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510(k) Data Aggregation

    K Number
    K233428
    Date Cleared
    2023-11-03

    (23 days)

    Product Code
    Regulation Number
    878.4780
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Guangzhou Easycess Medical Co., Ltd

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

    The Easycess Aspiration Pump is intended for general suction use in hospitals or clinics.

    Device Description

    The Easycess Aspiration Pump is mainly composed of negative pressure suction pump host and Easycess Canister(Model: DC1000). The Easycess Aspiration Pump is designed to provide general suction for use in hospitals or clinics. The Aspiration Pump operates using AC power and is designed to be portable if needed. The Aspiration Pump provides vacuum of up to 29 inHg. The pump is available in 110V and 220Vac versions. The pump is used with the available 1000ml canister / tubing set. The Easycess Aspiration Pump is provided in non-sterile; it is reusable and should be managed as a prescription device. The Easycess Canister is for single use only.

    AI/ML Overview

    The Easycess Aspiration Pump is a medical device intended for general suction use in hospitals or clinics. The study provided in the document focuses on bench testing to demonstrate its substantial equivalence to a predicate device, the Penumbra Pump MAX (K122756).

    Here's an analysis of the acceptance criteria and study details:

    1. Table of Acceptance Criteria and Reported Device Performance

    TestAcceptance Criteria (Specification)Reported Device Performance (Conclusion)
    AppearanceThe surface of the product is clear, the shell component has no burr sharp edge, the assembly splicing fixed firmly, no obvious gap, loose.The appearance is suitable for intended clinical use. The subject device is equivalent to the predicate device.
    Vacuum levels10s vacuum levels ≥60.0Kpa(18 inHg)The vacuum level is suitable for intended clinical use and met requirements of ISO 10079-1 and 10079-4. The subject device is equivalent to the predicate device.
    Free air flowsFree air flows ≥20L/minThe free air flow is suitable for intended clinical use and met requirements of ISO 10079-1 and 10079-4. The subject device is equivalent to the predicate device.
    Final vacuum-98.2Kpa±7 Kpa(-29 inHg±2inHg)The final vacuum is suitable for intended clinical use. The subject device is equivalent to the predicate device.
    Vacuum adjustment range-98.2Kpa(-29 inHg)The vacuum adjustment range is suitable for intended clinical use. The subject device is equivalent to the predicate device.
    Liquid levelClearly show the level of contents.The liquid level is suitable for intended clinical use and met requirements of ISO 10079-1 and 10079-4. The subject device is equivalent to the predicate device.
    VolumeVolume ≥1LThe volume is suitable for intended clinical use and met requirements of ISO 10079-1 and 10079-4. The subject device is equivalent to the predicate device.
    StrengthCollection containers shall not implode, crack or permanently deform after 5 minutes of continuous pumping at atmospheric pressure of -95 Kpa.The strength is suitable for intended clinical use and met requirements of ISO 10079-1 and 10079-4. The subject device is equivalent to the predicate device.
    Vacuum level indicatorsThe full scale of analogue vacuum level indicators shall be ≤ 60 inHg. Analog displays shall have graduations ≥ 2mm apart with each graduation representing ≤ 5% of the full-scale value.The vacuum level indicators are suitable for intended clinical use and met requirements of ISO 10079-1 and 10079-4. The subject device is equivalent to the predicate device.
    Vacuum level indicators accuracyDigital displays shall indicate the vacuum level at intervals ≤ 5% of the full-scale value.The vacuum level indicators accuracy is suitable for intended clinical use and met requirements of ISO 10079-1 and 10079-4. The subject device is equivalent to the predicate device.
    Operating positionWhen placed at any position on an incline at an Angle of (10±1) °with the horizontal plane, the equipment meets the requirements for use.The operating position is suitable for intended clinical use and met requirements of ISO 10079-1 and 10079-4. The subject device is equivalent to the predicate device.
    Overfill protection devicesOverfill protection devices shall not activate until at least 90% of the indicated maximum capacity of the collection container has been reached. When an overfill protection devices is activated, suction shall cease and prevent > 5ml of fluid from passing downstream of the overfill protection device within 2min.The overfill protection devices are suitable for intended clinical use and met requirements of ISO 10079-1 and 10079-4. The subject device is equivalent to the predicate device.
    NoiseThe maximum A-weighted sound pressure level (steady or peak value) ≤70 dB(A).The noise is suitable for intended clinical use and met requirements of ISO 10079-1 and 10079-4. The subject device is equivalent to the predicate device.
    Pharyngeal suction equipmentSuction equipment intended for pharyngeal suction shall evacuate ≥200ml of simulated vomitus in not more than 10s.The pharyngeal suction equipment is suitable for intended clinical use and met requirements of ISO 10079-1 and 10079-4.
    Negative pressure values and flow performance requirements - Power interruptionThe interruption and restoration of the power supply of the suction device should not cause any danger, and the change of the negative pressure value and flow rate should not exceed ±10% of the set value. The same performance requirement applies if the original power supply is replaced by another power supply.The negative pressure values and flow performance requirements - Power interruption is suitable for intended clinical use and met requirements of ISO 10079-1. The subject device is equivalent to the predicate device.
    Simulated useThe pump could provide stable vacuum in accompany with compatible devices.Device performs as intended under simulated use conditions. The subject device is equivalent to the predicate device.
    ConnectionsWith the company's production of disposable suction pipe, and suitable for the vast majority of the market suction extension tube.The connections are suitable for intended clinical use and met requirements of ISO 10079-1 and 10079-4. The subject device is equivalent to the predicate device.
    Work cycleNon-continuous duty [ 45min( 97.8%) ON/ 1 min (2.2%) OFF ]The work cycle is suitable for intended clinical use. The subject device is equivalent to the predicate device.
    Vacuum feedback lampWhen the device runs to vacuum less than -85 Kpa, the vacuum feedback light will turn on.The negative pressure feedback lamp is suitable for intended clinical use.
    Electrical SafetyComply with IEC 60601-1:2020Comply with IEC 60601-1.
    Electromagnetic Compatibility (EMC)Comply with IEC 60601-1-2:2014+A1:2020Comply with IEC60601-1-2.

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

    The provided document describes bench testing, which typically does not involve patient data. The tests were performed on the Easycess Aspiration Pump itself to verify its physical and mechanical performance. Therefore, there is no specific "sample size" of patient data for a test set in the traditional sense, nor data provenance related to country of origin or retrospective/prospective collection as one would find in clinical studies.

    The testing was conducted according to the FDA special control guidance document: Guidance Document for Powered Suction Pump 510(k)s, and the ISO 10079-1:2022 Medical suction equipment - Part 1: Electrically powered suction equipment.

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

    There is no mention of experts or their qualifications being used to establish a ground truth. Since this was bench testing of a hardware device's performance characteristics, the "ground truth" was the objective measurement of the device against established engineering and safety standards (e.g., ISO, IEC, FDA guidance).

    4. Adjudication Method for the Test Set

    As there were no human readers or interpretations involved in establishing a ground truth for a test set (it was objective bench testing), there was no adjudication method applied.

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

    No, an MRMC comparative effectiveness study was not done. The study presented here is focused on the device's adherence to technical standards and its substantial equivalence based on bench testing.

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

    The Easycess Aspiration Pump is a hardware medical device; it is not an algorithm-based device or an AI system. Therefore, the concept of a "standalone" algorithm performance study is not applicable.

    7. The Type of Ground Truth Used

    For this device, the "ground truth" for the bench testing was established by objective engineering specifications, regulatory standards (ISO 10079-1:2022, IEC 60601-1, IEC 60601-1-2), and FDA guidance documents for powered suction pumps. These are physical and mechanical performance metrics rather than clinical outcomes or expert interpretations.

    8. The Sample Size for the Training Set

    As this is a hardware medical device and not an AI/ML algorithm, there is no concept of a "training set" for an algorithm.

    9. How the Ground Truth for the Training Set Was Established

    Again, since there is no training set, this question is not applicable.

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    K Number
    K213065
    Date Cleared
    2022-05-31

    (250 days)

    Product Code
    Regulation Number
    870.1250
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Guangzhou Easycess Medical Co., Ltd

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

    The Distal Access Catheter is indicated for general intravascular use, including the neuro and peripheral vasculature. It can be used to facilitate introduction of diagnostic agents or therapeutic devices. It is not intended for use in coronary arteries.

    Device Description

    The Distal Access Catheter consists of a catheter and accessories (hemostatic valve, introducer sheath, and a shaping mandrel). The catheter is a single-lumen, flexible catheter designed with coil and braid reinforcement. The distal segment is steamshapeable, and a hydrophilic coating is applied for navigation of the catheter through the vasculature. The radiopaque marker is located at the distal end of the catheter for visualization under fluoroscopy.

    The catheter body is constructed with a stainless-steel coil (less 2 cm of the catheter length) over the inner lumen liner comprised of polytetrafluoroethylene (PTFE). To provide additional shaft support, a stainless-steel wire braiding has been added over the stainless-steel coil from the proximal end to distal end. A platinum/iridium alloy radiopaque marker band is located at the distal tip of the catheter. An outer layer of varying durometers and lengths of polyamide (PA), polyether block amide (Pebax) and polyurethane (PU) covers the entire catheter body from proximal to distal end, respectively.

    A hub (PC) is attached to the proximal end of the catheter. A strain relief made from polyether block amide (Pebax) is placed at the proximal end of the catheter and distal end of the hub. The hub-strain relief provides for the kink resistance for the proximal end. A luer fitting on the catheter hub is used for the attachment of accessories.

    The outer surface of the catheter (distal 60 cm) is coated with a hydrophilic coating to reduce friction during navigation in the vasculature.

    A shaping mandrel (stainless steel, 80 mm in length) is provided with the catheter to be used by the physician for tip shaping. An introducer sheath (PTFE) is included to facilitate the introduction of the catheter into guide catheters during clinical use. A hemostatic valve is used to connect to the proximal section of the catheter.

    The Distal Access Catheter is provided sterile and for single use only. The catheter is placed in a dispenser tube (HDPE) and is placed on a packaging card (HDPE) that is provided in a sterile barrier PET/PE film and Tyvek pouch and placed in a carton box.

    AI/ML Overview

    This document describes the regulatory clearance for a medical device called a "Distal Access Catheter," not an AI/ML device. Therefore, the questions related to AI/ML device performance, such as sample size for test/training sets, expert ground truth, MRMC studies, and human-in-the-loop performance, are not applicable.

    The acceptance criteria and the study that proves the device meets them are based on bench testing (physical and mechanical properties) and biocompatibility testing.

    1. Table of Acceptance Criteria and Reported Device Performance

    Test TypeAcceptance Criteria (Specification)Reported Device Performance (Conclusion)
    Bench Testing
    Surface InspectionExternal surface free from extraneous matter, process, and surface defects that could cause trauma to vessels.The surface integrity is suitable for intended clinical use.
    Surface ContaminationFree from surface contaminants from uncured coating surface particulates > 0.02 mm², embedded particulates. Distal tip smooth and tapered. PTFE inner layer not delaminated.The surface integrity is suitable for intended clinical use.
    DimensionalMeet specified dimensional requirements (catheter OD, ID, effective length, distal tip length, total accessories length).The device met the dimensional and physical specifications.
    Distal TipSmooth, rounded, tapered, or similarly finished to minimize trauma to vessels.Distal tip is suitable for intended clinical use.
    RadiodetectabilityTip of the catheter visible under fluoroscopy.Device radiopacity is suitable for intended clinical use.
    Corrosion ResistanceMetallic components show no signs of corrosion.Corrosion resistance is suitable for intended clinical use and met requirements of ISO 10555-1.
    Peak Tensile Force6F Catheter: ≥15N for distal section and hub/catheter junction. 5F Catheter: ≥10N for distal section and hub/catheter junction.Peak tensile force is suitable for intended clinical use and met requirements of ISO 10555-1.
    Fluid LeakageNo liquid leakage from hub and catheter shaft at 46 psi for 30 seconds.Device integrity is suitable for intended clinical use and met requirements of ISO 10555-1.
    Air LeakageNo air leakage at hub into syringe when negative pressure was applied for 15 seconds.Device integrity is suitable for intended clinical use and met requirements of ISO 10555-1.
    GaugingPlane of maximum diameter at opening of female conical fitting lies between two limit planes of the gauge.The device hub met the requirements of ISO 80369-7.
    Separation ForceMating parts separation force > 35 N.The device hub met the requirements of ISO 80369-7.
    Unscrewing TorqueTest article luer remains attached after applying unscrewing torque not less than 0.02 N·m for a minimum of 10 seconds.The device hub met the requirements of ISO 80369-7.
    Stress CrackingNo stress cracks on the test article hub.The device hub met the requirements of ISO 80369-7.
    Ease of AssemblyComponents fit together securely with no resistance between test article luer and reference fitting.The device hub met the requirements of ISO 80369-7.
    Resistance to OverridingTest article luer does not override reference fitting threads.The device hub met the requirements of ISO 80369-7.
    ParticulateAmount of particulate matter during simulated use determined and compared to predicate device.The amount and size of particles from the subject device was comparable to the predicate device.
    Static Burst PressureEvaluate burst pressure under static conditions per ISO 10555-1:2013(E) Annex F.Device integrity is suitable for intended clinical use and met requirements of ISO 10555-1.
    Lubricity and DurabilityFrictional force equivalent to predicate device and less than 0.3N. No coating cracking or separation.Frictional force is suitable for intended clinical use, no coating cracking or separation, and is equivalent to the predicate device.
    Equipment InterfaceCompatible with 0.035" guidewire, ≥ 0.088" ID guide catheter/introducer sheath, ≤ 0.027" OD microcatheters, and common hemostatic valve.The device is compatible with the accessories as specified.
    Tip ShapeabilityDistal tip steam shapeable and equivalent to predicate devices.Shapeability of the distal tip after steam shaping is equivalent to predicate device.
    Kink ResistanceNo kinks when wrapped around pin gauges of clinical use relevant radii. No kinks during simulated use. Equivalent to predicate devices.The device is resistant to kinking around relevant radii turns.
    Simulated UseCatheter reaches target locations in tortuous vessel model; delivered and retracted smoothly with 0.035" guidewire; no device damage or defects after simulated use.Device performs as intended under simulated use conditions.
    Torque ResponseTorque response no worse than the predicate device.Device torque response is equivalent to the predicate device.
    Torque StrengthNo catheter breakage after 50 rotations.Device torque strength is equivalent to the predicate device.
    Pushability/RetractabilityPushability/retractability in tortuous vessel model no worse than the predicate device.Device pushability/retractability is equivalent to the predicate device.
    Catheter StiffnessCatheter stiffness equivalent to the predicate devices.The catheter stiffness is equivalent to the predicate device.
    Catheter Flexural FatigueNo flexural fatigue following repeated bending or hoop stress.The catheter flexural fatigue is equivalent to the predicate device.
    Dynamic BurstCatheter does not burst under dynamic pressure of 300 psi for 30 seconds.The device met the test acceptance criteria.
    Flow RateCatheter withstands manual injection of contrast media and saline at clinically relevant flow rates.The device can withstand flow rates suitable for intended clinical use.
    Ethylene Oxide ResidueResidual amount of ethylene oxide in single package ≤ 10µg/g.Ethylene Oxide Residue met the acceptance criteria per ISO 10993-7:2008.
    SterilityProduct shall be sterile.Sterility of the catheter met the acceptance criteria per ISO 11135:2014.
    Bacterial EndotoxinsEndotoxin content ≤ 2.15 EU/kit.Bacterial endotoxins met the acceptance criteria per USP .
    Biocompatibility Testing
    Cytotoxicity Test (ISO 10993-5)Cell viability of 100% test article extract shall be acceptable (not cytotoxic).The cell viability of 100% test article extract was 95.5%. (Conclusion: Non-cytotoxic)
    Skin Sensitization Test (ISO 10993-10)No significant evidence of skin sensitization.The positive rate of the test article was 0%. (Conclusion: No significant evidence of skin sensitization)
    Intracutaneous Reactivity Test (ISO 10993-10)Non-irritant. Final test article score acceptable.The final test article score was calculated to be 0. (Conclusion: Non-irritant)
    Acute Systemic Toxicity Test (ISO 10993-11)No significant evidence of systemic toxicity. Body weight data acceptable and equivalent between groups.Body weight data were acceptable and equivalent between the corresponding test and control treatment groups. (Conclusion: No significant evidence of systemic toxicity)
    Hemolytic Properties Test (ASTM F756)No influence on hemolytic properties.The hemolysis index was 0.44% (direct contact) and 0.00 (indirect contact). (Conclusion: No influence on hemolytic properties)
    Partial Thromboplastin Time (PTT) Test (ISO 10993-4)No effect on PTT—no significant differences between sample group and negative group.No significant differences between the sample group and the negative group. (Conclusion: No effect on PTT)
    In Vivo Thrombogenicity Test (ISO 10993-4)Equivalent to the control article—no significant differences between test and control articles.No significant differences between the test and control articles. (Conclusion: Equivalent to the control article)
    Pyrogen Test (ISO 10993-11)Non-pyrogenic—no rabbit shows an individual rise in temperature of 0.5 °C or more.No rabbit shows an individual rise in temperature of 0.5 °C or more. (Conclusion: Non-pyrogenic)
    Complement Activity (C3a, SC5b-9) Test (ISO 10993-4)Equivalent to the negative control group—no significant difference between sample group and negative control group.No significant difference between the sample group and negative control group. (Conclusion: Equivalent to the negative control group)

    Study Proving Device Meets Acceptance Criteria:

    The device met its acceptance criteria through a series of bench tests and biocompatibility evaluations.

    Bench Test Study:

    • Study Design: The bench testing of the Distal Access Catheter was performed using the applicable sections of the ISO 10555-1 international standard for sterile, single-use intravascular catheters. This standard specifies requirements for sterile, single-use intravascular catheters. The tests covered various physical and mechanical properties crucial for safe and effective device function.
    • Methodology: The document lists 24 distinct bench tests (e.g., Surface Inspection, Dimensional Verification, Corrosion Resistance, Peak Tensile Force, Fluid Leakage, Kink Resistance, Simulated Use, Dynamic Burst, Flow Rate, etc.). Each test had specific acceptance criteria derived from the ISO standard or established engineering specifications for the device. The results consistently concluded that the device was "suitable for intended clinical use," "met requirements," or was "equivalent to the predicate device."
    • Conclusion: The bench testing demonstrated that "the in vitro behavior of the device is well characterized within design specifications."

    Biocompatibility Study:

    • Study Design: The biocompatibility evaluation was conducted in accordance with FDA's biocompatibility guidance, "Use of International Standard ISO 10993-1, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process"."
    • Methodology: The biological tests were conducted in compliance with the Good Laboratory Practice (GLP) Regulation 21 CFR 58. These tests included Cytotoxicity, Skin Sensitization, Intracutaneous Reactivity, Acute Systemic Toxicity, Hemolytic Properties, Partial Thromboplastin Time (PTT), In Vivo Thrombogenicity, Pyrogen, and Complement Activity tests. Each test had specific criteria for acceptable biological response. The conclusions for these tests consistently indicated that the device was non-cytotoxic, non-sensitizing, non-irritant, non-systemically toxic, had no effect on hemolytic properties or PTT, was equivalent to control/predicate for thrombogenicity and complement activity, and was non-pyrogenic.
    • Conclusion: The biocompatibility testing confirmed the device material safety for its intended biological contact.

    The following information is not applicable (N/A) as this is a traditional medical device (catheter) and not an AI/ML powered device.

    1. Sample size used for the test set and the data provenance: N/A (for AI/ML test sets). These are physical and biological tests, not data-driven evaluations.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: N/A (for AI/ML expert annotation). Ground truth for physical/biological tests is based on objective measurements against established standards.
    3. Adjudication method (e.g. 2+1, 3+1, none) for the test set: N/A (for AI/ML expert adjudication).
    4. 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 (not an AI-assisted device).
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: N/A (not an AI algorithm).
    6. The type of ground truth used (expert concensus, pathology, outcomes data, etc): For this device, the "ground truth" or acceptance standard is derived from established international medical device standards (e.g., ISO 10555-1, ISO 80369-7, ISO 10993 series, USP ) and internal design specifications, verified through objective bench and biological testing.
    7. The sample size for the training set: N/A (not an AI/ML device; no training set in this context).
    8. How the ground truth for the training set was established: N/A (not an AI/ML device).
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