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510(k) Data Aggregation

    Why did this record match?
    Applicant Name (Manufacturer) :

    Nuwellis, Inc.

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

    The Dual Lumen Extended Length Catheter (dELC) is indicated for use up to 72 hours in attaining vascular venous access for use with the Aquadex FlexFlow® and Aquadex SmartFlow® systems for ultrafiltration therapy. It is not for pediatric use. The catheter is not intended for the infusion of medications or fluids, for laboratory sampling, or other venous access needs.

    Device Description

    The Dual Lumen Extended Length Catheter (dELC) is a 6F reverse-tapered dual lumen venous access device with stainless steel coil reinforcement. It is inserted into peripheral venous circulation by way of a peel away introducer. The catheter is intended for use with the Aquadex FlexFlow® and Aquadex SmartFlow® Systems in attaining vascular venous access for ultrafiltration treatment of patients with fluid overload. It has two models, 320101 and 320102, with identical hub designs but different shaft lengths, 12 cm and 16 cm, to adapt to the patient's body size.

    The catheter has a radiopaque polyurethane shaft with two equal-sized inner lumens designed in a "double D" configuration. The shaft has a reverse-tapered design to minimize resistance to flow. Its outside diameter starts at 6F on the distal end and tapers back to 7F on the proximal end. The shaft with the coil reinforcement, designed based on the FDA cleared 5.2F dELC via K041791, provides kinking resistance and ensures consistent flow. Depth markings are provided in 0.5cm increments along the insertable length of the catheter shaft. The proximal end of the catheter shaft and clear polyurethane extension tubes are over-molded into a polyurethane hub, which has suture wings for securement to the skin.

    Additionally, the catheter has female ISO 80369-compliant luer connectors to connect with the Aquadex blood tubing set for withdrawal and infusion. When the catheter is not in use, two yellow male locking caps can be placed on the female luer connectors for reducing the risk of infection. Each extension tube has a clamp: blue on the blood withdrawal tube (marked by the withdrawal ID ring) and white on the blood infusion tube (marked by the infusion ID ring). The blood is drawn up through the withdrawal lumen, which is proximal to the infusion lumen. The skived offset tip is designed to minimize blood recirculation.

    An attached MRI tag indicates the device is MR unsafe.

    AI/ML Overview

    The provided FDA 510(k) clearance letter (K252226) describes a medical device, the Dual Lumen Extended Length Catheter (dELC), and details the rationale for its substantial equivalence to a predicate device. This submission focuses on a material change to an existing cleared device, rather than a de novo submission for a novel AI/software device. Therefore, the information typically requested regarding acceptance criteria and study proving performance for an AI/software device (e.g., accuracy, sensitivity, specificity, MRMC studies, ground truth establishment) is not applicable in this context.

    The acceptance criteria here pertain to the safety and effectiveness equivalency of the modified medical device (specifically, the change in material for the Female Luer Lock Connector) compared to its predicate. The study conducted is non-clinical performance testing rather than a clinical trial or AI model validation.

    Here's a breakdown of the available information relevant to "acceptance criteria" and "study that proves the device meets the acceptance criteria" in the context of this specific 510(k) submission:

    Acceptance Criteria and Reported Device Performance (for a Material Change)

    The core acceptance criterion for this 510(k) submission is to demonstrate that the change in material for the Female Luer Lock Connector does not raise new questions of safety and effectiveness and that the modified device remains substantially equivalent to the predicate device.

    Acceptance Criterion (for a Material Change)Reported Device Performance/Conclusion
    Biocompatibility: No increased adverse tissue reactions from new material."The new material has a similar biocompatibility profile to the predicate."
    Sterilization: No increased patient harm from Ethylene Oxide (EO) residuals."Safety testing established that the new Female Luer Lock Connector material did not introduce new risks related to... increased patient harm from EO residuals."
    Shelf-Life: No reduced shelf-life."Safety testing established that the new Female Luer Lock Connector material did not introduce new risks related to... reduced shelf-life."
    Functional Integrity (Connector/Extension Tube Bond): Maintained mechanical integrity and bond strength."Functionality testing focused mainly on the integrity of the junction of the connector to the extension tubes."
    "Functionality testing established that the new Female Luer Lock Connector material did not impact device effectiveness."
    "This was determined by visual inspection of the caps for damage following IPA conditioning, the absence of catheter leakage, and suitable peak tensile force of the connector/extension tube bond."
    Overall Safety & Effectiveness: No new or increased risks."Risk analysis and, where applicable, verification and validation activities confirm that the change does not introduce new or increased risks."
    "The modified device is substantially equivalent to the predicate device (K233515) in terms of safety and effectiveness."

    Information NOT APPLICABLE to this 510(k) (as it's a material change, not an AI/software device):

    The following points are standard for AI/software device clearances but are not relevant to this specific 510(k) for a material change in a physical medical device.

    1. Sample sizes used for the test set and data provenance: Not applicable. The "test set" here refers to physical samples of the device undergoing non-clinical bench testing, not a dataset for an algorithm. Data provenance (country, retrospective/prospective) is typically for patient data used in AI validation.
    2. Number of experts used to establish ground truth for the test set and qualifications: Not applicable. There is no "ground truth" to establish in the context of an algorithmic output. The performance tests are specific to the mechanical and chemical properties of the device.
    3. Adjudication method for the test set: Not applicable. No human interpretation or adjudication of an algorithm's output.
    4. If a multi-reader multi-case (MRMC) comparative effectiveness study was done: Not applicable. MRMC studies are used to assess the impact of AI on human reader performance, which doesn't apply to this physical device change.
    5. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done: Not applicable. This is not an algorithm.
    6. The type of ground truth used: Not applicable. Ground truth typically refers to a verified diagnosis or measurement used to evaluate an AI model's accuracy. For this device, "ground truth" would be established through calibrated instruments measuring physical properties.
    7. The sample size for the training set: Not applicable. There is no AI model or training set involved.
    8. How the ground truth for the training set was established: Not applicable.

    In summary, this 510(k) demonstrates substantial equivalence through non-clinical bench testing to affirm that a material change to a connector on a physical medical device does not compromise its safety or effectiveness when compared to the previously cleared predicate device. It specifically avoids the need for clinical studies by establishing this equivalence.

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    Why did this record match?
    Applicant Name (Manufacturer) :

    Nuwellis Inc.

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

    The Dual Lumen Extended Length Catheter (dELC) is indicated for use up to 72 hours in attaining vascular venous access for use with the Aquadex FlexFlow® and Aquadex SmartFlow® systems for ultrafiltration therapy. It is not for pediatric use. The catheter is not intended for the infusion of medications or fluids, for laboratory sampling, or other venous access needs.

    Device Description

    The Dual Lumen Extended Length Catheter (dELC) is a 6F reverse-tapered dual lumen venous access device with stainless steel coil reinforcement. It is inserted into peripheral venous circulation by way of a peel away introducer. The catheter is intended for short-term use with the Aquadex FlexFlow® and Aquadex SmartFlow® Systems in attaining vascular venous access for ultrafiltration treatment of patients with fluid overload. It has two models, 320101 and 320102, with identical hub designs but different effective (insertable) shaft lengths, 12 cm and 16 cm, to adapt to the patient's body size. The catheter has a radiopaque polyurethane shaft with two equal-sized inner lumens designed in a "double D" configuration. The shaft has a reverse-tapered design to minimize resistance to flow. Its outside diameter starts at 6F on the distal end and tapers back to 7F on the proximal end. The shaft with reinforcement provides kinking resistance and ensures consistent flow. the Catheter has female ISO 80369-compliance Luer connectors to connect with the Aquadex blood tubing set for withdrawal and infusion. Each extension tube has a clamp: blue on the blood withdrawal tube and white on the blood infusion tube. The blood is drawn up through the withdrawal lumen, which is proximal to the infusion lumen. The skived offset tip is designed to minimize blood recirculation.

    AI/ML Overview

    The provided text is a 510(k) summary for a medical device called the "Dual Lumen Extended Length Catheter (dELC)". It describes the device, its intended use, comparison to predicate devices, and performance data submitted to support substantial equivalence.

    However, the provided text DOES NOT contain information about an AI device or a software component that would require an acceptance criteria table, a study proving the device meets that criteria with details about sample sizes, expert ground truth establishment, MRMC studies, or standalone algorithm performance.

    The "Performance Data" section (Section VII) lists various bench tests (e.g., Dimensional Analysis, Shaft Stiffness, Flow Rate, Kink Resistance) and biocompatibility tests performed on the physical catheter. These are standard tests for a physical medical device and are not related to an AI/software component.

    Therefore, I cannot fulfill your request to describe the acceptance criteria and the study proving an AI device meets the acceptance criteria, as this information is not present in the provided document. The document pertains to a physical catheter, not an AI or software-based medical device.

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