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510(k) Data Aggregation

    K Number
    K203796
    Date Cleared
    2021-07-30

    (214 days)

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

    PuraCath Medical, Inc

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

    The PuraCath™ Firefly™ Needleless Connector is a sterile single patient use connector for needleless access to the IV line and/or IV catheter during IV therapy and can be used for direct injection, intermittent infusion, continuous infusion or aspiration.

    Device Description

    The PuraCath Firefly Needleless Connector, Model 9001, is a neutral displacement needleless connector intended for single patient use, including pediatrics and immunocompromised patients, for direct injection, intermittent infusion, continuous infusion or aspiration of drugs, blood and fluids when using a vascular access device. The PuraCath Firefly Needleless Connector is a closed, luer activated device that eliminates the risk of needlestick injuries. The PuraCath Firefly Needleless Connector does not require a specific clamping sequence or technique in order to be used safely. The clear housing and open, fluid filled design enhances flushing practice. The Firefly Needleless Connector may be used with power injector procedures to a maximum pressure of 325 psi at a flow rate of 10 mL per second. The Firefly Needleless Connector can be used for seven (7) days and 200 activations. The PuraCath Firefly Needleless Connector is designed to be disinfected using standard of care alcohol wipe down.

    AI/ML Overview

    Here's a summary of the acceptance criteria and the study details for the Firefly Needleless Connector, based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    TestAcceptance Criteria (Standard)Reported Device Performance
    CytotoxicityISO 10993-5: 2009, Biological Evaluation of Medical Devices Part 5: Tests for in vitro CytotoxicityPass - No reactivity
    Intracutaneous reactivity / IrritationISO 10993-10: 2013 Biological evaluation of medical devices Part 10: Tests for irritation and skin sensitizationPass - Non-irritant
    SensitizationISO 10993-10: 2013 Biological evaluation of medical devices Part 10: Tests for irritation and skin sensitizationPass - Non-sensitizing
    Acute Systemic ToxicityISO 10993-11: 2017 Biological evaluation of medical devices Part 11: Tests for systemic toxicityPass – Did not cause acute systemic toxicity
    HemolysisASTM F 756 – 17: Standard Practice for Assessment of Hemolytic Properties of MaterialsPass - Non-hemolytic
    PyrogenicityUSP Pyrogen Test Procedure, Section (USP40)Pass - Non-pyrogenic
    Particulate MatterUSP Particulate Matter in InjectionsPass
    SterilityISO 11135:2014, Ethylene oxide — Requirements for development, v ISO 10993-7:2008 & ISO 10993-7:2008, Biological evaluation of medical devices — Part 7 - Ethylene oxide sterilization residuals validation and routine controlPass
    6 Month Shelf LifeASTM F1980-16: Standard Guide for Accelerated Aging of Sterile Barrier Systems for Medical Devices & ISO 11607-1 Second Edition 2019-02: Packaging for terminally sterilized medical devices - Part 1. Requirements for materials, sterile barrier systems, and packaging systemsPass
    MR CompatibilityFDA Guidance: Establishing Safety and Compatibility of Passive Implants in the Magnetic Resonance (MR) Environment: 2014Pass
    Microbial ingress (FDA Guidance)FDA Guidance: Intravascular Administration Sets Premarket Notification Submission [510(k)]: 2008Pass
    Fluid displacement (FDA Guidance)FDA Guidance: Intravascular Administration Sets Premarket Notification Submission [510(k)]: 2008Pass
    Flow rate at gravity (FDA Guidance)FDA Guidance: Intravascular Administration Sets Premarket Notification Submission [510(k)]: 2008Pass
    Power infusion flow (FDA Guidance)FDA Guidance: Intravascular Administration Sets Premarket Notification Submission [510(k)]: 2008Pass
    Flush volume (FDA Guidance)FDA Guidance: Intravascular Administration Sets Premarket Notification Submission [510(k)]: 2008Pass
    Priming volume (FDA Guidance)FDA Guidance: Intravascular Administration Sets Premarket Notification Submission [510(k)]: 2008Pass
    Size and weight (FDA Guidance)FDA Guidance: Intravascular Administration Sets Premarket Notification Submission [510(k)]: 2008Pass
    Valve actuation force (FDA Guidance)FDA Guidance: Intravascular Administration Sets Premarket Notification Submission [510(k)]: 2008Pass
    Valve recovery (FDA Guidance)FDA Guidance: Intravascular Administration Sets Premarket Notification Submission [510(k)]: 2008Pass
    Valve cycle test (FDA Guidance)FDA Guidance: Intravascular Administration Sets Premarket Notification Submission [510(k)]: 2008Pass
    Valve back pressure test (FDA Guidance)FDA Guidance: Intravascular Administration Sets Premarket Notification Submission [510(k)]: 2008Pass
    Valve pressure test (FDA Guidance)FDA Guidance: Intravascular Administration Sets Premarket Notification Submission [510(k)]: 2008Pass
    Tensile strength (FDA Guidance)FDA Guidance: Intravascular Administration Sets Premarket Notification Submission [510(k)]: 2008Pass
    Flexural strength (FDA Guidance)FDA Guidance: Intravascular Administration Sets Premarket Notification Submission [510(k)]: 2008Pass
    Particulate contamination (ISO 8536-4)ISO 8536-4 Sixth edition 2019-09, Infusion equipment for medical use - Part 4: Infusion sets for single use, gravity feedPass
    Leakage (ISO 8536-4)ISO 8536-4 Sixth edition 2019-09, Infusion equipment for medical use - Part 4: Infusion sets for single use, gravity feedPass
    Tensile strength (ISO 8536-4)ISO 8536-4 Sixth edition 2019-09, Infusion equipment for medical use - Part 4: Infusion sets for single use, gravity feedPass
    Male Conical fitting (ISO 8536-4)ISO 8536-4 Sixth edition 2019-09, Infusion equipment for medical use - Part 4: Infusion sets for single use, gravity feedPass
    Reducing matter (ISO 8536-4)ISO 8536-4 Sixth edition 2019-09, Infusion equipment for medical use - Part 4: Infusion sets for single use, gravity feedPass
    Metal ions (ISO 8536-4)ISO 8536-4 Sixth edition 2019-09, Infusion equipment for medical use - Part 4: Infusion sets for single use, gravity feedPass
    Titration acidity or alkalinity (ISO 8536-4)ISO 8536-4 Sixth edition 2019-09, Infusion equipment for medical use - Part 4: Infusion sets for single use, gravity feedPass
    Residue on evaporation (ISO 8536-4)ISO 8536-4 Sixth edition 2019-09, Infusion equipment for medical use - Part 4: Infusion sets for single use, gravity feedPass
    UV absorption (ISO 8536-4)ISO 8536-4 Sixth edition 2019-09, Infusion equipment for medical use - Part 4: Infusion sets for single use, gravity feedPass
    Dimensional requirements (ISO 80369-7)ISO 80369-7 First edition 2016-10-15, Small-bore connectors for liquids and gases in healthcare applications - Part 7: Connectors for intravascular or hypodermic applicationPass
    Positive pressure liquid leakage (ISO 80369-7)ISO 80369-7 First edition 2016-10-15, Small-bore connectors for liquids and gases in healthcare applications - Part 7: Connectors for intravascular or hypodermic applicationPass
    Sub-atmospheric pressure air leakage (ISO 80369-7)ISO 80369-7 First edition 2016-10-15, Small-bore connectors for liquids and gases in healthcare applications - Part 7: Connectors for intravascular or hypodermic applicationPass
    Stress cracking (ISO 80369-7)ISO 80369-7 First edition 2016-10-15, Small-bore connectors for liquids and gases in healthcare applications - Part 7: Connectors for intravascular or hypodermic applicationPass
    Resistance to separation from axial load (ISO 80369-7)ISO 80369-7 First edition 2016-10-15, Small-bore connectors for liquids and gases in healthcare applications - Part 7: Connectors for intravascular or hypodermic applicationPass
    Resistance to separation from unscrewing (ISO 80369-7)ISO 80369-7 First edition 2016-10-15, Small-bore connectors for liquids and gases in healthcare applications - Part 7: Connectors for intravascular or hypodermic applicationPass
    Resistance to overriding (ISO 80369-7)ISO 80369-7 First edition 2016-10-15, Small-bore connectors for liquids and gases in healthcare applications - Part 7: Connectors for intravascular or hypodermic applicationPass

    Study Proving Device Meets Acceptance Criteria:

    The document describes non-clinical bench testing as the study conducted to determine if the device is substantially equivalent to the predicate device. These tests covered biocompatibility testing and performance testing based on various international standards and FDA guidance documents.

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

    The document does not specify the exact sample sizes (N-numbers) for each individual test conducted. It only states that "The following non-clinical data were provided in support of the substantial equivalence determination." and lists various test categories.

    Regarding data provenance, the tests are non-clinical (bench testing), so there is no patient data involved from specific countries or retrospective/prospective collection. The provenance here refers to the standards and guidance followed (e.g., ISO, ASTM, USP, FDA Guidance).

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

    This information is not applicable (N/A) as the tests are non-clinical bench tests (e.g., material compatibility, mechanical performance) and do not involve human interpretation or clinical ground truth established by experts in the typical sense of a diagnostic device. The "ground truth" for these tests are the defined pass/fail criteria outlined in the referenced standards.

    4. Adjudication Method for the Test Set

    This information is not applicable (N/A) for non-clinical bench testing. Adjudication methods like 2+1 or 3+1 are used for human-in-the-loop studies or clinical trials where expert consensus is needed to establish ground truth for diagnostic decisions. In this case, the test results are objective measurements against predefined standards.

    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

    There is no indication that an MRMC comparative effectiveness study was done. This device is a passive medical device (a needleless connector), not an AI-powered diagnostic or assistive tool, so such a study would not be relevant.

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

    This information is not applicable (N/A). The device is a physical medical device, not an algorithm, so standalone algorithm performance is not a relevant concept here.

    7. The Type of Ground Truth Used

    The "ground truth" for the non-clinical tests is established by objective measurements and observations performed according to recognized international standards (ISO, ASTM, USP) and FDA guidance documents. The acceptance criteria for each test are defined by these standards, and the device's performance is compared against these predetermined thresholds. For biocompatibility, this involves evaluating biological responses to materials. For performance, it involves mechanical, fluid dynamic, and durability assessments.

    8. The Sample Size for the Training Set

    This information is not applicable (N/A). This device is a physical medical device and does not involve AI/machine learning, and therefore does not have a "training set" in that context. The "design" and "testing" of the device are based on engineering principles and regulatory standards.

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

    This information is not applicable (N/A), as it's not an AI/machine learning device requiring a training set.

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    K Number
    K151620
    Date Cleared
    2016-01-20

    (218 days)

    Product Code
    Regulation Number
    876.5630
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    PURACATH MEDICAL, INC.

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

    The PuraCath™ Firefly IM Peritoneal Dialysis Connector Disinfecting System is intended for use by PD (peritoneal dialysis) patients as a method of controlling air and touch contamination while performing a solution exchange dialysis patiens as a nethod of connector Disinfecting System is comprised of Firefly™ UV Purification Device, FireflyTM Transfer Catheter, FireflyTM Luer Cover, and FireflyTM 99% IPA bottle.

    The effectiveness of the PuraCath Firefly Peritoneal Dialysis Connector Disinfecting System was tested in viro against The enectivelless of the Funceoccus epidermidis, Escherichia coli, Pseudomonas aeruginosa, Streptococus Staphylococcus autous, Staphylococcus aureus, and Candida albicans yielding ≥ 4log reduction in microorganisms.

    The PuraCath Firefly Peritoneal Dialysis Connector Disinfecting System may be used in the home or a healthicare facility.

    Device Description

    The PuraCath Firefly Peritoneal Dialysis Connector Disinfecting System provides a way for patients to ensure the cleanliness of the fluid connections associated with ambulatory peritoneal dialysis. The system accomplishes cleaning with a combination of alcohol, flushing with sterile dialysate, and ultraviolet (UV) light. The System consists of the components shown below.

    The Firefly UV Purification Device is a multi-year reusable device which helps to clean the connection between the Firefly Transfer Catheter and the dialysate Y-set (Y-set). The UV Purification Device is powered by off-the-shelf, replaceable AA batteries. The UV Purification Device directs ultraviolet (UV) light through the Transfer Catheter connector. UV Purification Device uses lights and an audible alert to indicate device status.

    The Firefly Transfer Catheter is a sterile, 6 month use, disposable device providing communication between the indwelling patient catheter and the Y-set. A proprietary, UV transparent control valve on the end of the Transfer Catheter allows for draining and filling the peritoneum. The control valve is actuated manually, adjustable between fully open and fully closed. The Transfer Catheter also has a flush feature. The flush feature allows for flushing of air and potential contaminants from the Y-set prior to fluid exchange.

    The Firefly Luer Cover is a 6 month use, disposable, UV transparent component designed to protect the Transfer Catheter connector between uses and to aid in keeping the control valve closed.

    The Firefly IPA Dropper Bottle provides a convenient way to apply 99% IPA solution to the inside of the Y-set and Transfer Catheter connectors.

    AI/ML Overview

    Acceptance Criteria and Study for the Firefly™ Peritoneal Dialysis Connector Disinfecting System

    This document describes the acceptance criteria and the study conducted to prove that the Firefly™ Peritoneal Dialysis Connector Disinfecting System meets those criteria, as detailed in the provided FDA 510(k) summary (K151620).

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Required Performance)Reported Device Performance
    Microbiological Efficacy: Achieve ≥ 4 log reduction in specified microorganisms.Achieved ≥ 4 log reduction in each tested microorganism: Staphylococcus aureus, Staphylococcus epidermidis, Pseudomonas aeruginosa, Escherichia coli, Streptococcus pneumoniae, Methicillin-resistant Staphylococcus aureus, and Candida albicans.
    Biocompatibility: Meet ISO 10993 standards for medical devices.Evaluation conducted in accordance with FDA Blue Book Memorandum #G95-1 and ISO 10993. Tests included Cytotoxicity, Sensitization, and Irritation or Intracutaneous Reactivity. (Specific pass/fail results not detailed, but implied by "conducted in accordance" and accepted by FDA).
    Sterilization: Ensure proper sterilization of components.Testing conducted to confirm proper sterilization. (Specific acceptance criteria for sterilization, e.g., sterility assurance level (SAL), not explicitly stated, but assumed to meet applicable standards).
    Electrical Safety and Electromagnetic Interference (EMI): Comply with relevant electrical safety and EMI standards.Testing conducted to confirm compliance with electrical safety and electromagnetic interference standards. (Specific standards, e.g., IEC 60601-1, are listed as adhered to).
    Life Cycle Testing: Demonstrate durability and performance over expected lifespan.Life cycle testing conducted. (Specific performance metrics and duration not explicitly detailed).
    Light Leak Testing: Ensure no light leakage from the UV Purification Device.Light leak testing conducted. (Specific acceptance criteria not explicitly detailed).
    Transit Testing: Withstand transport and shipping conditions.Transit testing conducted. (Specific acceptance criteria not explicitly detailed).
    Water Ingress Testing: Ensure protection against water entry.Water ingress testing conducted. (Specific acceptance criteria not explicitly detailed).
    Human Factors - Usability: Demonstrate intuitive and safe use by intended users.Human factors - usability studies conducted. (Specific acceptance criteria not explicitly detailed).
    Adherence to Performance Standards: Compliance with listed ISO/AAMI/IEC standards.All applicable requirements of ISO 14971-1:2012, AAMI/ANSI HE75:2009, ISO 62366-1:2015, ISO 15223-1:2012, IEC 60601-1, ISO 10993-1:2009, ISO 10993-7:2008, and ISO 594-2:1998 were met.
    Substantial Equivalence: Demonstrate substantial equivalence to predicate devices in terms of intended use, design, materials, operation, function, and sterilization method.Concluded as substantially equivalent to predicate devices based on presented data.

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

    The provided document primarily details in vitro studies for microbiological efficacy and various bench tests for physical and electrical performance.

    • Microbiological Testing: The sample size for the microbiological efficacy testing is not explicitly stated. It is described as "in vitro antimicrobial efficacy studies," suggesting laboratory-based experiments using cultured microorganisms.
    • Other Performance Tests (Biocompatibility, Sterilization, Electrical Safety, Life Cycle, Light Leak, Transit, Water Ingress, Human Factors): The sample sizes for these tests are not explicitly stated in the summary. These would typically involve testing a representative number of devices or components.
    • Data Provenance: All described studies are pre-market, laboratory-based in vitro and bench testing. No clinical data from human subjects is mentioned for performance evaluation. The data provenance is implied to be from the manufacturer's testing facilities or accredited laboratories. There is no indication of country of origin of the data beyond the manufacturer being US-based, and the submission being to the US FDA.

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

    This information is not provided in the given 510(k) summary. For in vitro and bench testing, "ground truth" is typically established by the reference standards and protocols of the tests themselves, conducted by qualified scientists and engineers in a laboratory setting, rather than through expert consensus on observational data.

    4. Adjudication Method for the Test Set

    This concept is not applicable to the type of studies presented (in vitro microbiological tests and various bench performance tests). Adjudication methods like 2+1 or 3+1 are typically used in clinical studies or image review settings where human interpretation introduces variability requiring a consensus process.

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

    No, a Multi Reader Multi Case (MRMC) comparative effectiveness study was not conducted or described. This type of study assesses the impact of a device (often AI) on human reader performance, which is not relevant for this device as it is a physical disinfecting system, not an AI-assisted diagnostic tool.

    6. Standalone Performance (Algorithm Only without Human-in-the Loop Performance)

    Yes, a form of standalone performance was assessed. The "Microbiological testing" section describes the device's ability to achieve a "≥ 4 log reduction in micro-organisms" in vitro. This demonstrates the device's inherent capability to disinfect independently of human factors (beyond proper operation of the system). Similarly, other bench tests (e.g., electrical safety, life cycle) evaluate the device's inherent performance characteristics as a standalone product. The device itself is not an "algorithm" in the sense of software for interpretation, but rather a physical system.

    7. Type of Ground Truth Used

    The ground truth for the performance evaluations described in this document is primarily based on:

    • In Vitro Microbiological Reference Standards: For the microbiological testing, the ground truth is the known concentration of specified microorganisms and the quantitative measurement of their reduction after exposure to the device. This is a highly controlled, objective, and quantifiable measure.
    • Engineering Specifications and Standardized Testing Protocols: For other performance tests (e.g., electrical safety, life cycle, light leak), the ground truth is established by meeting predefined engineering specifications and adhering to recognized industry standards (e.g., ISO, IEC, AAMI/ANSI). These are objective, measurable criteria.
    • Physical Measurements and Observations: For tests like transit or water ingress, the ground truth is the observable outcome or measured performance against defined pass/fail criteria.

    8. Sample Size for the Training Set

    This is not applicable. The Firefly™ Peritoneal Dialysis Connector Disinfecting System is a physical medical device, not a machine learning or AI algorithm that requires a "training set" of data.

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

    This is not applicable as there is no "training set" for this device.

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