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510(k) Data Aggregation
(272 days)
Isopure, Corp.
The Isopure Corp Dry Acid Dissolution System is designed to mix dry acid concentrates with purified water to produce an acid concentrate solution for hemodialysis for use in 3- Stream (acid concentrate, bicarbonate concentrate, and water) hemodialysis machines.
The Isopure Dry Acid Dissolution System consists mainly of a Mixing Tank, a Distribution and Mixing Pump, a Hopper (with or without an automated opening mechanism), a Venturi inductor, and accompanying hydraulics and control circuits and sensors. The users will enter the dry acid powder mix into the Hopper either manually or by means of the automated bag opening mechanism. The contents of the Hopper will be drawn into the Mixing Tank by means of the Venturi inductor and the Distribution and Mixing Pump. Once all bags have been entered and the solution thoroughly mixed, the reading of the hydrostatic pressure inside the Tank will be converted into a specific gravity value. This in turn will be used to verify that the proper solution has been prepared against a pre-loaded table of values provided by the powder manufacturer. If the solution passes this verification, the system will allow transferring of the solution to the corresponding storage tank in the facility. The tanks will be identified by the use of quick connectors with RFID to prevent the transfer hose from being connected to the wrong tank.
The provided text describes the Isopure Dry Acid Dissolution System, a medical device for preparing hemodialysis solutions. However, it does not describe an AI/ML-based medical device. Therefore, it does not contain the information required to answer the prompt regarding acceptance criteria and a study proving the device meets those criteria for an AI/ML device.
The document is a 510(k) summary for a traditional medical device. It lists non-clinical performance data and explicitly states: "No clinical performance testing was required for determination of substantial equivalence of this type and class of device."
Therefore, I cannot provide the requested information, particularly points 1-9, as they pertain to the evaluation of an AI/ML medical device, which is not what this document describes.
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(86 days)
ISOPURE CORP.
The Isopure ACDS with remote fill is intended to be used in Hemodialysis facilities for the storage and distribution of acid concentrate to be used in the treatment of Hemodialysis patients.
The Isopure ACDS (Acidified Concentrate Distribution and Storage) is designed for storage of pre-mixed acidified concentrate in a tank for transfer through a loop to the individual dialysis machines or to fill jugs which then can be transported to the individual dialysis machines when no distribution loop exists. ISOPURE ACDS (Acidified Concentrate Distribution and Storage) with optional remote fill uses "one-piece molded seamless tanks constructed of linear polyethylene" for bulk storage of acidified concentrate. The optional remote fill allows the storage tanks to be filled by the vendor from outside the building. The Isopure ACDS (Acidified Concentrate Distribution and Storage) with optional remote fill meets or exceeds all Association for the Advancement of Medical Instrumentation (AAMI) National Standards for Hemodialysis.
The provided text is a 510(k) summary for the Isopure ACDS (Acidified Concentrate Distribution and Storage) device, which is a medical device used in hemodialysis facilities. The summary focuses on demonstrating substantial equivalence to a predicate device, rather than providing a detailed study proving the device meets specific acceptance criteria in the format typically seen for novel AI/software devices.
Instead, the "acceptance criteria" here refer to the performance and functional equivalence to the previously cleared predicate device (Pure Water Inc.'s Acidified Storage and Distribution System, K993058). The "study" proving this equivalence is the validation protocol VP12-002, which tests the operation of various components of the ACDS system.
Here's an analysis of the provided information, addressing your questions where applicable and noting where information is not present in this type of submission:
1. Table of Acceptance Criteria and Reported Device Performance
Given the nature of this 510(k) (seeking substantial equivalence for a device that is essentially a re-branded and re-manufactured version of a previously cleared device), the acceptance criteria are implicitly that the new device operates identically or equivalently to the predicate device, especially regarding functional components. The "performance" is the successful testing of those components.
Acceptance Criteria (Implicit from Predicate Device) | Reported Device Performance (Validation Protocol VP12-002) |
---|---|
ACDS Storage Tank: | |
- Proper assembly of trim kit. | - A 250-gallon storage tank assembled with the trim kit. |
- No leaks in trim kit assemblies and connections. | - Tested for leaks in trim kit assemblies and connections to the storage tank. (Implied successful as no failures reported). |
- Bottom connection provides acidified concentrate. | - When connected to the bottom, provided acidified concentrate to the distribution pump. |
- Valve allows flow termination. | - Valve allowed flow to be terminated to the distribution pump when closed. |
Level Floats: | |
- Low float provides low tank warning. | - Low float tested to ensure proper operation of the remote alarm low-level indicator. (Implied successful). |
- Low float turns power on for remote fill station. | - Low float tested to ensure proper operation for the optional remote fill station (turns power on). (Implied successful). |
ACDS Control Box: | |
- Proper operation of control box. | - Connected to storage tank and remote fill box. Power connected. (Implied successful operation of the control box). |
- Distribution pump operation. | - Distribution pump tested. (Implied successful). |
- Low-level alarm operation. | - Low-level alarm tested. (Implied successful). |
- Optional remote fill station operation. | - Optional remote fill station tested. (Implied successful). |
Distribution Pump: | |
- Distribution of acidified concentrate. | - Connected to a 500 ft ½" polyethylene line to test distribution. (Implied successful distribution). |
- Pressure and flow measurement. | - Pressure gauge and flow meter used to measure flow and pressure on the distribution line. (Measurements taken, implied within acceptable parameters of the predicate device, though specific numbers are not provided). |
- Flow switch operation validation. | - Flow meter used to verify the operation of the flow switch on the ACDS distribution pump. (Implied successful validation). |
Remote Fill Station: | |
- On/off electrical connections to controller. | - Connected to storage tank and controller; tested the on/off electrical connections of the controller in relation to the fill station. (Implied successful). |
Regulators: | |
- Regulates excessive pressure (> 5 psig). | - A 0-25 regulator is supplied to regulate pressure at each individual station in the event of excessive pressure (> 5 psig) at the distribution box. (Implied functional as designed, though a specific test scenario for excessive pressure and its regulation is not detailed, it often falls under design verification testing). |
Overall Equivalence: | - "The Isopure ACDS... is the same device that was manufactured by Pure Water, Inc. under 510(k) 993058." "The only change to the device is the name and manufacturing location. All performance data provided in the original 510(k) remains the same." "Performance testing was undertaken to verify that the device is as safe, as effective and performs as well as or better than the earlier versions of the Pure Water Inc's Acidified Concentrate Distribution and Storage system (K993058)." |
Information Not Applicable or Provided in this 510(k) Summary:
The following questions are typically relevant for AI/software devices performing diagnostic or interpretive tasks, clinical studies, or novel device performance claims. This 510(k) is for a physical medical device (Acidified Concentrate Distribution and Storage System) and focuses on manufacturing transfer and minor changes, demonstrating substantial equivalence to an existing device. Therefore, these categories are mostly Not Applicable (N/A) to this specific submission.
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- N/A. The "test set" here refers to the actual physical device components and their integrated system. The testing is a validation protocol on a single prototype/production unit or a representative sample, not a data-based test set for an algorithm. The testing was done at the manufacturer's location (Simpsonville, KY, USA).
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
- N/A. "Ground truth" in this context would be engineering specifications and functional requirements outlined in the design and AAMI standards, which are verified by engineers or quality control personnel, not clinical experts establishing diagnostic "ground truth."
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- N/A. Adjudication methods are for human interpretation conflicts in clinical studies, not for the functional testing of a physical 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
- N/A. This applies to AI-assisted diagnostic or interpretive devices. The Isopure ACDS is a physical system for storing and distributing hemodialysis concentrate.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
- N/A. This applies to AI/software performance.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- N/A. The "ground truth" for this device's performance is adherence to engineering specifications, functional requirements (e.g., pump distributes fluid, alarm activates), and relevant industry standards (AAMI National Standards for Hemodialysis).
8. The sample size for the training set
- N/A. This device does not use a "training set" in the context of machine learning or algorithms. Its design and manufacturing are based on established engineering principles and the predicate device.
9. How the ground truth for the training set was established
- N/A. As above, no training set. The "ground truth" for its design and performance expectations is based on the previously cleared predicate device and industry standards for hemodialysis equipment.
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(156 days)
ISOPURE CORP.
The Isopure Sodium Bicarbonate Mixing and Distribution System is intended to be used in Hemodialysis facilities for the mixing, storage and distribution of Bicarb liquid concentrate to be used in the treatment of Hemodialysis patients.
The Isopure Sodium Bicarbonate Mixing and Distribution System is designed to mix sodium bicarbonate powder into a liquid solution based on the recommended mixing procedures from the powder manufacturers. Once the powder is mixed into a liquid solution and verified for content accuracy, the solution is transferred to an independent distribution tank for transfer through a loop to the individual dialysis machines or to fill jugs which then can be transported to the individual dialysis machines when no distribution loop exists. The Isopure Sodium Bicarbonate Mixing and Distribution System features the patented SOLUBILIZER™, which utilizes a large volume of water spinning in a vortex manner to dissolve dry powder into a liquid solution that is drawn into a mix tank. The solution is mixed with AAMI quality water according to specifications outlined by the manufactures for the bicarbonate powder. Once the solution has been dissolved and mixed, the solution can be transferred from the mixing tank to the storage delivery tank for distribution to the loop or jugs. The tanks and the SOLUBILIZER™ are sealed to reduce microbial contamination. The sealed design also facilitates CO2 recovery and gassing off of CO2 during the mixing procedure. The entire system is controlled by programmable control logic (PLC), which operates the system. The PLC will control the mixing, the delivery and disinfection of the complete system. The system PLC is operated through an HMI touch screen which displays the critical aspects of the system. including the operational stages, real-time indication of various steps, and alarm conditions.
The provided text describes a 510(k) premarket notification for the Isopure Sodium Bicarbonate Mixing and Distribution System. This type of submission focuses on demonstrating substantial equivalence to a legally marketed predicate device, rather than proving safety and effectiveness through extensive de novo clinical trials. Therefore, the information typically requested in your prompt (e.g., acceptance criteria with reported device performance in a table, sample sizes for test/training sets, number and qualifications of experts for ground truth, MRMC studies, standalone performance, type of ground truth) is not explicitly present in the provided document.
The document primarily focuses on comparing the technological characteristics of the new device to its predicate and outlining non-clinical testing performed to establish equivalence.
Here's an analysis based on the available information:
1. Table of Acceptance Criteria and Reported Device Performance:
The document doesn't present a table with explicit acceptance criteria and corresponding reported device performance metrics in the format typically used for performance studies. Instead, it states that the system "was tested repeatedly for proper operation" and "each mix batch was tested for the target conductivity of the solution to confirm the correct mixture."
The implied acceptance criterion is:
- Target conductivity of the solution: The mixed sodium bicarbonate solution must achieve the "target conductivity" to confirm correct mixture.
The reported device performance is:
- "each mix batch was tested for the target conductivity of the solution to confirm the correct mixture, and then transferred to the Distribution Tank."
- "The distribution function was then tested to ensure that circulation of the solution through the loop occurred as expected."
- "The system has undergone 100% testing to ensure substantial equivalence to the Pure Water, Inc. predicate device. Both systems are fully capable of meeting the mix requirements specified for a suitable sodium bicarbonate solution."
2. Sample Size Used for the Test Set and Data Provenance:
- Sample Size: The document does not specify a numerical sample size for the test set. It states the system "was tested repeatedly" and "each mix batch was tested for the target conductivity." This suggests multiple batches were tested for each selectable volume.
- Data Provenance: The testing was non-clinical. The "testing area consists of all components of a water room that would normally be present at a dialysis clinic." It utilized "the same brand of bicarbonate typically used in an operating clinic." This implies the testing environment and materials were representative of real-world use within a dialysis facility. The country of origin for the data is implicitly the US, as the submitter is an American company and the approval is from the US FDA. The testing was prospective within the context of the device development and validation.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of those Experts:
- Experts: Not applicable. The "ground truth" for the device's function (correct mixing and distribution) was established through objective measurements (conductivity) and functional assessments (circulation). This is a technical performance verification, not a clinical interpretation requiring expert consensus.
4. Adjudication Method for the Test Set:
- Adjudication Method: Not applicable. The "ground truth" (correct mixture via conductivity, proper circulation) was determined by direct measurement and observation, not expert review or adjudication.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done:
- MRMC Study: No, an MRMC comparative effectiveness study was not done. This device is a medical equipment system for mixing and distributing solutions, not an imaging or diagnostic device that would involve human readers interpreting cases.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done:
- Standalone Performance: Not applicable in the context of typical AI/algorithm standalone performance. The device itself is an automated system controlled by a PLC, and its performance was assessed directly. There isn't a separate "algorithm" for human-in-the-loop interaction in the way AI diagnostics are often evaluated. The testing described focuses on the machine's ability to execute its programmed functions (mixing, distribution) correctly and automatically.
7. The Type of Ground Truth Used:
- Type of Ground Truth: The ground truth was based on objective technical measurements and functional verification. Specifically:
- Conductivity Readings: To confirm the correct mixture of the sodium bicarbonate solution (compared against a target conductivity).
- Functional Assessment: To ensure proper circulation of the solution through the distribution loop.
- Compliance with Manufacturer Recommendations and Standards: Adherence to powder manufacturers' recommendations and AAMI RD52-2004 requirements for mixing procedures.
8. The Sample Size for the Training Set:
- Training Set Sample Size: Not applicable. This device is not an AI/machine learning model in the conventional sense that would require a "training set" of data to learn from. Its operation is governed by pre-programmed logic (PLC) and engineering design, not statistical learning from a dataset.
9. How the Ground Truth for the Training Set was Established:
- Training Set Ground Truth: Not applicable, as there is no training set for this type of device. The operating parameters and expected performance are established through engineering specifications, manufacturer guidelines, and relevant industry standards (like AAMI RD52-2004).
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(157 days)
ISOPURE CORP.
The Isopure Complete Water Purification System each device is intended for use in Hemodialysis and is intended to remove organic and inorganic chemical contaminants and microbitorial contaminants from water used to dilute dialysate substances. These systems are to be use in Hospitals and/or Hemodialysis facilities.
The Isopure Complete Water Purification System for direct feed Hemodialysis Facilities Indirect feed utilizing the MD610, MD620, MD630, MD640 Ultra Filter System. Each indirect feed model has the following optional configuration: MD610 – Single distribution pump with a series of ultra-filters based on the required flow of the facility. The MD610 has no Deionization capabilities. MD620 – Dual multi-stage distribution pumps with a series of ultra-filters based on the required flow of the facility. The MD620 has no Deionization capabilities. MD630 – Single multi-stage distribution pump with a series of ultra-filters based on the required flow of the facility. The MD630 is equipped to process a single bank of medical grade Deionization exchange tanks. MD640 – Dual multi-stage distribution pumps with automatic pump alternation with a series of ultra-filters based on the required flow of the facility. The MD640 is equipped to process dual banks of medical grade Deionization exchange tanks. The MD640 is capable of operating continuously by automatically alternating between the two banks of exchange tanks.
I am sorry, but based on the provided text, I cannot extract the information required to describe the acceptance criteria and the study that proves the device meets those criteria.
The document is a 510(k) premarket notification letter from the FDA regarding the "Isopure Complete Water System for Hemodialysis". It states that the device is substantially equivalent to legally marketed predicate devices and outlines the indications for use. However, it does not contain details about:
- Specific acceptance criteria for device performance (e.g., purity levels of water, removal efficiency of contaminants).
- Any study performed by the manufacturer to demonstrate compliance with performance metrics.
- Sample sizes, data provenance, expert qualifications, adjudication methods, MRMC studies, standalone performance, types of ground truth, or details about training sets.
This document is a regulatory approval letter, not a scientific study report or a detailed performance validation document.
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(122 days)
ISOPURE CORP.
The MD 420-490 series reverse osmosis system is intended to purify water for hemodialysis when used as a component of a complete water purification system.
The MD 420-490 Series is a Reverse Osmosis Machine used in purifying water. The MD 420-490 series features an advanced electronic package including a PLC with software and validation procedures and a Touch-screen. The new advanced system has the capability to monitor both the pre-treatment and posttreatment of the water room. The data can be printed for a daily log or modem to a remote location. The machine is now simpler, quieter, and easier to maintain, run, and service compared to the MD 400 A-F. The PLC can monitor all aspects of the water room including the RO, pre-treatment, storage tank, line and loop pressures, temperatures, and flows. The system will display membrane % rejection and % recovery. All of this data is sent back to the RO where it is displayed. The data also has the capability to be modemed to a remote location. The hydraulic design of the machine remains unchanged for the original 510(k) application, however, we now use SCH 80 PVC pipe and 316L Stainless Steel piping in place of the tubing originally used of the HD- MD series.
The provided document describes a 510(k) submission for a medical device, the MD 420/440/460/470/480/490 Multi-Patient Reverse Osmosis (RO) Machine. However, it does not include information about acceptance criteria or a study that proves the device meets specific performance metrics in the way that would typically be presented for a diagnostic or AI-driven device.
Instead, this document is a summary of the substantial equivalence determination for a modified RO machine for hemodialysis water purification. The "study" here is essentially the comparison to a predicate device and a discussion of non-clinical tests to determine substantial equivalence.
Here's an analysis based on the information available in the provided text:
1. Table of Acceptance Criteria and Reported Device Performance:
The document does not explicitly state acceptance criteria in terms of numerical performance thresholds (e.g., sensitivity, specificity, accuracy). The acceptance criteria implicitly revolve around maintaining the safety and effectiveness of the predicate device while incorporating new electronic and design features.
Acceptance Criteria Category | Specific Acceptance Criteria (Inferred from text) | Reported Device Performance (Inferred from text) |
---|---|---|
Intended Use | Must purify water for Hemodialysis as a component of a complete water purification system. | "The MD 420-490 series is intended to purify water for Hemodialysis when used as a component of a complete water purification system." (Stated as maintained from predicate) |
Safety | No adverse changes in safety from the predicate device. | "Based on the information submitted, there are no changes in the safety of effective issues." (Stated by FDA and manufacturer) |
Effectiveness | No adverse changes in effectiveness from the predicate device in purifying water for hemodialysis. | "Based on the information submitted, there are no changes in the safety of effective issues." (Stated by FDA and manufacturer) |
Functionality (New Features) | Advanced electronic package (PLC, touchscreen) must monitor pre-treatment and post-treatment, print data, and allow remote modem communication. Improved design for quieter operation, easier maintenance, and reduced failures. | The device "features an advanced electronic package including a PLC with software and validation procedures and a Touch-screen. The new advanced system has the capability to monitor both the pre-treatment and post-treatment of the water room. The data can be printed for a daily log or modem to a remote location." The machine is "simpler, quieter, and easier to maintain, run, and service compared to the MD 400 A-F." |
Material Changes | Use of SCH 80 PVC pipe and 316L Stainless Steel piping must not compromise performance or safety. | The hydraulic design "remains unchanged for the original 510(k) application, however, we now use SCH 80 PVC pipe and 316L Stainless Steel piping in place of the tubing originally used of the HD- MD series." (Implies these materials maintain required performance) |
2. Sample Size Used for the Test Set and Data Provenance:
- Sample Size for Test Set: Not applicable. This submission is not based on a clinical trial with a "test set" of patients or data in the way a diagnostic device would be. It's an engineering and design modification approval.
- Data Provenance: The "data" primarily consists of engineering specifications, design comparisons, and the rationale for modifications. It's not based on patient data from a specific country or collected retrospectively/prospectively from a clinical population. It's an internal design and safety/effectiveness assessment by the manufacturer, reviewed by the FDA.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications:
Not applicable. "Ground truth" in the context of this document refers to the established safety and effectiveness of the predicate device and the engineering assessment that the modifications do not negatively impact these aspects. This would involve internal engineering expertise from Isopure Corporation and regulatory review by the FDA (specifically, the Division of Reproductive, Abdominal, Ear, Nose and Throat, and Radiological Devices). No external medical experts are mentioned as establishing "ground truth" for a specific test set.
4. Adjudication Method for the Test Set:
Not applicable. There is no specific test set requiring adjudication in the context of this 510(k) submission. The FDA's substantial equivalence review process serves as the "adjudication" of the overall submission.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done:
No. An MRMC study is relevant for diagnostic devices where human readers interpret medical images or data. This device is a water purification system, not a diagnostic tool.
6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done:
No. This device is an electromechanical system, not an algorithm. Its "performance" is its ability to purify water, not to interpret data in an autonomous way.
7. The Type of Ground Truth Used:
The "ground truth" in this context is the established safety and effectiveness of the predicate device (MD 400 Series Multi-Patient Reverse Osmosis (RO) Water Treatment System) and the engineering and regulatory assessment that the modified device (MD 420-490 Series) maintains this level of safety and effectiveness despite design changes and the addition of features like a PLC. It's based on technical specifications, regulatory standards, and the intended use of water purification for hemodialysis.
8. The Sample Size for the Training Set:
Not applicable. This device is not an AI/ML algorithm that is "trained" on a dataset.
9. How the Ground Truth for the Training Set Was Established:
Not applicable, as it's not an AI/ML device with a training set.
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