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510(k) Data Aggregation

    K Number
    K061023
    Date Cleared
    2006-09-20

    (160 days)

    Product Code
    Regulation Number
    870.5900
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    LIFE RECOVERY SYSTEMS HD, LLC

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

    The ThermoSuit System™ is a thermal requlating system.
    Indications for Use are
    a. Temperature reduction in patients where clinically
    indicated, e.g. in hyperthermic patients;
    b. Monitoring of patient temperature.

    Device Description

    The ThermoSuit System (TSS) is a device that allows rapid patient cooling by the circulation of cold water in direct contact with the skin of the patient. Patient temperature measurements control the extent and duration of cooling, by controlling pump output and drainage of cooling fluid. Temperature measurements and associated alarm signals are designed to prevent overcooling.

    The ThermoSuit System™ consists of the following main components:

    • . ThermoSuit Body Enclosure
    • Multi-lumen Umbilicus Hose .
    • . Reservoir/Pump Assembly
    • . Pump Controller Console
    • . Other Components
    AI/ML Overview

    Here's an analysis of the acceptance criteria and study information for the ThermoSuit System, based on the provided document:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document doesn't explicitly define numerical acceptance criteria (e.g., cooling rate target, temperature accuracy range) or quantifiable performance metrics for the ThermoSuit System. Instead, the performance testing focuses on functional verification and comparison with a predicate device.

    Acceptance Criteria (Inferred from context)Reported Device Performance
    Optimal suit dimensions and operating parametersResults from human volunteer testing used to optimize suit dimensions and operating parameters.
    Mechanical integrity of the ThermoSuit Body Enclosure (pressure resistance)ThermoSuit Body Enclosure passed testing with a 50% excess pressure in air compartments and fluid channels.
    Product meets all performance specifications (functional testing with new and aged components)ThermoSuit System was functionally tested with new and aged ThermoSuit Body Enclosures by measuring relevant design parameters; the product met all performance specifications.
    Pump/Controller functions and software validation conform to device specificationsPerformance testing included a full evaluation of Pump/Controller functions and software validation; results conformed to device specifications.
    Ability to cool test systems (comparable to predicate device)Comparative Cooling Bench Study (Heated Mannequin): New device and predicate device both cooled test systems. Cooling occurred at a higher rate in the new device.
    Animal Study (Large Pigs): New device and predicate device both cooled test systems. Cooling occurred at a higher rate in the new device.
    System works in the hands of users (monitoring water volumes)Monitoring of water volumes during system operation showed the system worked in the hands of users.
    Users understand the Operator's Manual, device, and its operationUsers' responses to a detailed questionnaire established that they understood the Operator's Manual, the device, and its operation.
    Biocompatibility for short-term skin contactISO 10993 (Biocompatibility for short-term skin contact) standard was met.
    Electrical safety and electromagnetic compatibilityMet UL 60601-1, CSA C22.2 NO 601.1-M90, CENELEC EN 60601-1, CENELEC EN 60601-1-2, IEC 60601-1-2, and JIS T0601-1 standards.
    Patient temperature monitoring functions as designed (prevents overcooling, alerts user)Designed to prevent overcooling (temperature measurements and alarm signals) and alerts user when patient temperature approaches target.
    Substantial equivalence to predicate device in cooling function and other key aspects (see Section 7.6)Determined to be substantially equivalent to the predicate device in its cooling function and other listed attributes.

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

    • Human Volunteers (for suit optimization): Sample size not specified.
    • ThermoSuit Body Enclosures (mechanical integrity): "All suits" implies the entire production batch or a representative sample from it. Sample size not specified quantitatively.
    • Functional Testing (new and aged components): Sample size not specified quantitatively for components, but refers to "ThermoSuit System" and "ThermoSuit Body Enclosures."
    • Comparative Cooling Bench Study:
      • Test Set: One "Heated Mannequin."
      • Data Provenance: Benchtop study (laboratory setting).
    • Animal Study:
      • Test Set: "Large pigs." Sample size not specified quantitatively.
      • Data Provenance: Animal study (presumably in a controlled laboratory or research facility).
    • Design Validation (User Testing):
      • Test Set: Four (4) Users, completing a total of nine (9) test runs.
      • Data Provenance: User testing, likely in a simulated clinical or laboratory environment.
    • Data Provenance (overall): Primarily internal testing (bench, animal, user validation). Country of origin is not specified, but the company is US-based (Kinnelon, NJ), suggesting US provenance. All studies appear to be prospective.

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

    • For the technical and functional performance tests (mechanical integrity, pump/controller, software), the "ground truth" would be established by the engineering and testing protocols themselves, not typically by experts in a clinical sense.
    • For the cooling studies (mannequin and animal), the ground truth is the actual measured temperature change and cooling rates. This is a direct measurement, not an expert consensus.
    • For the user validation test, the ground truth for understanding the manual and device operation was established through a "detailed questionnaire" answered by the four users. Their qualifications as "Users" are not further specified (e.g., nurses, technicians, physicians), but they are implied to be representative of target operators.

    4. Adjudication Method for the Test Set:

    Not applicable in the conventional sense. The studies described are primarily objective measurements (temperature, pressure, functional checks) or direct user feedback (questionnaire). There's no mention of subjective interpretation of results requiring adjudication by multiple readers or evaluators.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:

    No, an MRMC study was not done. The comparative studies involved the device and a predicate device in bench and animal models, not human readers interpreting cases.

    6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study:

    The ThermoSuit System is a medical device that involves direct interaction with a patient and a human operator. Its "performance" isn't a standalone algorithm in the way an AI diagnostic tool would be. The closest equivalent would be the automated functions of the pump controller and software. The document states:

    • "Performance testing of the ThermoSuit System included a full evaluation of the Pump/Controller functions and software validation; the results conformed to the device specifications."
      This indicates that the automated control aspects were tested for their inherent functionality according to specifications, representing a form of standalone performance for the automated components.

    7. The Type of Ground Truth Used:

    • Objective Measurements: For mechanical tests (pressure), functional tests (pump/controller, software), and cooling studies (temperature reduction, cooling rate).
    • Test Specifications: The device was tested against its own "performance specifications" and "design parameters."
    • User Feedback: For understanding of the Operator's Manual and device operation in the design validation.
    • Compliance with Standards: For biocompatibility, electrical safety, and electromagnetic compatibility.
    • Comparison to Predicate Device: For cooling effectiveness, where the predicate device's performance served as a benchmark for "comparable" results.

    8. The Sample Size for the Training Set:

    This device is not an AI/ML algorithm that requires a "training set" in the computational sense. The development and optimization processes of the ThermoSuit System likely involved iterative design, prototyping, and testing (including the human volunteer testing for suit dimensions/operating parameters), which could be considered analogous to "training" in an engineering context, but not a data-driven training set for an algorithm. No specific sample sizes for such iterative development are provided here.

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

    As above, there is no "training set" in the AI/ML context for this device. The development process would have involved engineering design principles, physical testing, and potentially user feedback during various stages to refine the product, with "ground truth" being established by physical measurements, functional requirements, and design specifications.

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