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510(k) Data Aggregation

    K Number
    K200176
    Date Cleared
    2021-12-15

    (691 days)

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

    Repro-Med Systems, Inc., dba KORU Medical Systems

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

    The Freedom Integrated Syringe Infusion System is specifically indicated for the subcutaneous infusion of the following human plasma-derived immunoglobulins when used according to the FDA approved biologic labeling: Cutaquig®, Immune Globulin Subcutaneous (Human) 16.5% Solution (manufactured by Octapharma®); Cuvitru®, Immune Globulin Infusion (Human) 20% (manufactured by Takeda®); Gammagard Liquid®, Immune Globulin Infusion (Human) 10% (manufactured by Takeda®); Hizentra®, Immune Globulin Subcutaneous (Human) 20% Liquid (manufactured by CSL Behring®); and Xembify®, Immune Globulin Subcutaneous (Human) 20% Liquid (manufactured by Grifols®) in the home, hospital, or ambulatory settings when administered according to the approved biologic or drug product labeling.

    The FREEDOM Integrated Syringe Infusion System with the FREEDOM60® Syringe Driver and Precision Flow Rate Tubing™, is specifically indicated for the intravenous infusion of the following antibiotics when used according to the FDA approved drug product labeling: ertapenem, meropenem, oxacillin, and tobramycin.

    The Freedom Integrated Syringe Infusion System consists of the following components:

    • FREEDOM60® Syringe Driver
    • Precision Flow Rate Tubing™M
    • HIgH-Flo Subcutaneous Safety Needle SetsTM
    • HIgH-Flo Super26™ Subcutaneous Needle Sets are specifically indicated for the subcutaneous infusion of the following human plasma-derived immunoglobulins: Cutaquig®, Immune Globulin Subcutaneous (Human) 16.5% Solution (manufactured by Octapharma®); Cuvitru®, Immune Globulin Infusion (Human) 20% (manufactured by Takeda®); Hizentra®, Immune Globulin Subcutaneous (Human) 20% Liquid (manufactured by CSL Behring®); and Xembify®, Immune Globulin Subcutaneous (Human) 20% Liquid (manufactured by CSL Behring®).

    The FREEDOM60® Syringe Driver is indicated for use with the BD® 50 ml syringe (US Reference number 309653).

    Device Description

    The FREEDOM® Integrated Syringe Infusion System is a single-channel, volumetric infusion pump. The FREEDOM60® Integrated Syringe Infusion System consists of four primary components:

      1. FREEDOM60® Syringe Driver,
      1. Precision Flow Rate Tubing™ and
      1. HIgH-Flo Subcutaneous Safety Needle Set™, or
      1. HIgH-Flo Super26TM Subcutaneous Safety Needle Set
    1. FREEDOM60® Syringe Driver:
      The FREEDOM60® Syringe Driver in combination with Precision Flow Rate Tubing™ (sterile) and HIgH-Flo Subcutaneous Safety Needle Sets (sterile) makes up the Freedom Integrated Syringe Infusion system. The FREEDOM60® Syringe Driver is a non- sterile, reusable non-electric driver that infuses immunoglobulins subcutaneously and antibiotic solutions intravenously to patients.

    The FREEDOM60® Syringe Driver is an ambulatory device designed to accommodate a BD Luer- Lok™ 50mL Syringe (Catalog No.: 8881-560125, BD 309653), and fluid volumes ranging from 10cc to 60cc may be used. The pump uses a constant force spring mechanism to apply pressure to the plunger-end syringe.

    The Freedom Integrated Syringe System is assembled by loading the syringe with tubing into the Freemdom60® driver.

    1. Precision Flow Rate Tubing™:
      The Freedom Integrated Syringe System includes a range of Freedom Precision Flow Rate Tubing™ (provided sterile). The tubing ranges from F0.5 to F2400. Each F-number provides a different level of flow restriction, which, when combined with the viscosity of the medication, provides a controlled delivery in an all-mechanical system. The tubing sets connect at one end to the syringe being used and on the other end to the Subcutaneous Safety Needle Sets or directly on venous catheters for intravenous infusions as needed.

    2. HIgH-Flo Needles Sets:
      The HIgH-Flo Subcutaneous Safety Needle SetsTM
      The HIgH-Flo Subcutaneous Safety Needle Sets™ (provided sterile) are used to administer drugs to the subcutaneous layers using small needles attached to the skin. Subcutaneous needles come in different lengths to administer immunoglobulins and antibiotics.

    Subcutaneous Safety Needle Sets comes in multiple configurations (1, 2, 3, 4, 5, 6 needle sites). Needles are available in 4mm, 6mm, 9mm, 12mm, and 14mm lengths combined with 24 or 26 Gauge. Using the Y-Connector, the patient can have up to 8 sites for drug delivery.

    The HIgH- Flo Subcutaneous Safety Needle Sets™ also allow each needle to be enclosed between the wings after use.

    The HIgH-Flo Super26TM Subcutaneous Needle Sets
    The HIgH-Flo Super26TM Subcutaneous Needle Sets are sterile, non-pyrogenic, single use, Subcutaneous Administration Sets, comprised of a Super 26-gauge needle assembly, combined with 24-gauge needle tubing and are intended for the delivery of medication to the subcutaneous tissue. Each set consists of a sterile infusion set and a commercially available adhesive dressing used to hold the device in place. The infusion set is a 90degree, 26-gauge stainless steel needle, mounted to a butterfly winged safety closure on one end which is used to close the set upon completion. The other end consists of a luer lock which connects to PVC medical grade tubing. Additionally, each tubing set is equipped with a slide clamp used to stop flow, immediately as needed. HIgH-Flo Super 26TM Subcutaneous Needle Sets are available as a single set, as well as 2-needle, 3needle, 4-needle, 5-needle, 6-needle, sets; through use of a Y-connector, 7-needle and 8 needle sets may also be assembled.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and the study information presented in the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document primarily focuses on demonstrating substantial equivalence to a predicate device and provides performance data for flow rates with different configurations. It doesn't explicitly state "acceptance criteria" in a singular table, but rather details the performance characteristics that were measured and compared. The key performance aspect is the flow rate accuracy.

    Acceptance Criteria (Implied)Reported Device Performance
    Flow Rate AccuracyPredicate Device (K162613): +/- 8% of predicted flow rates.

    Subject Device (K200176): Flow rates will fall between the minimum and maximum predicted values as specified in the Instructions for Use (IFU). The document then provides extensive tables of min-max predicated flow rates per site for various drugs (Cutaquig®, Xembify®, Cuvitru®, Gammagard Liquid®, Hizentra® PI, Hizentra® CIDP) across different needle sets (HIgH-Flo 26G, HIgH-Flo Super26, HIgH-Flo 24G) and tubing types (F120-F2400). |
    | Biocompatibility | Materials comply with ISO 10993-1 and FDA Blue Book Memorandum #G95-1. Testing included Cytotoxicity, Sensitization, and Irritation. |
    | Human Factors | Human factors studies were conducted per FDA Guidance "Applying Human Factors and Usability Engineering to Medical Devices" (February 3, 2016). Results demonstrate validation of the device per its intended use. |
    | Reprocessing/Cleaning | Compliance with AAMI TIR12:2010, AAMI TIR30:2011(R)2016, "Reprocessing Medical Devices in Health Care Settings," and ISO 17664:2017. Worst-case design for cleaning and low-level disinfection efficacy studies were reviewed and compared. |
    | Packaging | Compliance with ISO 11607-1:2019 (Packaging for terminally sterilized medical devices). The nylon film pouch maintains sterile barrier. |
    | Sterility | Compliance with ISO 11137-2:2013 (Sterilization of health care products - Radiation). |
    | MR Safety | Compliance with ASTM F2503-13 ("Standard Practice for Marking Medical Devices and Other Items for Safety in the Magnetic Resonance Environment"). |
    | Safety Assurance | A safety assurance case was provided, addressing: device requirements, risk identification/mitigation, and device reliability. |

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

    The document does not explicitly state a sample size for a "test set" in the context of an accuracy study with patient data. The performance data presented (flow rate combinations) appears to be derived from bench testing and theoretical calculations, rather than a clinical trial or a test set of patient data.

    • Provenance: This is bench testing data, not human or animal data. The origin would be the testing laboratories where the physical measurements were taken. No country of origin is specified for the testing. It is not retrospective or prospective clinical data.

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

    Not applicable. The "ground truth" for the flow rate performance is established through direct measurement on the physical device during bench testing, not through expert consensus on medical images or patient outcomes.

    4. Adjudication Method for the Test Set:

    Not applicable. There is no human adjudication process described, as the evaluation is based on physical device performance measurements.

    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 for infusion, not an AI-powered diagnostic tool. Therefore, MRMC studies and AI assistance for human readers are not relevant.

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

    Not applicable. This is a mechanical infusion system, not an algorithm.

    7. The Type of Ground Truth Used:

    The ground truth for the flow rate performance is based on direct physical measurements (bench testing) of the device under various configurations and theoretical calculations. This is supplemented by compliance with recognized international standards and FDA guidance documents for biocompatibility, sterility, packaging, human factors, and reprocessing.

    8. The Sample Size for the Training Set:

    Not applicable. This is a mechanical infusion system, not an AI model 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 model.

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    K Number
    K201490
    Manufacturer
    Date Cleared
    2021-02-12

    (253 days)

    Product Code
    Regulation Number
    868.5665
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Med Systems, Inc.

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

    The Electro Flo® 6 Airway Clearance System is intended to provide Airway Clearance Therapy and promote bronchial drainage where external manipulation of the physician's choice of treatment. It is indicated for patients having difficulty with secretion clearance, or the presence of atelectasis caused by mucus plugging.

    The device is intended for home or institutional use by patients weighing at least 23 Kg.

    Device Description

    The Electro Flo® 6 Airway Clearance System is a High Frequency Chest Wall Oscillation System (HFCWO), including all accessories and supplies.

    Electro Flo® 6 Airway Clearance System comprises:

    • An electrically powered Control Box with a power switch on the back and two knobs on the front: one knob provides five intensity settings, and the other provides six frequency settings,
    • The Power Head, connected by a cable to the Control Box, ●
    • The Carrying Case,
    • The Information Manual, ●
    • The Optional Self-Administrator® Strap that can hold the Electro Flo® 6 system Power Head and enable a patient to apply therapy to the back, unassisted.

    The Electro Flo® 6 Airway Clearance System's operating mechanism is an electromechanical "hammer and anvil"; the hammer is the handheld body of the Power Head, and the anvil is the surface of the Power Head that is held in contact with the chest. Repeated electrical pulses from the Control Box separate the hammer and anvil. The Frequency knob of the Control Box controls the repetition rate, and the Power knob controls the pulse duration; there are 30 combinations.

    When each electrical pulse ends, the force applied by the therapist's hand forces the hammer through the gap until it strikes the anvil and delivers a mechanical impulse to the chest. The resulting pressure wave radiates into the chest cavity to shake mucus loose. Because the energy transmitted to the chest vibrations is a multiple of the force applied by hand, the Electro Flo® 6 system acts as a "force multiplier" that provides the therapist with additional control.

    AI/ML Overview

    The provided text is a 510(k) premarket notification for the Electro Flo® 6 Airway Clearance System. This document focuses on demonstrating substantial equivalence to predicate devices rather than proving the device meets specific performance acceptance criteria through clinical studies or extensive standalone testing.

    Therefore, many of the requested details, such as a table of acceptance criteria with reported performance, sample sizes for test sets, expert-established ground truth, adjudication methods, MRMC studies, and detailed standalone algorithm performance, are not applicable or not present in this type of FDA submission document.

    Here's a breakdown based on the information available in the document:

    1. Table of Acceptance Criteria and Reported Device Performance:

    This document does not contain a table of specific performance acceptance criteria for clinical outcomes or diagnostic accuracy per se. Instead, it focuses on demonstrating that the device is substantially equivalent to legally marketed predicate devices in terms of indications for use, intended use, and technological characteristics.

    The "performance data" section (Section XI) refers to bench testing to characterize mechanical performance and verify its nature as a high-frequency chest wall oscillator.

    Performance Metric (Bench Data)Reported Performance (Qualitative)
    Mechanism CategoryAt all settings, most of the power generated was in the acoustic frequency range of 16 - 127 Hz, consistent with High Frequency Chest Wall Oscillation (HFCWO).
    Control of Power OutputVarying the static load could control the power output, as predicted by the force multiplier design principle.

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

    • Test Set Sample Size: Not applicable. The "test set" here refers to bench testing of the device itself, not a clinical patient cohort. The testing involved various settings (frequency, power, static loads) on a single physical device within a controlled laboratory setup.
    • Data Provenance: The bench testing was conducted by Aeromethod Precision Engineering and Manufacturing, San Diego, CA, and analysis was performed by BioMedical Strategies, White River Junction, VT. This is laboratory-generated data, not from patient populations. It is inherently "prospective" in the sense of being planned testing, but not clinical.

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

    Not applicable. For this type of mechanical device and 510(k) submission, "ground truth" is established through engineering and physics principles, and measured physical parameters, not expert human interpretation of complex data (like radiology images). The objective measurements from the bench test served as the data.

    4. Adjudication Method for the Test Set:

    Not applicable. There was no "adjudication" necessary as the test involved objective mechanical measurements.

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

    Not applicable. This device is a therapeutic/clearance system, not a diagnostic AI tool, so a MRMC study is not relevant to its performance demonstration. The submission focuses on comparison to predicate mechanical devices.

    6. Standalone (i.e., algorithm only without human-in-the-loop performance):

    • Yes, in the context of mechanical performance. The "bench data" section describes the standalone mechanical characterization of the device itself.
    • The study demonstrated that the device, on its own when operated, functions as a high-frequency chest wall oscillator and its power output can be controlled.

    7. Type of Ground Truth Used:

    • Engineering/Physics Measurements: The ground truth for the bench testing was objective, quantitative measurements of mechanical output (vibration data, power spectra) collected from the device under controlled laboratory conditions, analyzed based on established engineering and physics principles.

    8. Sample Size for the Training Set:

    Not applicable. This is a physical medical device, not an AI/ML algorithm that requires a "training set" of data in the computational sense. Its design and development would have involved engineering principles and iterative testing, but not "training data" in the AI context.

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

    Not applicable, as there is no "training set" in the AI/ML sense for this device.

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    K Number
    K180843
    Date Cleared
    2019-04-04

    (367 days)

    Product Code
    Regulation Number
    880.5440
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Repro-Med Systems, Inc. dba RMS Medical Products

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

    RMS High-FLO Super26™ Subcutaneous Needle Sets are indicated for subcutaneous infusion of medications in the home, hospital, or ambulatory settings when administered according to the approved biologic or drug product labeling for the capacity for infusion of high flow rates including human plasma-derived immunoglobulins when used according to the FDA approved biologic labeling for: Hizentra®, Immune Globulin Subcutaneous (Human) 20% Liquid (manufactured by CSL Behring); and Cuvitru™ Immune Globulin Infusion (Human) 20% (manufactured by Shire).

    Device Description

    The RMS HIgH-Flo Super26™ Subcutaneous Needle Sets are sterile, non-pyrogenic, single use, Class II Subcutaneous Administration Set, per 21 CFR 880.5440, comprised of a Super 26-gauge needle assembly, combined with 24-gauge needle tubing and are intended for the delivery of medication to the subcutaneous tissue. Each set consists of a sterile infusion set and a commercially available adhesive dressing used to hold the device in place. The infusion set is a 90-degree, 26gauge stainless steel needle, mounted to a butterfly winged safety closure on one end which is used to close the set upon completion. The other end consists of a luer lock which connects to PVC medic al grade tubing (Figure I). Additionally, each tubing set is equipped with a slide clamp used to stop flow, immediately; as needed. RMS HigH-Flo Super 26TM Subcutaneous Needle Sets are available as a single-needle set, as well as 2-needle, 4- needle, 5-needle, 6-needle sets; through use of a Y-connector, 7-needle and 8-needle sets may also be assembled. The device is for single use only.

    AI/ML Overview

    The provided document is a 510(k) premarket notification for a medical device (HIgH-Flo Super26™ Subcutaneous Needle Sets) and focuses on demonstrating substantial equivalence to a predicate device rather than a comprehensive study proving acceptance criteria for a new AI/software-based device.

    Therefore, many of the requested details regarding acceptance criteria for a study proving device performance (e.g., sample size for test set, data provenance, number of experts, adjudication methods, MRMC studies, standalone performance, ground truth establishment) are not applicable to this document as it's primarily a regulatory submission for a physical medical device based on bench testing for an incremental design modification, not a study of an AI algorithm or a diagnostic tool requiring extensive human reader involvement or ground truth establishment in a clinical context.

    However, I can extract information related to the acceptance criteria for this specific device, which are mainly focused on bench performance to demonstrate equivalence.

    Here's an attempt to answer the questions based on the provided text, noting where specific questions are not applicable to this type of regulatory submission:

    Acceptance Criteria and Device Performance Study (Based on 510(k) Submission)

    The study described here is a bench performance study designed to demonstrate that the redesigned device (HIgH-Flo Super26™ Subcutaneous Needle Sets) is substantially equivalent to its predicate device (Integrated Catch-up Freedom Syringe Driver Infusion System) despite differences in tubing diameter and needle set configurations. The primary performance metric assessed is flow rate.

    1. A table of acceptance criteria and the reported device performance

    Given that this is a 510(k) summary for a physical device where the "acceptance criteria" are implicitly meeting functional specifications and demonstrating performance comparable to a predicate, the "acceptance criteria" are not explicitly stated with numerical thresholds in the same way they would be for an AI algorithm's performance metrics (e.g., sensitivity > X%, specificity > Y%). Instead, the "conclusion" is that the device "performs as intended and is substantially equivalent to the predicate device" based on bench testing.

    The reported device performance presented is the achievable flow rates under various conditions (different fluid types, number of needles, and pump settings). The tables themselves represent the performance data that presumably met the implicit acceptance criteria of demonstrating comparable or improved flow for the intended use.

    Implicit Acceptance Criteria (derived from context):

    • Biocompatibility: Device materials must meet ISO 10993 standards and be non-hemolytic.
    • Flow Rate: The device must achieve flow rates suitable for the intended subcutaneous infusion of specified medications (Hizentra, Cuvitru) across various needle configurations and pump settings, and ideally meet or exceed drug manufacturer's recommended flow rates. The stated purpose of the design modification was to allow for "high flow rates."
    • Sterility, non-pyrogenicity, single-use, safety features: These are standard performance and design criteria for such devices.

    Reported Device Performance:

    The document provides tables of "Achievable Flow Rates with Super26™ and Specific Medications/Indications." These tables are the reported performance data. For brevity, only a summary of insights from these tables is provided here, rather than reproducing them entirely:

    Performance Aspect / CriteriaReported Device Performance (HIgH-Flo Super26™)
    BiocompatibilityMeets ISO 10993 requirements. Modified ASTM Hemolysis test showed 0.68% difference in hemolytic index, placing it in a non-hemolytic range. (Based on identical materials and manufacturing to predicate).
    Hizentra - Max Flow Rate Per Site (ml/hr/site) (Example rows)Varied by needle count and pump setting. Examples (F275 pump setting):
    • 1 needle: 19.5 ml/hr/site
    • 4 needles: 5.8 ml/hr/site
    • 8 needles: 3.0 ml/hr/site
      Some combinations "Exceeds drug manufacturer's maximum indicated flow rate." |
      | Hizentra® CIDP - Max Flow Rate Per Site (ml/hr/site) (Example rows) | Varied by needle count and pump setting. Examples (F275 pump setting):
    • 1 needle: 19.5 ml/hr/site
    • 4 needles: 5.8 ml/hr/site
    • 8 needles: 3.0 ml/hr/site
      Some combinations "Exceeds drug manufacturer's maximum indicated flow rate." |
      | Cuvitru™ PI - Max Flow Rate Per Site (ml/hr/site) (Example rows) | Varied by needle count and pump setting. Examples (F275 pump setting):
    • 1 needle: 19.1 ml/hr/site
    • 4 needles: 5.7 ml/hr/site
      Some combinations "Exceeds drug manufacturer's maximum indicated flow rate."
      *Some combinations were "Flow rate per site is lower than what is recommended on the biologic label" (e.g., 1-4 needles at lower F-settings). |

    Note on "Acceptance Criteria" for this submission: The document states, "Bench testing has been conducted to verify that the product performance of the subject device and predicate device are substantially equivalent." The tables of flow rates are the data used to demonstrate this equivalence, implicitly meeting the "acceptance criteria" that the new design performs effectively for its intended use.

    2. Sample size used for the test set and the data provenance

    • Sample Size: Not specified in terms of number of devices tested for flow rates. The text only mentions "Bench Performance Studies" and "Flow Rate Testing." Typical bench testing involves a statistically significant number of samples, but the exact count isn't in this summary.
    • Data Provenance: The data is generated from bench testing conducted by the manufacturer, Repro-Med Systems, Inc. dba RMS Medical Products. It is not clinical data from patients.
    • Retrospective or Prospective: N/A. This is bench testing, not a clinical study.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    • N/A. This is a physical device (subcutaneous needle set) and the "ground truth" for flow rate performance is established through repeatable physical measurements using laboratory equipment (e.g., pumps, timers, volume measurements), not by expert human interpretation of images or other clinical data.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    • N/A. See point 3.

    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 is not an AI/diagnostic device.

    6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done

    • N/A. This is not an AI/diagnostic device.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    • The "ground truth" for the performance (flow rate) is established via direct physical measurement during bench testing. For biocompatibility, it's based on laboratory test results (ISO 10993 series standards, Modified ASTM Hemolysis).

    8. The sample size for the training set

    • N/A. This is not an AI/machine learning device that requires a training set. The device is a physical product for which performance is verified through engineering bench tests.

    9. How the ground truth for the training set was established

    • N/A. See point 8.

    In summary: The provided document is a 510(k) premarket notification for a physical medical device, not an AI or software-based medical device. Therefore, many of the questions related to AI study design, expert ground truth, and human reader studies are not applicable. The "study" proving the device meets acceptance criteria is primarily bench testing to demonstrate functional equivalency, particularly concerning flow rates and biocompatibility, compared to a legally marketed predicate device.

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    K Number
    K162613
    Date Cleared
    2017-08-31

    (346 days)

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

    Repro-Med Systems, Inc., DBA RMS Medical Products

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

    The Integrated Catch-Up Freedom Syringe Driver Infusion System (ICFSDIS), which includes the FREEDOM60® and FreedomEdge® syringe pumps, is indicated for the intravenous infusion of medications and fluids in the home, hospital, or ambulatory settings when administered according to the approved biologic or drug product labeling. The ICFSDIS is specifically indicated for the subcutaneous infusion of the following human plasma-derived immunoglobulins when used according to the FDA approved biologic labeling: Hizentra, Immune Globulin Subcutaneous (Human) 20% Liquid (manufactured by CSL Behring); Gammagard Liquid, Immune Globulin Infusion (Human) 10% (manufactured by Shire); and Cuvitry Immune Globulin Infusion (Human) 20% (manufactured by Shire). The ICFSDIS is specifically indicated for the intravenous infusion of the following antibiotics when used according to the FDA approved drug product labeling: meropenem, ertapenem, oxacillin, and tobramycin.

    The FreedomEdge® Syringe Infusion System is indicated for use with the BD 20 ml (model no. 302830/301031) or BD 30 ml (model no. 30103) syringe. The Freedom60 Syringe Infusion System is indicated for use with the BD 60 ml syringe (model no. 309653).

    Device Description
      1. Freedom60® Syringe Driver: The Freedom60 Syringe Infusion driver in combination with RMS Freedom60 Precision Flow Rate Tubing™ (sterile) and RMS HIgH-Flo Subcutaneous Safety Needle Sets (sterile) makes up the Freedom60 infusion system. The Freedom60® driver is a non-sterile, reusable non-electric driver that infuses immunoglobulins subcutaneously and antibiotic solutions intravenously to patients.
        The Freedom60® driver is an ambulatory device designed to accommodate a BD Luer-Lok™ 60mL Syringe (Catalog No.: 8881-560125, BD 309653), and fluid volumes ranging from 10cc to 60cc may be used. The pump uses a constant force spring mechanism to apply pressure to the plunger-end svringe.

    The Freedom60 system is assembled by loading the prefilled syringe with tubing into the Freemdom60 driver.

      1. FreedomEdge® Syringe Driver: The FreedomEdge® Syringe Infusion driver is used with a syringe in an infusion system for administering therapeutic fluids. The infusion system or related kits can include, in addition to the pump assembly, a luer connector or disc luer connector for connecting the syringe to components of the infusion system, an RMS Precision Flow Rate Tubing™ (sterile) and RMS HIgH-Flo Subcutaneous Safety Needle Sets (sterile) for administering the therapeutic fluid subcutaneously into a patient's body.
        The FreedomEdge® driver is a portable device designed to accommodate BD Luer-Lok™ 20mL syringe, Catalog No.: 302830 and 301031 or BD Luer-Lok™ 30mL, Catalog No.: 301033. The pump uses a constant force spring mechanism to apply pressure to the plunger- end syringe.

    The FreedomEdge® is comprised of housing that has a distal end and a proximal end. The housing comprises an expandable base with a first base section and a second base section. wherein the first base section is in sliding engagement with the second base section such that the first base section and the second base section move relative to each other between a closed position and an expanded position. The base in the expanded position is adapted to seat a syringe with the plunger.

    There is also an expandable cover consisting of a first cover section and a second cover section, wherein the first cover section is in sliding engagement with the second cover section. The cover is pivotally connected to the base at a position allowing the cover to open and close in a sliding motion of the second base section, which is relative to the first base section moving together.

    When the cover is in the closed position, a pusher is in sliding engagement with the base. The pusher is in position to contact the head of the plunger and a puller is in position with the sliding engagement of the base. There is a spring at the first end portion and a second end portion. The first end portion is connected to the puller, while the second end portion is connected to the pusher and a set of linkages pivotally coupled to the cover and the puller.

    The pivots of the linkages are located to move the puller towards the distal end when the cover is lowered and move the puller towards the proximal end when the cover is raised. Moving the puller towards the distal end by lowering the cover when the syringe is seated in the base causes the pusher to contact and exert force on the head of the plunger, thereby causing ejection of any fluid contents in the syringe barrel.

      1. Precision Flow Rate Tubing Set:
        The Freedom60 Infusion system includes a range of Freedom Precision Flow Rate Tubing™. The tubing ranges from F0.5 to F2400. Each F-number provides a different level of flow restriction, which, when combined with the viscosity of the medication, provides a controlled delivery in an all-mechanical system. The tubing sets connect at one end to the syringe being used and on the other end to the Subcutaneous Safety Needle Sets or directly on venous catheters for intravenous infusions as needed.
      1. High-Flo Needles set: The HIgH-FloTM Subcutaneous Safety Needle Sets are used to administer drugs to the subcutaneous layers using small needles attached to the skin. Typical uses are to administer immunoglobulins and antibiotics and for such applications subcutaneous needles come in different lengths.
        Subcutaneous Safety Needle Sets comes in multiple configurations (single, double, tri, and quad). Needles are available in 4mm, 6mm, 9mm, 12mm lengths combined with 24 or 26 Gauge. Using the Y-Connector, the patient can have up to 8 sites for drug delivery.

    The HIgH- Flo™ Subcutaneous Safety Needle Sets also allow each needle to be trapped between the wings after use.

    AI/ML Overview

    Here's an analysis of the provided text regarding the acceptance criteria and study for the Integrated Catch-up Freedom Syringe Driver Infusion System.

    It's important to note that the provided text is a 510(k) Summary, which is designed to demonstrate substantial equivalence to a legally marketed predicate device, rather than a detailed clinical study report proving the device alone meets specific effectiveness criteria through a groundbreaking study. The focus here is on bench testing and compatibility, not human performance or effect size with AI. Therefore, many of your requested points related to human readers, experts, and training sets for an AI/machine learning device are not applicable to this particular document.


    Acceptance Criteria and Device Performance for Integrated Catch-up Freedom Syringe Driver Infusion System

    Based on the provided 510(k) summary, the "acceptance criteria" are primarily demonstrated through performance testing, specifically flow rate testing, and drug-device compatibility testing. The summary doesn't explicitly state quantitative acceptance limits for all parameters, but rather "results showed acceptable" or provides tables of achieved flow rates as evidence of performance.

    1. Table of Acceptance Criteria and Reported Device Performance

    Parameter / AspectAcceptance Criteria (Implied)Reported Device PerformanceStudy that Proves Acceptance
    Safety AssuranceDevice is safe for intended use; risks identified, controlled, mitigated.Safety assurance case provided (design-FMEA, use-FMEA) demonstrating safety. Risks related to operation, hardware/mechanical, use/performance, environment/chemical, and errors are identified and controlled.FMEA documents and safety assurance case.
    Drug-Device Compatibility (Immunoglobulins: Hizentra, Cuvitru)No adverse effects on drug characteristics (appearance, particulates, protein concentration, IgG fragments/polymers/aggregates, anti-complementary activity, density, Fc-function).Results "showed acceptable" for all listed characteristics for Hizentra and Cuvitru.Validated test methods for drug-device compatibility.
    Flow Rate Performance (Hizentra, Cuvitru, Gammagard Liquid - Subcutaneous)Achieve desired infusion rates for indicated immunoglobulin fluids.Detailed tables provided showing achieved flow rates (total and per site) and infusion times for various drug volumes, flow tubes, and needle sets. (See Tables 1-6 in input text for specific values). Devices maintained a constant pressure of 13.5psi and automatically decrease flow with increasing resistance.Detailed flow rate testing.
    Mechanical System PerformanceConsistent pressure delivery; automatic flow rate adjustment to resistance.Operates at a constant pressure of 13.5 psi. Automatically decreases flow rate if resistance increases, reaching an equilibrium.Inherent design and functionality described under "Technological Characteristics," and supported by flow rate testing results.

    Important Note on "Acceptance Criteria": This 510(k) summary focuses on demonstrating substantial equivalence to a predicate device. For areas like drug-device compatibility, the statement "results showed acceptable" implies that the performance met internal benchmarks or recognized standards for maintaining the integrity and efficacy of the drugs. For flow rates, the tables themselves represent the demonstrated performance characteristics under specific conditions, which are then used to inform safe and effective use.


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

    • Sample Size for Test Set: The document does not specify a numerical sample size for the "test set" in terms of how many individual devices, tests, or samples of drugs were used. It refers to "detailed flow rate testing" and "drug-device compatibility testing" without providing the number of units tested or repetitions.
    • Data Provenance: The studies appear to be retrospective in the sense that they are laboratory/bench tests conducted by the manufacturer, rather than prospective clinical trials with human subjects. The country of origin of the data is not explicitly stated but is implicitly from the manufacturer, Repro-med Systems, Inc., DBA RMS Medical Products, located in Chester, New York, USA.

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

    • Not Applicable. This document describes the performance of a mechanical infusion pump system through bench testing and compatibility studies. There is no mention of human experts or ground truth establishment in the context of diagnostic interpretation, as would be relevant for an AI/machine learning device. The "ground truth" for flow rates and drug compatibility comes from physical measurements and chemical analyses, not expert consensus.

    4. Adjudication Method for the Test Set

    • Not Applicable. As there are no human experts involved in establishing a "ground truth" for interpretation, no adjudication method is relevant or mentioned. The data is quantitative from laboratory measurements.

    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 mechanical infusion pump, not an AI/machine learning diagnostic device. Therefore, no MRMC study, human readers, or AI assistance is involved.

    6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done

    • Not Applicable. This device is a mechanical pump, not an algorithm. Its performance is inherently "standalone" in mechanical function, but "human-in-the-loop" applies to its operation by a user, not its analytical process.

    7. The Type of Ground Truth Used

    • The "ground truth" for the performance testing is based on:
      • Direct Physical Measurements: For flow rates (mL/hr) and time taken (hours:minutes), measured during the detailed flow rate testing.
      • Chemical and Biological Assays: For drug-device compatibility (e.g., measuring protein concentration, particulate count, Fc-function of immunoglobulins).
      • Engineering Analysis: For the safety assurance case (FMEA documents).

    8. The Sample Size for the Training Set

    • Not Applicable. This device does not involve a "training set" in the context of machine learning or AI. The design and validation are based on engineering principles, material science, and physical testing, not data training.

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

    • Not Applicable. See point 8.
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    Why did this record match?
    Applicant Name (Manufacturer) :

    REPRO-MED SYSTEMS, INC. DBA RMS MEDICAL PRODUCTS

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

    RMS HigH-Flo™ Subcutaneous Safety Needle Sets are intended for the delivery of medication to the subcutaneous tissue.

    Device Description

    The RMS HIgH-Flo™ Subcutaneous Safety Needle Sets are a Class II Intravascular Administration Set per 21 CFR 880.5440 and intended for the delivery of medication to the subcutaneous tissue. Each set consists of a sterile packaged kit including the infusion set and a commercially available adhesive dressing used to hold the device in place. The infusion set has a 90-degree stainless steel grade needle mounted to a butterfly assembly on one end, and a luer lock on the other end, connected by medical grade tubing. The needles are available in 24 and 26 gauges and in lengths of 4mm, 6mm, 12mm and 14mm. The 4mm and 14mm lengths are added for children and obese adult patients, respectively. The optional convenience 24" Extension Set is used to add length to a needle set when desired.

    There is a snap closure to safely capture the needle after use. This minimizes the potential for a needlestick injury. Each leg in a set is equipped with a slide clamp to stop flow immediately, if needed. The RMS HIgH-Flo™ Subcutaneous Safety Needle Sets are available for up to 8 infusion sites using our basic sets of one, two, three or four legs ganged together using a low residual "Y-Connector" (for example to achieve a 7 site infusion, a RMS 4 set will be ganged with a RMS 3 set using a Y-Connector). All needle sets, regardless of combination, are for single use only.

    AI/ML Overview

    The provided text describes the RMS HIgH-Flo™ Subcutaneous Safety Needle Sets and the studies performed to demonstrate its substantial equivalence to predicate devices, particularly focusing on performance, biocompatibility, and safety.

    Here's the breakdown of the acceptance criteria and study information:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria / Performance AspectDevice Performance (RMS HIgH-Flo™ Subcutaneous Safety Needle Sets)Study/Method to Prove Acceptance
    Biocompatibility
    Systemic Toxicity (Extract - NaCl)Meets acceptable ISO criteriaISO Systemic Toxicity Study
    Systemic Toxicity (Extract - Sesame Oil)Meets acceptable ISO criteriaISO Systemic Toxicity Study
    Subcutaneous Implantation (Rabbits - 6wks)Meets acceptable ISO criteriaISO Subcutaneous Implantation Study
    Non-pyrogenicWithin acceptable USP limits ( and )Pyrogen Study (Material Mediated), Limulus Amebocyte Lysate
    CytotoxicityEqual to, or better than, predicate devicesStudies submitted for predicate K102512
    IrritationEqual to, or better than, predicate devicesStudies submitted for predicate K102512
    SensitizationEqual to, or better than, predicate devicesStudies submitted for predicate K102512
    HemocompatibilityEqual to, or better than, predicate devicesStudies submitted for predicate K102512
    Safety
    Minimized needlestick injury potentialSnap closure safely captures needle after useDevice design, Clinical Simulated Use Study
    Overall safety classificationMet criteria, classified as "safety sets"RMS Clinical Simulated Use Study (per FDA guidance, FDA reviewed protocol)
    No adverse effects/complicationsNo adverse effects or complications reportedRMS Clinical Simulated Use Study
    Critical/Essential task evaluationAll critical and essential tasks evaluated, no difficultiesRMS Clinical Simulated Use Study
    Performance (Flow Rate)
    Flow rate with 7-needle sets (26G)No degradation of flow compared to single 26G setComparison test (26 gauge sets up to 8-needles)
    Leg-to-leg consistency (7th/8th needles)No negative effect on leg-to-leg consistencyAdditional test
    Flow rate with 24 gauge needle setEqual or better flow performance than Evans and MarCal predicate devices (up to 8-needle configurations)Flow testing (24 gauge sets up to 8-needles)
    Flow rate vs. predicate 27G26 gauge RMS HIgH-Flo™ flows betterFlow testing (comparison to predicate 27G)
    Flow rate vs. predicate Evans 24G26 gauge RMS HIgH-Flo™ flows somewhat betterFlow testing (comparison to Evans 24G)
    Flow rate vs. predicate MarCal 24G26 gauge RMS HIgH-Flo™ flows slowerFlow testing (comparison to MarCal 24G)
    Flow rate 24G vs. all predicatesFlows as well as, or better than, any listed predicate devicesFlow testing (comparison to all predicates)
    Flow degradation with 7th/8th 24G needlesNo degradation of flow ratesSecond test (24 gauge, single vs. multiple configurations)
    Flow variation (leg-to-leg 24G)Less than 7%Second test (24 gauge, leg-to-leg consistency)
    Flow with 5cp viscosity fluid (24G)Thicker drugs will flow as designedFlow test (24 gauge with 5cp viscosity fluid)
    Impact of 24" Extension Set (26G)Minor impact on flow rateFlow test
    Residual Volume
    Priming/residual volumesSimilar performance to predicate devices (substantially equivalent)Priming/residual volume measurements
    Sterilization & Shelf Life
    Packaging/product integrity (3-year aging)Acceptable integrity, no degradation of productISO 11137 aging studies (dye migration, bag seal, luer function, needle/hub bond, flexibility, butterfly wing performance, luer/tube integrity)
    Material CharacteristicsIdentical or equivalent medical grade materials as predicatesMaterials Comparison Chart
    Device CharacteristicsEquivalent physical properties, material grade, indications for use, compared to predicates for 4mm and 14mm needle lengthsPredicate Device Comparison Chart
    Needle Tip MeasurementsNo substantial difference from predicate devicesComparison of needle tip dimensions
    Performance Testing (General)Similar performance to predicate devicesNeedle tip, stiffness, resistance to breakage and corrosion, conical fitting, and fatigue tests

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

    The document does not explicitly state the numerical sample size for individual tests within the "Clinical Simulated Use Study" or the flow rate studies. It mentions "medical professionals participated" in the clinical study and "comparative tests" and "flow tested" for the performance studies without giving specific numbers of devices or test runs.

    • Provenance: This is a 510(k) summary submitted to the FDA (United States). The studies appear to be internal RMS Medical Products studies ("RMS internal procedure (SOP 8001)") or performed in accordance with international (ISO) and national (USP) standards, indicating the data is likely from studies conducted by or for the manufacturer. The document doesn't specify countries of origin for the test data beyond the manufacturer's location in New York, USA.
    • Retrospective/Prospective:
      • Biocompatibility and Sterilization/Shelf Life: These are typically prospective laboratory/animal studies.
      • Clinical Simulated Use Study: This was a prospective study ("medical professionals participated in an RMS Clinical Simulated Use Study, per FDA guidance documents with FDA review of the proposed protocol").
      • Performance Testing (flow rate, residual volume, material/device characteristics): These were prospective laboratory tests.

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

    The document mentions "medical professionals participated" in the RMS Clinical Simulated Use Study. However, it does not specify the number or qualifications of these medical professionals, nor does it explicitly define their role in establishing a "ground truth" in the way one might for diagnostic accuracy studies. Their role was to evaluate the device during simulated use, and their subjective and statistical data contributed to the safety determination.

    4. Adjudication Method for the Test Set

    The document does not describe an adjudication method for establishing ground truth from multiple experts. For the "Clinical Simulated Use Study," it states, "An analysis of all subjective and statistical data concludes that the RMS HIgH-Flo™ Subcutaneous Safety Needle Sets met the criteria set." This implies an analysis of the collected data rather than a consensus or adjudication process among multiple reviewers to determine a 'truth' independently.

    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

    • No MRMC Comparative Effectiveness Study: This device is a medical device (subcutaneous needle set), not an AI/diagnostic software. Therefore, an MRMC comparative effectiveness study involving human readers and AI assistance is not applicable and was not performed. The studies focus on the physical performance, biocompatibility, and safety of the needle set itself.

    6. If a Standalone (i.e. algorithm only without human-in-the loop performance) was done

    • Not applicable: As this is a physical medical device and not an AI algorithm, a standalone performance study in the context of AI is not relevant. The device's performance is standalone in the sense that its physical properties (flow rate, material, etc.) are tested without human intervention impacting the measurement of those properties, but it is ultimately used by a human.

    7. The Type of Ground Truth Used

    The concept of "ground truth" in the context of this device's evaluation is primarily based on:

    • Established Scientific Standards: For biocompatibility (ISO standards), pyrogenicity (USP limits), and sterilization (ISO 11137).
    • Pre-defined Acceptance Criteria: For the Clinical Simulated Use Study, criteria were "set" and the device "met the criteria."
    • Direct Measurement and Comparison: For flow rates, residual volumes, material characteristics, device dimensions, and mechanical properties, the "ground truth" is the measured physical data, which is then compared against predicate devices and internal performance expectations.

    8. The Sample Size for the Training Set

    • Not applicable: This device is a physical medical device, not an AI algorithm. Therefore, there is no "training set" in the context of machine learning.

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

    • Not applicable: As there is no training set for an AI algorithm, this question is not relevant.
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    K Number
    K102512
    Date Cleared
    2011-05-20

    (261 days)

    Product Code
    Regulation Number
    880.5440
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    REPRO-MED SYSTEMS, INC.

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

    RMS Subcutaneous Needle Sets are intended for the delivery of medication to the subcutaneous tissue.

    Device Description

    The RMS Subcutaneous Needle Set is a Class II Intravascular Administration Set per 21 CFR 880.5440 and intended for the delivery of medication to the subcutaneous tissue. Each set consists of a sterile packaged kit including the infusion set and a commercially available adhesive dressing used to hold the device in place. The infusion set has a 90-degree stainless steel needle mounted to a butterfly on one end, and a luer lock on the other end, connected by medical grade tubing. Each set is equipped with a slide clamp used to stop flow immediately, as well as a snap together capture arrangement used to close the set upon completion. RMS Subcutaneous Needle Sets are available as single sets, as well as 2-needle, 3-needle, 4-needle, 5-needle and 6-needle assemblies, with the use of a low residual volume Y or multi-connector. The device is for single use only.

    AI/ML Overview

    The provided text describes a 510(k) summary for the RMS Subcutaneous Needle Set, which aims to demonstrate substantial equivalence to predicate devices rather than proving a device meets specific acceptance criteria in the sense of a novel AI or diagnostic device. Therefore, several of the requested sections about AI-specific criteria (e.g., sample size for AI test and training sets, number of experts for ground truth, adjudication methods, MRMC studies) are not applicable to this type of submission.

    However, I can extract information related to performance testing that served to support the claim of substantial equivalence.

    1. Table of Acceptance Criteria and Reported Device Performance

    For a 510(k) submission, the "acceptance criteria" are implicitly defined by demonstrating that the device performs similarly to or better than the legally marketed predicate devices, and that any differences do not raise new questions of safety or effectiveness. The reported performance is compared directly to the predicate devices.

    Performance CharacteristicAcceptance Criteria (Implicit: Comparable or Better than Predicate)RMS Device Performance (K102512)Predicate Device 1 Performance (Evans Medical, K020530)Predicate Device 2 Performance (Marcal Medical, K082818)
    Fluid Flow RateComparable or better than predicate devices1996.35 (Total for 26G)838.98 (Total for 27G), 1988.98 (Total for 24G)4041.17 (Total for 24G)
    Priming/Residual VolumeComparable or better than predicate devicesLower values across all needle counts (e.g., 0.074ml for 1-needle)Higher values across all needle counts (e.g., 0.23ml for 1-needle)Higher values across all needle counts (e.g., 0.15ml for 1-needle)
    Needle Tip DimensionsNo substantial difference from predicate devicesTop Angle: 52.3°, Side Angle: 16.5°, Length: 0.018 inTop Angle: 52.3°, Side Angle: 16.5°, Length: 0.022 inTop Angle: 51.9°, Side Angle: 16.3°, Length: 0.016 in
    Wing FlexibilityEqual or better (less force to flex) than predicate devicesMean: 22 grams (less force)Mean: 39 gramsMean: 48 grams
    Sterility 10-6PASSPASS(Not explicitly stated for predicates, assumed to meet standard)(Not explicitly stated for predicates, assumed to meet standard)
    BiocompatibilityPASS for various tests (Cytotoxicity, Irritation, Sensitization, Hemocompatibility)PASS for all listed tests(Implicitly comparable as per textual claim for thrombogenicity and hemocompatibility)(Implicitly comparable as per textual claim for thrombogenicity and hemocompatibility)
    MaterialsSimilar enough not to raise new issues of safety/effectivenessPVC, Polypropylene, 3M DressingPVC, Polyethylene, 3M DressingPVC, Polyethylene

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

    • Fluid Flow Rate Testing: The table shows results for 4 individual measurements for each needle set configuration (Needle 1, 2, 3, 4). The "Total" represents the sum of these four measurements for each device type. Therefore, a sample size of 4 measurements per device type/configuration was used.
    • Priming/Residual Volume Measurements: Not explicitly stated, but measurements are provided for 1-needle to 6-needle configurations for each device.
    • Needle Tip Measurements: One measurement is provided for each characteristic (Top Angle, Side Angle, Length) for each company.
    • Wing Flexibility: For each of the three manufacturers (RMS, Marcal, Evans Medical), 4 individual "Butterfly" measurements are provided for flexibility, along with a calculated mean.
    • Biocompatibility/Sterility: These are standard compliance tests, typically performed on a statistically significant sample based on the specific ISO standards, but the exact sample sizes for each test are not detailed in this summary.
    • Data Provenance: Not explicitly stated. The tests were performed according to RMS's "Needle Set Fluid Flow Rate Test Procedure" (SOP 5071) and ISO standards. The data is likely from laboratory testing conducted as part of the submission process, not from patient studies or specific geographical regions. It is retrospective in the sense that it was generated for the submission.

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

    This information is not applicable. The device is a medical accessory (subcutaneous needle set), and the testing performed involves objective physical and material performance measurements (e.g., flow rate, volumes, dimensions, flexibility, biocompatibility), not diagnostic image analysis or clinical assessment requiring expert consensus ground truth.

    4. Adjudication Method for the Test Set

    This is not applicable as the tests are objective laboratory measurements, not subjective evaluations requiring adjudication.

    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

    This is not applicable. This is a 510(k) submission for a physical medical device, not an AI/diagnostic software.

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

    This is not applicable. This is a 510(k) submission for a physical medical device.

    7. The Type of Ground Truth Used (Expert Consensus, Pathology, Outcomes Data, etc.)

    The "ground truth" for the performance comparisons in this 510(k) submission consists of objective physical measurements, material properties, and compliance with specified standards (e.g., ISO for sterility and biocompatibility). The predicate devices' performance serves as the benchmark for demonstrating substantial equivalence.

    8. The Sample Size for the Training Set

    This is not applicable as there is no "training set" for physical device performance testing in this context.

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

    This is not applicable as there is no "training set" for physical device performance testing in this context.

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    K Number
    K020529
    Date Cleared
    2002-08-26

    (188 days)

    Product Code
    Regulation Number
    870.4360
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    A-MED SYSTEMS, INC.

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

    The A-Med Large Centrifugal Blood Pump is indicated for pumping blood through the extracorporeal bypass circuit for extracorporeal circulatory support for periods appropriate to cardiopulmonary bypass (up to six hours). It is also indicated for use in extracorporeal circulatory support systems (for periods up to six hours) not requiring complete cardiopulmonary bypass (e.g., valvuloplasty, circulatory support during mitral valve operations, surgery of the vena cava or aorta, liver transplants, etc). The A-Med Large Centrifugal Blood Pump is indicated for use only with the A-Med Blood Pump Controller.

    Device Description

    The A-Med Large Centrifugal Blood Pump is a sterile, disposable, non-pulsatile, non-roller pump that utilizes an impeller to impart energy to the blood through centrifugal forces. The flow of the pump is "demand responsive" by automatically responding to the resistance against which it is pumping and to the amount of fluid returned to the large pump with the appropriate changes in flow and pressure. A drive cable and magnetic coupling are hermetically sealed components of the pump. A motor ultrasonic flow sensor and a microcomputer-based control console are available separately.

    AI/ML Overview

    Acceptance Criteria and Device Performance Study for A-Med Large Centrifugal Blood Pump

    This document outlines the acceptance criteria for the A-Med Large Centrifugal Blood Pump and describes the study that supports its substantial equivalence to predicate devices.

    1. Table of Acceptance Criteria and Reported Device Performance

    The provided 510(k) summary (K020529) does not explicitly list specific acceptance criteria with numerical targets for the A-Med Large Centrifugal Blood Pump. Instead, the submission focuses on demonstrating substantial equivalence to predicate devices based on similarities in intended use, material, design, performance, and physical characteristics.

    The core of the "acceptance" in this context is the FDA's determination of substantial equivalence, meaning the device is "as safe and effective as a legally marketed device."

    Acceptance Criteria CategoryDescription (as inferred from submission)Reported Device Performance (as described in submission)
    Intended UseThe device must be indicated for pumping blood through the extracorporeal bypass circuit for extracorporeal circulatory support for periods appropriate to cardiopulmonary bypass (up to six hours), and for use in extracorporeal circulatory support systems (for periods up to six hours) not requiring complete cardiopulmonary bypass (e.g., valvuloplasty, circulatory support during mitral valve operations, surgery of the vena cava or aorta, liver transplants, etc.). It must also be indicated for use only with the A-Med Blood Pump Controller. This must be substantially equivalent to the predicate devices.The A-Med Large Centrifugal Blood Pump's intended use statement precisely matches the acceptance criteria. It is stated to be "identical in design, material, intended use and technological characteristics to the predicate devices" with the only difference being "size and pressure only." This implies that its functional performance for the stated duration is comparable since the intended use is the same.
    Technological CharacteristicsThe device must be substantially equivalent in design, material, and technological characteristics to the predicate devices. This implies similar principles of operation (non-pulsatile, non-roller, centrifugal impeller), and blood compatibility.The device "is identical in design, material, intended use and technological characteristics to the predicate devices. The difference is size and pressure only." This indicates that the fundamental technology and how it interacts with blood are considered equivalent, despite the physical dimension and the resulting capacity to generate more pressure. The mechanism of being "demand responsive" is also noted as a function.
    Safety and EffectivenessThe device must be demonstrated to be as safe and effective as the predicate devices, despite the larger size and ability to produce more pressure. This would implicitly involve considerations of hemolysis, thrombosis, and adequate flow/pressure delivery for the indicated procedures.The submission explicitly states that "The line extension A-Med Large Centrifugal Blood Pump is substantially equivalent to the predicates in intended use, material, design, performance and physical characteristics." While no specific test data on hemolysis or pressure/flow curves are provided in this summary, the claim of substantial equivalence, particularly regarding "performance," suggests that any necessary testing to demonstrate comparable safety and effectiveness (e.g., concerning blood damage) for the increased size and pressure capability was conducted and found acceptable. The reliance on literature discussing aspects like pulsatile vs. non-pulsatile perfusion, hemorrhagic complications, and hemolytic characteristics of similar pumps (though not directly on this specific device) further suggests a consideration of these safety aspects.
    CompatibilityThe device must be compatible with the A-Med Blood Pump Controller.The indications for use explicitly state that the device "is indicated for use only with the A-Med Blood Pump Controller." This directly confirms the compatibility requirement.

    Description of the Study Proving Acceptance Criteria

    The provided 510(k) summary for the A-Med Large Centrifugal Blood Pump (K020529) does not describe an explicit, dedicated clinical or performance study to prove the device meets specific acceptance criteria in the manner one might expect for a novel device. Instead, the entire submission is a comparative effectiveness argument based on substantial equivalence to predicate devices.

    The study "proving" the device meets the acceptance criteria is effectively the demonstration of substantial equivalence to the A-Med Miniature Centrifugal Blood Pump System (K992592) and the Medtronic Bio-Medicus Centrifugal Blood Pump (K973011).

    The rationale for substantial equivalence is based on the following:

    • Identical Intended Use: The indications for use are described as being the same as the predicate devices.
    • Identical Design, Material, and Technological Characteristics: The device is stated to be "identical in design, material, intended use and technological characteristics to the predicate devices." The only stated difference is "size and pressure only," implying a scaled-up version of an already approved technology.
    • Performance: While not detailed with specific metrics, the claim of substantial equivalence in "performance" implies that the larger pump, despite its increased pressure capability, operates within acceptable parameters for its intended use, similar to its smaller counterpart or the Medtronic predicate. This would implicitly cover aspects like blood flow, pressure generation, and potential for blood damage (hemolysis), though specific test data is not provided in this summary.

    The literature cited (Driessen et al., Glauber et al., Noon et al., Dantas & Costa, Takami et al.) are general medical literature related to cardiopulmonary bypass, centrifugal pumps, and their physiological effects. These references appear to provide background and context for the technology and its implications rather than being specific performance studies conducted on the A-Med Large Centrifugal Blood Pump itself. For instance, Takami et al. discusses hemolytic characteristics of a different gyro centrifugal pump, suggesting these are relevant considerations for this type of device, but not data generated for this device.

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

    Given that this is a substantial equivalence (510(k)) submission relying on comparison to predicate devices and not a de novo clinical trial, there is no "test set" in the traditional sense with a specific sample size of patients or physical devices subjected to a statistical performance study for this specific device.

    The "data provenance" would refer to the existing regulatory approvals and performance data for the two predicate devices (A-Med Miniature Centrifugal Blood Pump System (K992592) and Medtronic Bio-Medicus Centrifugal Blood Pump (K973011)), which would have previously undergone their own approval processes. The current submission leverages the safety and effectiveness established by those prior approvals.

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

    Since there was no dedicated "test set" or de novo clinical study described in this summary requiring expert adjudication for ground truth, this information is not applicable. The "ground truth" for the current submission is the established safety and effectiveness of the predicate devices as determined by prior FDA clearances.

    4. Adjudication Method for the Test Set

    As there was no dedicated "test set" or de novo clinical study, adjudication methods are not applicable.

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

    No MRMC comparative effectiveness study was done or is mentioned in the provided 510(k) summary. This type of study is typically associated with AI/imaging devices where human interpretation is a key component, and the impact of AI assistance on human performance needs to be quantified. The A-Med Large Centrifugal Blood Pump is a medical device (a mechanical pump), not an AI-assisted diagnostic tool.

    6. Standalone Performance Study (Algorithm Only)

    Not applicable. This device is a mechanical blood pump, not an algorithm. Therefore, there is no "standalone (algorithm only)" performance to evaluate. The device inherently involves a human operator (surgeon/perfusionist) during its use, but its core function is mechanical.

    7. Type of Ground Truth Used

    The "ground truth" for this substantial equivalence determination is the regulatory precedent and established safety and effectiveness of the legally marketed predicate devices. The device's "acceptance" is based on its demonstrated similarity (in function, material, design) to devices already deemed safe and effective by the FDA. This is a common approach for Class II and Class III (pre-amendments, 510k pathway) devices where a new device doesn't raise new questions of safety or effectiveness.

    8. Sample Size for the Training Set

    Not applicable. As this is a mechanical medical device submission and not a machine learning model, there is no "training set."

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

    Not applicable. As there is no training set for an algorithm, the concept of establishing ground truth for it does not apply here.

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    K Number
    K013393
    Date Cleared
    2001-11-09

    (25 days)

    Product Code
    Regulation Number
    870.4360
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    A-MED SYSTEMS, INC.

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

    The A-Med Heparin Coated Miniature Centrifugal Blood Pump System is indicated for use in extracorporeal circulatory support systems (for periods up to six hours) not requiring artificial oxygenation (e.g., valvuloplasty, circulatory support during surgery of the vena cava or aorta, liver transplants, etc). The A-Med Heparin Coated Miniature Centrifugal Blood Pump is indicated for use only with the A-Med Blood Pump Controller.

    Device Description

    The A-Med Heparin Coated Miniature Centrifugal Blood Pump is a sterile, disposable, non-pulsatile, non-roller pump that utilizes an impeller to impart energy to the blood through centrifugal forces. The flow of the pump is "demand responsive" by automatically responding to the resistance against which it is pumping and to the amount of fluid returned to the large pump with the appropriate changes in flow and pressure. A drive cable and magnetic coupling are hermetically sealed components of the pump. The coating which A-Med propose to add to the pump will be a photoactivated hydrogel surface modification. The process uses light activated chemistry to coat the device. A motor ultrasonic flow sensor and a microcomputer-based control console are available separately.

    AI/ML Overview

    The provided text is a 510(k) summary for a medical device called the "A-Med Heparin Coated Miniature Centrifugal Pump System." It describes the device, its intended use, and its similarities to a predicate device. However, it does not contain the detailed information necessary to fully answer all aspects of your request regarding acceptance criteria and a study proving the device meets those criteria.

    Here's what can be extracted and what is missing:

    1. A table of acceptance criteria and the reported device performance

    This information is not present in the provided text. The submission focuses on demonstrating substantial equivalence to a predicate device, primarily due to the addition of a heparin coating. It does not include specific performance metrics, acceptance criteria, or their corresponding test results for the heparin-coated device.

    2. Sample size used for the test set and the data provenance

    This information is not present in the provided text. No specific test sets or study data are detailed.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    This information is not present in the provided text. Since no specific test set or study is described, there's no mention of experts establishing ground truth.

    4. Adjudication method for the test set

    This information is not present in the provided text.

    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

    A MRMC study is not applicable to this device. This device is a centrifugal blood pump, not an AI-powered diagnostic or interpretive tool that would involve human readers.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    This information is not applicable to this device. This is a medical device (centrifugal pump), not an algorithm.

    7. The type of ground truth used

    This information is not present in the provided text.

    8. The sample size for the training set

    This information is not present in the provided text.

    9. How the ground truth for the training set was established

    This information is not present in the provided text.

    Summary of available information from the document:

    • Device: A-Med Heparin Coated Miniature Centrifugal Pump System
    • Predicate Device: A-Med Miniature Centrifugal Blood Pump System (K992592)
    • Key Change: Addition of a photoactivated hydrogel surface modification (heparin coating).
    • Basis for Equivalence: Similarities to the predicate device in intended use, material, design, performance, and physical characteristics. The heparin coating is the only change and is stated not to impact the currently cleared indication.
    • Intended Use: Extracorporeal circulatory support systems (up to six hours) not requiring artificial oxygenation (e.g., valvuloplasty, circulatory support during surgery of the vena cava or aorta, liver transplants, etc.). For use only with the A-Med Blood Pump Controller.

    Conclusion:

    The provided 510(k) summary focuses on demonstrating substantial equivalence through a comparison of the modified device (with heparin coating) to an existing predicate device. It explicitly states that the modification (heparin coating) is the only change to the existing device and that it does not impact the currently cleared indication. This type of submission typically relies on showing that the new modification does not negatively alter the fundamental safety and effectiveness demonstrated by the predicate device, often without presenting new, extensive clinical or performance studies with detailed acceptance criteria in the summary itself. The detailed performance data, acceptance criteria, and specific study results that would typically answer your questions are not included in this high-level regulatory summary.

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    K Number
    K992592
    Date Cleared
    2000-05-04

    (276 days)

    Product Code
    Regulation Number
    870.4360
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    A-MED SYSTEMS, INC.

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

    The A-Med Miniature Centrifugal Blood Pump System is indicated for use in extracorporeal circulatory support systems (for periods up to six hours) not requiring artificial oxygenation (e.g., valvuloplasty, circulatory support during surgery of the vena cava or aorta, liver transplants, etc.). The A-Med Miniature Centrifugal Blood Pump is indicated for use only with the A-Med Blood Pump Controller.

    Device Description

    The A-MED Miniature Centrifugal Pump is a sterile, disposable, non-roller pump which utilizes a rotor to impart energy to the blood through centrifugal forces. The flow of the miniature pump is "demand responsive" by automatically responding to the resistance against which it is pumping and to the amount of fluid returned to the miniature pump with the appropriate changes in flow and pressure. A drive cable and magnetic coupling are hermetically sealed components of the miniature pump.

    The A-MED Miniature Centrifugal Pump System includes a motor, ultrasonic flow sensor and a microcomputer-based control console which are available separately. The Miniature pump consists of inner and outer housings containing a rotor which imparts energy to the pumping fluid through centrifugal forces. The inlet to the pump runs concentric with the axis of the rotor. The outlet of the pump is perpendicular to the inlet and tangent to the outer diameter. The shaft of the rotor is constrained by two sets of bearings that allow it to rotate freely. A lip seal is used just behind the rotor to seal fluid from entering into the bearing area.

    A sheath cable assembly connects the pump to the drive motor. The pump end of the cable has a square drive shaft that is bonded and crimped to the cable. This drive shaft fits into a square opening in the end of the rotor. The other end of the cable is connected to a magnet rotor housed in a plastic shell. This end is assembled onto the motor-stator for operation. By assembling the magnet rotor into the end of the cable-sheath assembly, hermitic sealing of the pumping chamber is obtained.

    A priming port (valve) is provided on the housing to clear the pump of air before starting circulation. The port is designed to open when a syringe is inserted and seals when the syringe is removed.

    The pump is designed to be placed in the sterile field and operated from the A-Med remote motor and microcomputer based blood pump controller, located outside the sterile field. The A-Med Centrifugal Pump System also includes an ultrasonic flow meter, manufactured by Transonics, Inc.

    AI/ML Overview

    This document is a 510(k) summary for the A-Med Miniature Centrifugal Pump System. It provides information about the device's substantial equivalence to predicate devices, but it does not contain acceptance criteria or a study proving the device meets acceptance criteria.

    Therefore, I cannot provide the requested information. The document focuses on demonstrating substantial equivalence to previously cleared devices rather than presenting specific performance metrics and associated studies.

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    K Number
    K991541
    Date Cleared
    1999-12-28

    (239 days)

    Product Code
    Regulation Number
    870.4210
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    A-MED SYSTEMS, INC.

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

    The A-Med Vascular Cannula is intended for use in accessing the circulatory system during extracorporeal circulation.

    The A-Med Vascular Cannula is intended for intraoperative access to the arterial (i.e., aorta, femoral artery or pulmonary artery) or venous system. (i.e., femoral vein, right atrium) during procedures requiring arterial or venous access for short term extracorporeal support (less than six hours). Arterial or venous access is left to the discretion of the physician.

    Device Description

    The A-Med Vascular Cannula is a cannula comprised of a flexible tip, radiopaque stripes, wire reinforced tubing, non-reinforced proximal clamp zone, and a proximal connector. Configurations are available with the following options:

    • . Outer diameter: 24 French
    • . Effective length: 10, 21 inch
    • Number of holes in tip: 8, 16, 32, 44 (dependant on length) ●
    • Proximal connector: barb, barb with side luer lock, quick connect ●
    AI/ML Overview

    The provided 510(k) premarket submission for the A-Med Systems, Inc. Vascular Cannula (K991541) does not contain acceptance criteria or study details in the requested format for AI/software-as-a-medical-device (SaMD) products.

    This submission is for a physical medical device (a vascular cannula) and follows the regulatory pathway for such devices, primarily relying on non-clinical performance testing and substantial equivalence to a predicate device.

    Therefore, many of the requested fields are not applicable to this submission. I will address the applicable parts based on the provided text, and explicitly state when a requested piece of information is not available or not relevant to this type of device submission.

    Acceptance Criteria and Study to Prove Device Meets Criteria

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Explicitly Stated)Reported Device Performance
    Substantial equivalence to predicate device (Baxter/RMI FEM FLEX II Cannula K891576, K974259)Achieved; "The performance of this device is substantially equivalent to the predicate device and performs as intended."
    Compliance with A-Med Systems, Inc. performance specificationsAchieved; "performance characteristics of this device were tested and compared with A-Med Systems, Inc. performance specifications."
    No clinical testing required for intended useNot applicable; "Clinical testing was not performed on this device."

    2. Sample size used for the test set and the data provenance

    • Not Applicable in the context of SaMD. For this physical device, the "test set" refers to the specific cannulas and materials used in the non-clinical performance tests (e.g., mechanical strength, flow rates, material compatibility). The document does not specify the number of units tested.
    • Data Provenance: The tests were conducted internally by A-Med Systems, Inc. (implied by "A-Med Systems, Inc. performance specifications"). The country of origin for the data is not explicitly stated but is presumed to be the United States, given the submitter's address. The data is "prospective" in the sense that the tests were performed specifically for this submission, not a retrospective analysis of existing data.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    • Not Applicable. For a physical device like a vascular cannula, "ground truth" in the SaMD sense (e.g., expert consensus on image interpretation) is not established. Performance is measured directly (e.g., flow rates, material properties, mechanical integrity) against specifications validated by engineering and regulatory standards. The expertise involved would be in engineering, material science, and quality assurance, rather than clinical interpretation.

    4. Adjudication method for the test set

    • Not Applicable. Adjudication methods (like 2+1, 3+1) are used for resolving discrepancies in expert interpretations, typically in studies involving subjective assessments (e.g., radiology reads). This is not relevant for the non-clinical performance 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

    • No. This is a physical medical device, not an AI/software device designed to assist human readers. Therefore, an MRMC study is not relevant or applicable.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    • No. This is a physical medical device, not an algorithm. Therefore, "standalone performance" in the SaMD context is not applicable.

    7. The type of ground truth used

    • Engineering Specifications and Predicate Device Performance: The "ground truth" for this device's performance is established by:
      • Comparison to the performance characteristics of the legally marketed predicate device (Baxter/RMI FEM FLEX II Cannula).
      • Adherence to internal A-Med Systems, Inc. performance specifications, which would be derived from engineering requirements, material standards, and clinical needs for such a device.
      • This is not "expert consensus," "pathology," or "outcomes data" in the typical SaMD sense.

    8. The sample size for the training set

    • Not Applicable. This is a physical device, not a machine learning algorithm. There is no concept of a "training set" for manufacturing and testing a vascular cannula for regulatory submission in this context.

    9. How the ground truth for the training set was established

    • Not Applicable. As there is no training set, this question is not relevant.
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