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510(k) Data Aggregation
(42 days)
The Advocate PTA Catheter is intended for balloon dilation of the illac, femoral, popliteal, renal arteries and for the treatment of obstructive lesions of native or synthetic arteriovenous dialysis fistulae.
The Advocate PTA Catheter consists of two lumens, a compatible guidewire lumen (0.014", 0.018" or 0.035") extending from guide wire port in the manifold to the catheter distal tip, and an inflation lumen extending from the proximal inflation port in the manifold to the balloon interior. There are various size balloons in the product matrix, ranging from 2.0-12.0mm in diameter and 15-300mm in length. The catheter has two radiopaque marker bands that facilitate visibility and location during the placement and inflation of the balloon. The catheter is inserted through a 4Fr, 5Fr, 6Fr or 7Fr haemostatic or non haemostatic introducer, depending on the model selected.
This document describes the Advocate PTA Catheter and its 510(k) premarket notification (K192907). It addresses a change in manufacturing location and an expansion of the Indications for Use. The relevant information provided focuses on the safety and performance testing related to these changes.
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly provide a table of acceptance criteria with corresponding device performance metrics for the expanded indications for use. Instead, it states that "extra Validation testing was done on the device to qualify the expanded indications for use" and lists the types of tests successfully completed. This implies that the tests performed met internal acceptance criteria for demonstrating safety and performance.
| Acceptance Criteria (Implied) | Reported Device Performance |
|---|---|
| Device successfully navigates anatomical pathways (AVF) | Deliverability (AVF Trackability) - Successfully completed |
| Device demonstrates sufficient force transmission for advancement | Deliverability (Pushability) - Successfully completed |
2. Sample Size for the Test Set and Data Provenance
The document does not specify the sample size used for the test set (i.e., the number of catheters or tests performed for Deliverability AVF Trackability and Pushability).
The data provenance is not explicitly stated in terms of country of origin. The study appears to be prospective testing conducted by Merit Medical Systems, Inc. to qualify the expanded indications for use and the manufacturing location change.
3. Number of Experts Used to Establish Ground Truth and Their Qualifications
This information is not applicable as the document describes physical performance testing of a medical device, not a diagnostic or AI-based study requiring expert ground truth establishment for a test set.
4. Adjudication Method for the Test Set
This information is not applicable as the document describes physical performance testing of a medical device, not a study requiring adjudication of expert opinions.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
This information is not applicable. The document describes the testing of a medical device (PTA Catheter), not an AI algorithm. Therefore, no MRMC study or comparison of human readers with/without AI assistance was performed.
6. Standalone (Algorithm Only) Performance Study
This information is not applicable. The document describes the testing of a medical device (PTA Catheter), not an AI algorithm.
7. Type of Ground Truth Used
This information is not applicable in the context of expert consensus, pathology, or outcomes data. For the physical performance tests, the "ground truth" would be the engineering specifications and expected performance characteristics of the device, assessed through laboratory testing.
8. Sample Size for the Training Set
This information is not applicable as the document describes the testing of a medical device, not an AI algorithm that requires a training set.
9. How the Ground Truth for the Training Set Was Established
This information is not applicable as the document describes the testing of a medical device, not an AI algorithm that requires a training set and ground truth establishment.
Summary of Key Information from the Document:
- Device: Advocate PTA Catheter
- Purpose of Submission (K192907): Change in Indications for Use and manufacturing location.
- Expanded Indications for Use: Balloon dilation of iliac, femoral, popliteal, infra-popliteal, renal arteries and treatment of obstructive lesions of native or synthetic arteriovenous dialysis fistulae.
- Testing Performed to Qualify Expanded Indications: Deliverability (AVF Trackability) and Deliverability (Pushability).
- Outcome of Testing: Successfully completed.
- Manufacturing Change: Moved from a subcontractor (Arravasc) to Merit Medical in Galway, using the same qualified processes.
- The document implies that the successful completion of the listed safety and performance tests demonstrates that the device meets the necessary acceptance criteria for the expanded indications. However, it does not provide detailed quantitative acceptance criteria or specific numerical results.
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(68 days)
The Merit S-MAK XL™ is intended for percutaneous placement of up to a 0.038" (.097mm) guide wire or catheter into the vascular system.
The S-MAK XL TM utilizes a small diameter coaxial introducer/dilator pair and guide wire for placement of larger diameter guide wires into the vasculature system when a small needle stick is preferred. The S-MAK XL TM consists of the following components: One (1) 4F Coaxial Introducer/Dilator Pair (30 cm length) One (1) 21 gauge Introducer Needle One (1) 0.018" (0.46mm) 80cm Nitinol/Palladium Guide Wire
The provided text describes the 510(k) summary for the S-MAK XL™ device. Based on the information available, a study was conducted to demonstrate the device's substantial equivalence to predicate devices, focusing on performance and biocompatibility.
Here's an analysis of the acceptance criteria and the study that proves the device meets them:
1. A table of acceptance criteria and the reported device performance
The document does not explicitly state "acceptance criteria" in a quantified table format for each test. Instead, it lists the types of performance and biocompatibility tests conducted and states that "Passing results were demonstrated on all tests above." We can infer the acceptance criterion for each test was a "passing result" according to the specified international standards and guidance documents.
| Category | Test Performed | Acceptance Criteria (Inferred) | Reported Device Performance |
|---|---|---|---|
| Performance - Bench | Effective Length Introducer and dilator | Passing result per standard | Demonstrated Passing Results |
| Guide wire insertion dilator | Passing result per standard | Demonstrated Passing Results | |
| Catheter insertion - introducer | Passing result per standard | Demonstrated Passing Results | |
| Biocompatibility | Cytotoxicity - Cytoxicity Study Using ISO Elation Method: MEM Extraction | Passing result per ISO 10993-5:2009 | Demonstrated Passing Results |
| Sensitization - ISO Guinea Pig Maximization Test: Sodium Chloride and Sesame Oil Extraction | Passing result per ISO 10993-10:2010 | Demonstrated Passing Results | |
| Irritation - ISO Intracutaneous Study in Rabbits: Sodium Chloride and Sesame Oil Extraction | Passing result per ISO 10993-10:2010 | Demonstrated Passing Results | |
| Acute Systemic Toxicity - ISO Acute Systemic Toxicity Study in Mice: Sodium Chloride and Sesame Oil Extraction | Passing result per ISO 10993-11 (implied) | Demonstrated Passing Results | |
| Pyrogenicity - USP Rabbit Pyrogen Study, Material Mediated: Nonpyrogenic 0.9% Sodium Chloride Extraction | Passing result per USP | Demonstrated Passing Results | |
| Hemocompatibility - ASTM Hemolysis Study Direct Contact and Extract O Method: Phosphate Buffered Saline Extraction | Passing result per ASTM | Demonstrated Passing Results | |
| Hemocompatibility - Indirect Contact Complement Activation Assay | Passing result per standard | Demonstrated Passing Results | |
| Hemocompatibility - In-vitro Assessment of Introducer Thrombosis | Passing result per standard | Demonstrated Passing Results | |
| Sterilization & Packaging | ISO 11135:2014, Sterilization of health care products - Ethylene oxide | Compliance | Implied Compliance |
| ISO 11070:1998, Sterile, single use intravascular catheter introducer | Compliance | Implied Compliance | |
| ISO 10993-7:2008, Biological Evaluation of Medical Devices - Part 7 Ethylene Oxide sterilization residuals | Compliance | Implied Compliance | |
| AAMI/ANSI/ISO 11607-1:2006, Packaging for terminally sterilized medical devices | Compliance | Implied Compliance | |
| ASTM D4169-16, Standards Practice for Performance Testing of Shipping Containers and Systems | Compliance | Implied Compliance | |
| ISO 2233 (2000), Packaging - Complete, filled transport packages and unit loads | Compliance | Implied Compliance |
2. Sample size used for the test set and the data provenance
The document does not explicitly state the sample sizes used for each performance and biocompatibility test set. The provenance of the data is implied to be from laboratory testing conducted according to the listed international standards (e.g., ISO, ASTM, USP). There is no information about the country of origin of the data or whether it was retrospective or prospective.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This information is not applicable to the type of testing performed for the S-MAK XL™. The tests are primarily physical, chemical, and biological evaluations, not requiring expert human interpretation to establish a ground truth in the way medical imaging or diagnostic studies might. The "ground truth" is inherently defined by the technical specifications and standards (e.g., a device either passes a tensile strength test or it doesn't).
4. Adjudication method for the test set
Not applicable. The tests are objective and based on established international standards, not requiring adjudication by multiple experts.
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. The S-MAK XL™ is a medical device (vessel dilator/introducer sheath), not an AI-powered diagnostic tool. Therefore, an MRMC comparative effectiveness study involving human readers or AI assistance would not be relevant.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
Not applicable. The S-MAK XL™ is a physical medical device, not an algorithm or software. Therefore, standalone algorithm performance testing is not relevant.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
The ground truth for the performance tests and biocompatibility tests is based on adherence to the specified international standards and guidance documents (e.g., ISO, ASTM, USP). For instance, for cytotoxicity, the ground truth is whether the device extract causes a cytotoxic effect within defined parameters. For physical performance, the ground truth is whether the device meets its design specifications (e.g., correct length, ability to insert guide wire).
8. The sample size for the training set
Not applicable. As a physical medical device, the S-MAK XL™ does not involve machine learning algorithms that require a "training set."
9. How the ground truth for the training set was established
Not applicable, as there is no training set for this type of device.
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(21 days)
The Advocate PTA Catheter is intended for balloon dilation of the iliac, femoral, popliteal, and renal arteries.
The Advocate PTA Catheter consists of two lumens, a compatible guidewire lumen (0.014", 0.018" or 0.035") extending from guide wire port in the manifold to the catheter distal tip, and an inflation lumen extending from the proximal inflation port in the manifold to the balloon interior. There are various size balloons in the product matrix, ranging from 2.0-12.0mm in diameter and 20-300mm in length. The catheter has two radiopaque marker bands that facilitate visibility and location during the placement and inflation of the balloon. The catheter is inserted through a 4Fr, 5Fr, 6Fr or 7Fr haemostatic or non haemostatic introducer, depending on the model selected.
The provided document is a 510(k) premarket notification decision letter from the FDA to Merit Medical Systems, Inc. regarding the Advocate PTA Catheter. It outlines the regulatory classification, intended use, and substantial equivalence to predicate devices.
Crucially, this document is for a physical medical device (a catheter for angioplasty), not a software or AI-based medical device. Therefore, the specific questions related to AI/software performance, such as acceptance criteria, sample sizes for test/training sets, expert ground truth establishment, MRMC studies, and standalone algorithm performance, are not applicable to the information contained within this document.
The document explicitly states: "No Safety or Performance testing is required to establish the safety and efficacy of the subject device." This is because the device is being marketed as substantially equivalent to existing predicate devices (Pirouette 014, 018, and 035) with "no technological differences" and manufactured by the "same Manufacturer who makes the identical device under the Pirouette name." The only difference noted is the naming and labeling of the product.
Therefore, I cannot provide the requested information based on this document. The questions you posed are relevant for AI/software medical devices, which typically require extensive validation studies to demonstrate performance.
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(30 days)
Merit Medical guide wires are used to facilitate the placement of devices during diagnostic and interventional procedures.
Merit InQwire® Amplatz Super Stiff Guide Wires are intended to facilitate the placement of devices during diagnostic and interventional procedures. The guide wires consist of a Blue PTFE (Polytetrafluoroethylene) coated flat wire coil, with an inside core wire. The core wire enhances the "Super Stiff" characteristic of the guide wire. The core wire extends the full length of the coil and is welded to the coil at three (3) points; a) the distal end, b) the proximal end and c) a spot weld approx. 22cm from the distal end. These welds are designed to provide integrity and ensure that the guide wire components remain together The outside coil is PTFE coated and this Blue PTFE coating extends from the distal tip of the wire to within 7cm of the proximal tip, which remains uncoated. The Merit InQwire® Amplatz Super Stiff Guide Wires are offered in 0.035-inch and 0.038-inch outer diameter with a 1cm, 3cm, 3.5cm ,4cm, 6cm and 7cm straight and J tip configuration and are available in lengths from 75cm to 260cm. The wires will be provided in a spiral hoop dispenser sized appropriately for the wires diameter and length. The dispenser has a standard flush port luer adapter that accepts any standard luer lock or slip tip syringe to facilitate flushing of the guide wire prior to use. A J-straightener is provided on the dispenser to facilitate the advancement of the wire tip into other devices.
The provided text describes testing conducted for the InQwire Amplatz Super Stiff Guide Wire (K170700) to demonstrate its substantial equivalence to predicate devices, not specifically for a software algorithm. Therefore, many of the requested categories related to AI performance, ground truth, and expert evaluation are not directly applicable.
However, I can extract the information that is present regarding the acceptance criteria and the study performed for this medical device.
1. Table of acceptance criteria and the reported device performance
| Test Parameter | Acceptance Criteria | Reported Device Performance |
|---|---|---|
| Radiopacity | Based on risk analysis, guidance documents, and industry standards (e.g., FDA guidance Coronary and Cerebrovascular Guide Wire Guidance, ISO 11070:2014) | "All test results were comparable to the predicate devices and the subject Merit InQwire® Amplatz Super Stiff Guide Wire met the predetermined acceptance criteria." |
| Tensile Strength | Based on risk analysis, guidance documents, and industry standards | "All test results were comparable to the predicate devices and the subject Merit InQwire® Amplatz Super Stiff Guide Wire met the predetermined acceptance criteria." |
| Torque Strength | Based on risk analysis, guidance documents, and industry standards | "All test results were comparable to the predicate devices and the subject Merit InQwire® Amplatz Super Stiff Guide Wire met the predetermined acceptance criteria." |
| Tip Flexibility | Based on risk analysis, guidance documents, and industry standards | "All test results were comparable to the predicate devices and the subject Merit InQwire® Amplatz Super Stiff Guide Wire met the predetermined acceptance criteria." |
| Coating Adherence/Integrity | Based on risk analysis, guidance documents, and industry standards | "All test results were comparable to the predicate devices and the subject Merit InQwire® Amplatz Super Stiff Guide Wire met the predetermined acceptance criteria." |
| Catheter and Needle Compatibility | Based on risk analysis, guidance documents, and industry standards | "All test results were comparable to the predicate devices and the subject Merit InQwire® Amplatz Super Stiff Guide Wire met the predetermined acceptance criteria." |
| Lubricity | Based on risk analysis, guidance documents, and industry standards | "All test results were comparable to the predicate devices and the subject Merit InQwire® Amplatz Super Stiff Guide Wire met the predetermined acceptance criteria." |
| Fracture | Based on risk analysis, guidance documents, and industry standards | "All test results were comparable to the predicate devices and the subject Merit InQwire® Amplatz Super Stiff Guide Wire met the predetermined acceptance criteria." |
| Flex | Based on risk analysis, guidance documents, and industry standards | "All test results were comparable to the predicate devices and the subject Merit InQwire® Amplatz Super Stiff Guide Wire met the predetermined acceptance criteria." |
| Particulate Evaluation | Based on risk analysis, guidance documents, and industry standards | "All test results were comparable to the predicate devices and the subject Merit InQwire® Amplatz Super Stiff Guide Wire met the predetermined acceptance criteria." |
| Surface | Based on risk analysis, guidance documents, and industry standards | "All test results were comparable to the predicate devices and the subject Merit InQwire® Amplatz Super Stiff Guide Wire met the predetermined acceptance criteria." |
| Biocompatibility | Based on ISO 10993-1:2009 and FDA Modified ISO 10993 Test Profile G95-1 | "All test results were comparable to the predicate devices and the subject Merit InQwire® Amplatz Super Stiff Guide Wire met the predetermined acceptance criteria." |
| Corrosion | Based on risk analysis, guidance documents, and industry standards | "All test results were comparable to the predicate devices and the subject Merit InQwire® Amplatz Super Stiff Guide Wire met the predetermined acceptance criteria." |
| Tip Shape | Based on risk analysis, guidance documents, and industry standards | "All test results were comparable to the predicate devices and the subject Merit InQwire® Amplatz Super Stiff Guide Wire met the predetermined acceptance criteria." |
| Sterilization (Ethylene Oxide) | Based on ISO 11135:2014 | Not explicitly detailed, but implied to be met as part of "All test results..." |
| Packaging (Shelf Life, Integrity) | Based on ASTM F1980-07 and ISO 11607-1:2006 | Not explicitly detailed, but implied to be met as part of "All test results..." |
2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
The document does not specify the exact sample sizes used for each performance test. It states that "A battery of testing was conducted" and implies these were laboratory-based tests comparing the subject device to existing predicate devices.
- Sample Size: Not specified.
- Data Provenance: The tests are implied to be conducted by the manufacturer, Merit Medical Systems, Inc., which has locations in South Jordan, UT, USA, and Galway, Ireland. The data is from laboratory testing of the physical device, not patient data (retrospective or prospective).
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
This is a physical medical device, not an AI/software device requiring expert interpretation of results for ground truth. Therefore, this information is not applicable. Ground truth was established through validated engineering and scientific testing methods against established standards.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This is not applicable as it refers to expert consensus for interpreting results, which is not relevant for the performance testing of a physical guide wire.
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 as this is not an AI/software device.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This is not applicable as this is not an AI/software device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
The ground truth for the reported tests was established by:
- Reference to predicate devices (Merit InQwire® Amplatz Super Stiff Guide Wire [K163575] and Amplatz Super Stiff Guidewire [K843012]).
- Adherence to industry standards and guidance documents (e.g., FDA guidance Coronary and Cerebrovascular Guide Wire Guidance, ISO 11070:2014, ISO 11135:2014, ASTM F1980-07, ISO 10993-1:2009, ISO 11607-1:2006).
- Risk analysis.
The "ground truth" for a physical device is its measurable physical and chemical properties and performance characteristics against established benchmarks.
8. The sample size for the training set
This is not applicable as this is not an AI/software device.
9. How the ground truth for the training set was established
This is not applicable as this is not an AI/software device.
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(142 days)
The Merit plastic jacketed introducer guide wire is intended to facilitate the placement of devices during diagnostic and interventional procedures, specifically sheath introducers. The wire is indicated for the peripheral vasculature only.
The Merit Prelude Plastic jacketed introducer guide wire consists of a high quality metallic core wire with a radiopaque polymer jacket. The wire will be offered in straight and angled versions, in various lengths.
The provided document is a 510(k) Summary for a medical device (Prelude Plastic Jacketed Guide Wire). It describes the device, its intended use, comparison to a predicate device, and a summary of safety and performance tests. However, it does not contain a detailed table of acceptance criteria and reported device performance with specific values. Instead, it broadly states that tests were conducted according to standards and met acceptance criteria.
Therefore, many of the requested elements cannot be fully extracted or are explicitly stated as not applicable to this type of submission.
Here's an analysis based on the information available:
1. A table of acceptance criteria and the reported device performance
The document does not provide a specific table with quantitative acceptance criteria and corresponding reported device performance values. It generally states that "A battery of testing was conducted in accordance with protocols based on requirements outlined in guidance's and industry standards and these were shown to meet the acceptance criteria that were determined to demonstrate substantial equivalence."
It lists the types of tests performed in the "Safety & Performance Tests" section, but without specific criteria or results.
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
The document does not specify the sample sizes used for the test set or the data provenance. This level of detail is typically found in the full test reports, not usually in the 510(k) summary.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable to this type of device (guide wire). The "tests" are primarily physical, chemical, and biological evaluations, not diagnostic assessments requiring expert interpretation of images or patient data.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. 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
Not applicable. This device is a medical instrument (guide wire), not an AI/software device that assists human readers.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
Not applicable. This is not an algorithm or AI device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
For the performance tests listed (e.g., tensile strength, flexibility, biocompatibility), the "ground truth" would be established by the defined test methodologies and expected physical/chemical properties as outlined in the referenced standards (e.g., ISO, ASTM, USP). For example, a "fracture test" would have an acceptance criterion that the wire should not fracture under certain conditions, and the "ground truth" would be the observation of fracture or no fracture.
8. The sample size for the training set
Not applicable. This type of device does not involve a "training set" in the context of machine learning or AI.
9. How the ground truth for the training set was established
Not applicable. See point 8.
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