learning requiring a "training set" in the typical sense. The device's core blood washing function is based on a continuous flow centrifuge, a well-established physical principle, rather than a learned algorithm needing an extensive training set.
9. How the Ground Truth for the Training Set Was Established
As no training set is mentioned or implied for the core functions or the hematocrit monitoring (which is for informational purposes only), the establishment of ground truth for a training set is not applicable to the information provided.
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