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510(k) Data Aggregation

    K Number
    K230718
    Manufacturer
    Date Cleared
    2023-06-15

    (92 days)

    Product Code
    Regulation Number
    880.5725
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Gilero, LLC

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

    The UTC 3 ml Medication Cartridge is intended for use in hospital and outpatient care environments with the CADD-MS® 3 Ambulatory Infusion Pump for subcutaneous infusion of medication in adults.

    Device Description

    The UTC 3 mL Cartridge (UTC Cartridge) is a is a sterile, single-use cartridge intended for use with the Smiths Medical MD, Inc. CADD-MS®3 Ambulatory Infusion Pump. The UTC Cartridge is for use in hospitals and outpatient care environments.

    The UTC 3 mL Medication Cartridge consists of 3 primary components: a 3mL cartridge that looks like a small syringe, 22G x 0.5 in. needle, and protective cap.

    The distal end of the device has a male luer lock used to attach the needle and withdraw medication from a vial. Once filled, the plunger is removed, needle is discarded, and protective cap is place on the luer until the cartridge is inserted into the CADD-MS 3 Infusion Pump and secured into place with the infusion pump's lid. The protective cap can then be discarded and the male luer can then be attached to the female luer of an infusion set.

    AI/ML Overview

    The provided FDA 510(k) summary for the UTC 3mL Medication Cartridge (K230718) does not describe an AI/ML-driven medical device, nor does it detail acceptance criteria related to algorithmic performance metrics (e.g., accuracy, sensitivity, specificity) for such a device. Instead, it concerns a physical medical device (a medication cartridge) and its substantial equivalence to a predicate device based on material, design, and performance testing for sterility, biocompatibility, and physical properties.

    Therefore, many of the requested points regarding AI/ML device testing (e.g., sample size for test set, number of experts, MRMC studies, standalone performance, training set details) are not applicable to this document.

    However, I can extract the performance data and acceptance criteria relevant to this specific device, as described in the 510(k) summary, and present them in a structured way that aligns with your request's format, even if the "performance" is mechanical/biological rather than algorithmic.


    Here's the information based on the provided document, interpreting "acceptance criteria" and "device performance" in the context of a physical medical device clearance:

    Device: UTC 3mL Medication Cartridge (K230718)
    Type of Device: Infusion Pump Syringe (Accessory to an Infusion Pump)
    Regulatory Class: Class II

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria for this device are primarily demonstrated through conformance to recognized international standards and specific performance tests. The summary states that the tests "demonstrated to be in conformance with" or "met the USP acceptance criteria," indicating successful performance against these standards.

    Acceptance Criteria CategorySpecific Test/StandardAcceptance Criteria (Implicit from Compliance)Reported Device Performance
    Performance TestingISO 7886-1:2017Conformance to "Syringes for manual use"Demonstrated conformance.
    ISO 7886-2:2020-04Conformance to "Syringes for use with power-driven syringe pumps"Demonstrated conformance.
    ISO 594-1:1986Conformance to "Conical fitting with 6% (Luer) taper for syringes, needles and certain other medical equipment - Part 1: General requirements"Demonstrated conformance.
    ISO 594-2:1998Conformance to "Conical fitting"Demonstrated conformance.
    BiocompatibilityISO 10993-1 seriesMeets established biological safety parameters for "externally communicating, prolonged exposure device that indirectly contacts the blood path."All required tests completed successfully (Cytotoxicity, Irritation, Sensitization, Acute Systemic Toxicity, Pyrogenicity, Subacute Toxicity, Hemocompatibility).
    Particulate MatterUSPMeets "Particulate Matter in Injection" acceptance criteria.Met USP acceptance criteria.
    SterilizationISO 113135:2014Validation via Overkill Approach (e.g., Half-Cycle method) and pyrogen test (Bacterial Endotoxin testing).Sterilized with Ethylene Oxide as per standard, validation successful.
    Packaging/Shelf-LifeASTM D4169-16Packaging integrity after conditioning and simulated transportation deemed acceptable for product protection and sterility maintenance.All packaging properties "deemed acceptable."
    Sterile Barrier PackagingASTM 1929Conformance to Dye Penetration Test.Performed, accepted.
    ASTM F1886/F1886M-16Conformance to Visual Inspection Test.Performed, accepted.
    ASTM F2069-11Conformance to Bubble Leak Test.Performed, accepted.
    Shelf-LifeASTM F1980-16Validation of 1-year shelf-life via accelerated aging.1-year shelf-life validated.

    2. Sample Size Used for the Test Set and Data Provenance

    The document does not explicitly state the specific sample sizes for each of the performance and biocompatibility tests. It only lists the standards followed. For medical device testing, sample sizes are typically defined by the specific test method within the referenced standards (e.g., ISO, ASTM, USP).

    The data provenance is implied to be from laboratory testing conducted as part of the device development and regulatory submission process. There is no mention of country of origin for the data or whether it was retrospective or prospective in the sense of clinical study data. These are bench/lab tests.

    3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications

    This concept is not applicable here as the "ground truth" for this physical device is established by objective engineering and biological test standards (e.g., whether a Luer taper fits correctly, whether a material is cytotoxic, whether packaging maintains sterility) rather than expert consensus on diagnostic images.

    4. Adjudication Method for the Test Set

    Not applicable. Adjudication methods like "2+1" or "3+1" are typical for clinical data review, especially in imaging studies, where expert disagreement needs resolution. For physical device performance tests, the outcome is typically an objective pass/fail against a standard.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and Effect Size

    Not applicable. This type of study assesses how human readers' performance (e.g., diagnostic accuracy) changes with or without AI assistance. The UTC 3mL Medication Cartridge is a physical component, not an AI/ML algorithm used for interpretation.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

    Not applicable, as this is not an AI/ML algorithm.

    7. The Type of Ground Truth Used

    The "ground truth" for this device is based on objective engineering and biological test standards and measurements. This includes:

    • Physical dimensions and tolerances (e.g., Luer taper).
    • Material properties (e.g., polypropylene).
    • Biological responses (e.g., cytotoxicity, irritation, hemocompatibility through ISO 10993 series).
    • Sterility assurance (e.g., Bacterial Endotoxin testing, ethylene oxide validation).
    • Particulate assessment (USP ).
    • Packaging integrity and shelf-life stability.

    8. The Sample Size for the Training Set

    Not applicable, as this is not an AI/ML device 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 this type of device.

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    K Number
    K201936
    Manufacturer
    Date Cleared
    2021-05-06

    (297 days)

    Product Code
    Regulation Number
    880.5025
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Gilero, LLC

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

    The SmartSite™ Bag is an empty container used for administration of intravenous solutions to the patient using an intravascular administration set. Medication transfer in and out of the container is done using aseptic technique.

    Device Description

    The SmartSite™ Bag is a single-use, empty IV container, which will be available in 100mL, 250mL, and 500mL product sizes. The SmartSite™ Bag is labeled as sterile fluid path, and contains both an add port and a spike port. The add port facilitates aseptic transfer of medication(s) into or out of the bag. The spike port contains a twist-off protective seal. Either the add port or the spike port can be connected to an intravenous (IV) administration set for medication delivery to the patient. The add port may be repeatedly accessed in accordance with the Directions for Use (DFU). The SmartSite™ Bag may be used for up to 24 hours after the initial access of the add port, consistent with prescribing information for the medications used.

    AI/ML Overview

    The provided text describes the 510(k) submission for the SmartSite Bag, an empty IV container. It outlines the device's indications for use, comparison to a predicate device, and non-clinical tests conducted to demonstrate substantial equivalence. However, the document does NOT contain a formal "study" proving the device meets acceptance criteria in the sense of a clinical trial or a structured performance study with defined acceptance criteria and reported numerical performance measures like sensitivity, specificity, or accuracy for a diagnostic device.

    Instead, the document details various engineering and biocompatibility tests designed to ensure the SmartSite Bag functions as intended and is safe for its stated use, thereby demonstrating equivalence to the predicate device. The acceptance criteria are implicitly met by passing these tests and standards.

    Here's a breakdown of the information that is present, organized as requested where applicable, and noting where the requested information is not available in the given text:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not present explicit acceptance criteria in a table format with corresponding numerical performance for the device for a specific clinical outcome. Instead, it lists various non-clinical tests and standards the device was evaluated against, implying that meeting these standards constitutes "acceptance."

    Test CategorySpecific Test/StandardAcceptance Criteria (Implied by standard compliance)Reported Device Performance
    BiocompatibilityISO 10993-1 (Evaluation and testing within a risk management process)Acceptable biological risk demonstrated by meeting ISO 10993 requirements for contact characterization."Acceptable biological risk established by demonstrating that the device meets ISO 10993."
    - Extractable and Leachables testing and toxicological risk evaluationCompliance with toxicological risk assessment.Passed
    - CytotoxicityNon-cytotoxic.Passed
    - SensitizationNon-sensitizing.Passed
    - Irritation or Intracutaneous ReactivityNon-irritating.Passed
    - Acute Systemic ToxicityNo acute systemic toxic effects.Passed
    - Subacute/Subchronic ToxicityNo subacute/subchronic toxic effects.Passed
    - Material-Mediated PyrogenicityNon-pyrogenic related to materials.Passed
    - HemocompatibilityBiocompatible with blood.Passed
    Bacterial EndotoxinBacterial Endotoxin testingEndotoxin requirements ofMeets particulate requirements.
    Additional Testing- Maintenance of performance requirements after infusate exposureMaintained performance after exposure.Passed
    - Luer connection performanceAcceptable Luer connection performance.Passed
    - Bag integrity (leakage)No leakage.Passed
    - Performance after simulated shippingMaintained performance after simulated shipping.Passed
    - Shelf lifeMaintained performance for specified shelf life.Passed
    - SmartSite Microbial Ingress TestingNo microbial ingress.Passed

    2. Sample size used for the test set and the data provenance
    The document does not provide specific sample sizes for each test in a numerical format (e.g., "n=X bags"). It refers to "testing" performed. The data provenance is internal to Gilero, LLC as it refers to non-clinical laboratory testing. There is no mention of country of origin of data or whether it was retrospective or prospective in a clinical sense, as these are non-clinical engineering tests.

    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 and not available in the document. The tests described are non-clinical, laboratory-based evaluations against established standards (e.g., ISO, USP), not assessments requiring expert "ground truth" establishment in a diagnostic context.

    4. Adjudication method for the test set
    Not applicable. There is no mention of an adjudication method as the tests are objective, laboratory-based measurements against defined standards.

    5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
    Not applicable. This is a medical device (IV bag), not an AI/diagnostic software.

    6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
    Not applicable. This is a medical device (IV bag), not an algorithm or AI.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
    The "ground truth" for the non-clinical tests is based on established industry standards and specifications (e.g., ISO 10993, USP , ISO 15747, and internal performance specifications for factors like leakage, Luer connection, and shelf life).

    8. The sample size for the training set
    Not applicable. This is a traditional medical device, not an AI/machine learning product that requires a training set.

    9. How the ground truth for the training set was established
    Not applicable. There is no training set for this type of device.

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