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510(k) Data Aggregation
(107 days)
The grantAdler Rhapsody Access Port and Catheter is indicated for any patient requiring reliable repeated access of the vascular system for delivery of medications, nutritional supplementation, fluids, blood, blood products or the sampling of blood. The Rhapsody Port and Catheter are safe to use in an MRI environment.
grantAdler Ports and Catheters are supplied as sterile devices, and are intended for single patient use only. The ports are available as a single model and are manufactured of the highest quality titanium. They also incorporate a durable high compression self-sealing silicone septum. Catheter materials include flexible, non-compressible, and reinforced silicone. Suture sites are incorporated into the port base to facilitate anchorage to the underlying fascia. The grantAdler port line is indicated for any patient requiring reliable repeated access of the vascular system for delivery of medications, nutritional supplementation, fluids, blood, blood products, or the sampling of blood.
The provided text is for a 510(k) summary for a medical device called "Rhapsody MRI," which is an implanted port and catheter. This document focuses on demonstrating substantial equivalence to a predicate device, particularly regarding its MRI compatibility. Therefore, the "acceptance criteria" and "study" described are related to verifying this compatibility, not the performance of an AI algorithm.
Based on the provided text, here's a breakdown of the requested information, interpreted in the context of a medical device submission rather than an AI/ML study:
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria | Reported Device Performance |
|---|---|
| MRI Compatibility | The Rhapsody MRI meets all established acceptance criteria for performance testing and design verification testing related to MRI compatibility. |
| Substantial Equivalence | The product is identical to the GrantAdler Rhapsody Access Port with different labeling and testing performed to demonstrate its substantial equivalence as an MRI Compatible Device. |
| Intended Use (General) | Indicated for reliable repeated access of the vascular system for fluid/medication delivery and blood sampling. Safe to use in an MRI environment. |
2. Sample Size Used for the Test Set and Data Provenance
The document does not explicitly state a "sample size" for a specific test set in the way one would for an AI/ML study (e.g., number of images or patients). Instead, it refers to "performance testing and design verification testing" related to MRI compatibility. This likely involved a set of physical devices being subjected to various MRI conditions to assess their safety and function.
- Sample Size: Not specified in terms of numerical units like "patients" or "cases." The context suggests a set of physical devices tested.
- Data Provenance: Not specified, but likely refers to internal testing conducted by the manufacturer (GrantAdler Corporation). It is not retrospective or prospective in the clinical study sense; rather, it's product testing.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
This concept of "experts establishing ground truth" is not directly applicable in the context of this device's submission. The "ground truth" here is the physical interaction of the device with an MRI environment, and its safe and effective function. This would be established through engineering and electromagnetic compatibility testing standards, not expert subjective review.
4. Adjudication Method for the Test Set
Not applicable. Adjudication methods like 2+1 or 3+1 are used for human review of data, typically in diagnostic imaging studies where there's subjectivity. Here, the assessment is based on objective measurements and adherence to engineering standards for MRI compatibility.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No. This is a medical device approval, not an AI/ML algorithm submission. An MRMC study is designed to evaluate the impact of an AI algorithm on human reader performance, which is not relevant for this device.
6. Standalone Performance Study (Algorithm Only)
No. This refers to a physical medical device, not an algorithm.
7. Type of Ground Truth Used
The "ground truth" for this device's acceptance is based on:
- Physical and electronic measurements: Demonstrating the device's behavior in an MRI field (e.g., heating, artifact generation, displacement).
- Adherence to recognized standards: Likely ISO, ASTM, or similar standards for MRI compatibility of implanted devices.
- Functional performance: Ensuring the port and catheter continue to function as intended after exposure to MRI.
8. Sample Size for the Training Set
Not applicable. This device is not an AI/ML algorithm that requires a "training set."
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there is no training set for an AI/ML algorithm.
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(133 days)
The Grant Adler Rhapsody port line is intended to facilitate reliable and repeated acces of the vascular system for delivery of medications, nutritional supplementation, fluids, blood, blood products or the sampling of blood. Access is performed by percutaneous needle insertion, using only non-coring, Huber needles. When used with a power injectable needle, Rhapsody CT is indicated for power injection of contrast media. For power injection of contrast media, the maxum recommended infusion rate is 5 ml/s with a 19 or 20 gauge non-coring power injectable needle and 2 ml/s with 22 gauge non-coring power injectable needle. The Rhapsody CT has been tested and is conditionally safe to use in an MRI environment up to 3T. The Port is normally included in a Convenience Kit which will be used for the procedure. The GrantAdler Convenience Kit includes all cleared or exempt devices.
The Rhapsody CT is supplied as a sterile device, and is intended for single patient use only. The port is available as a single model and is manufactured of the highest quality titanium. It also incorporates a durable high compression self-sealing silicone septum. Catheter materials include flexible, non-compressible, and reinforced silicone. The Port is normally inclused in a Convenience Kit which will be used for the procedure. The GrantAdler Convenience Kit includes all cleared or exempt devices.
Let's break down the information provided in the K081889 510(k) summary regarding the GrantAdler Rhapsody CT.
It's important to note that this 510(k) submission is for a medical device (implantable port and catheter), not an AI/ML algorithm. Therefore, many of the typical acceptance criteria and study designs associated with AI/ML devices (like sample sizes for test/training sets, ground truth establishment methods, expert adjudication, MRMC studies, and standalone AI performance) are not applicable here.
The "acceptance criteria" for this type of device are primarily compliance with design specifications, material properties, and functional performance, often benchmarked against predicate devices and relevant industry standards.
Here's an analysis based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The provided table in the document is a "Grant Adler Rhapsody CT Table of Comparison," which compares the Rhapsody CT device to its predicate devices (Grant Adler Rhapsody K043178 and Bard Power Port K060812). This table effectively serves as a summary of the device's performance against relevant design and functional criteria, demonstrating substantial equivalence to predicates.
| Acceptance Criteria (Test Description) | Reported Device Performance (Rhapsody CT) | Justification/Comparison to Predicates |
|---|---|---|
| Indications for Use | Power Injection | Has Power Injection indication, similar to Bard Power Port K060812. Expands on previous Rhapsody (K043178) which didn't have this. |
| Labeling | Equivalent | Equivalent to K043178 and K060812. |
| Target Population | Equivalent | Equivalent to K043178 and K060812. |
| Hospital Use | Yes | Consistent with K043178 and K060812. |
| Design | Port with Septum | Equivalent to K043178 and K060812. |
| Materials, Port | Titanium | Consistent with K043178 and K060812. |
| Materials, Septum | Silicone NuSil MED-4780 | Consistent with K043178 and comparable to K060812 (general Silicone). |
| Materials, Catheter | Silicone NuSil MED-4780 | Consistent with K043178 and comparable to K060812 (general Silicone). |
| Dimensional | 28.3mm x 12.7mm | Different from K060812 (32mm x 12.8mm) but stated as "Identical" to K043178. Dimensions are typically evaluated for functional equivalence. |
| Catheter to Port Connection | Double Barbed Fitting | Consistent with K043178, and a variation from K060812 (Barbed Fitting), implying a design difference but functionally equivalent for purpose. |
| Septum Puncture | Needle | Consistent with K043178 and K060812. |
| Port Leak Testing | No Leaks | Equivalent to K043178 and K060812. This would be a critical functional acceptance criterion, meaning the device must not leak under tested conditions. |
| Sterilization Information | ETO (Ethylene Oxide) | Consistent with K043178 and K060812. |
| Biocompatibility Assessment | Pass | Equivalent to K043178 and K060812. This is a crucial safety acceptance criterion, indicating the materials are safe for implantation. |
| Catheter | 7 Fr. up to 52cm | Different from K060812 (8 Fr. up to 45cm) but stated as "Identical" to K043178. Specific dimensions and French sizes are design parameters. |
| Max Power Injection Flow | 5ml/s 19 AWG | Directly matches K060812 for 19 AWG, and new for this product line. Also specifies 2 ml/s with 22 gauge non-coring power injectable needle in the Intended Use. |
| Max PI Pressure | Less than 300 psi | Directly matches K060812. This is a critical functional safety acceptance criterion. |
| MRI Safe | Yes | New feature compared to K043178 ("510k in process") and K060812 ("Unknown"). This required specific testing. |
2. Sample Size Used for the Test Set and Data Provenance
For a medical device like this, there isn't a traditional "test set" with "data provenance" in the way one would describe an AI/ML algorithm. Instead, verification and validation testing is performed on the physical device.
- Sample Size: The document does not specify the exact number of physical devices tested for each criterion (e.g., how many ports were tested for leaks, or how many underwent material biocompatibility assessments). This information is typically detailed in the full testing reports submitted to the FDA, but not usually in the 510(k) summary. We can infer that enough samples were tested to provide statistical confidence for the claimed performance.
- Data Provenance: Not applicable in the context of AI/ML data. The "data" here comes from laboratory testing of manufactured devices.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
This concept is not applicable to this device. There is no "ground truth" established by experts in the context of image interpretation or diagnosis. Instead, the performance criteria (e.g., "no leaks," "pass biocompatibility," "5 ml/s flow rate at <300 psi") are established through engineering specifications, regulatory standards, and comparison to predicate devices, and then verified through objective physical and chemical testing.
4. Adjudication Method
Not applicable to this device. Adjudication methods like 2+1 or 3+1 are used for resolving disagreements among human readers/experts in diagnostic tasks, which is not relevant for an implantable port.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
Not applicable. MRMC studies are used to evaluate the impact of a diagnostic aid (like AI) on human reader performance. This device is an implantable port, not a diagnostic aid.
6. Standalone (Algorithm Only) Performance
Not applicable. This is a physical medical device, not a software algorithm.
7. The Type of Ground Truth Used
Not applicable in the AI/ML sense. The "ground truth" for this device's performance is established by:
- Engineering Specifications: Design limits for pressure, flow rates, dimensions.
- Regulatory Standards: ISO standards for biocompatibility (e.g., ISO 10993), sterilization, and other device properties.
- Predicate Device Performance: The performance of legally marketed predicate devices forms a baseline against which the new device is compared to establish substantial equivalence.
- Objective Physical and Chemical Testing: Lab tests demonstrating "no leaks," "pass biocompatibility," "max pressure/flow capabilities," and "MRI safety."
8. Sample Size for the Training Set
Not applicable. This device is not an AI/ML algorithm that requires a training set.
9. How the Ground Truth for the Training Set Was Established
Not applicable.
In summary, the K081889 document is a 510(k) premarket notification for a physical medical device (an implantable port and catheter). The "acceptance criteria" and "study" described are focused on demonstrating the device's safety and effectiveness through engineering design, material compatibility, functional performance testing, and substantial equivalence to predicate devices, rather than the statistical performance metrics typical for AI/ML diagnostic software.
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