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510(k) Data Aggregation
(65 days)
Paragonix Technologies, Inc.
SherpaPak Cardiac Transport System: The SherpaPak Cardiac Transport System is intended to be used for the static hypothermic preservation of hearts during transportation and eventual transplantation into a recipient using cold storage solutions indicated for use with the heart. The intended organ storage time for the SherpaPak Cardiac Transport System is up to 4 hours. Donor hearts exceeding clinically accepted static hypothermic preservation times should be evaluated by the transplant surgeon to determine transplantability in accordance with accepted clinical guidelines and in the best medical interest of the intended recipient.
SherpaPak Kidney Transport System: The SherpaPak Kidney Transport System is intended to be used for the static hypothermic preservation of kidney organs during transportation and eventual transplantation into a recipient using cold storage solutions indicated for use with this organ. The SherpaPak Kidney Transport System can maintain the donor organ storage temperature between 4 C and 8 C through 24 hours.
The SherpaPak Cardiac Transport System and SherpaPak Kidney Transport System result from modifications made to the cleared Sherpa Pak Cardiac Transport System and Sherpa Pak Kidney Transport System most recently cleared under K133432 and K133694, respectively. The principle of operation of the modified devices is identical to that of the cleared devices, namely, cold static storage and transportation of donor hearts (Cardiac version) or donor kidneys (Kidney version), using cleared preservation solutions specific to the organ type being transported. Further, the modified designs have the same indications for use and utilize the same technology as the predicate devices.
The subject SherpaPak design (cardiac and kidney) like its predecessor, consists of 1) outer transport shipper which contains within it various non-ice based temperature controlled packaging elements, 2) an inner and outer hard shell assembly (i.e. Sherpa Canister/Sherpa Shell) which provides a double, rigid barrier shipper in which the heart/kidney is immersed and suspended in a cold storage solution cleared for use in storing and transporting donor hearts/kidneys, and 3) a data logger that monitors and displays the temperature of the cold storage solution in which the heart/kidney is stored during transport.
The provided document (K180194 510(k) Summary for SherpaPak Cardiac Transport System and SherpaPak Kidney Transport System) does not pertain to an AI/ML medical device. It describes a medical device designed for the static hypothermic preservation and transport of donor hearts and kidneys.
Therefore, the document does not contain any information regarding:
- Acceptance criteria for an AI/ML device.
- A study proving an AI/ML device meets acceptance criteria.
- Sample sizes for AI/ML test sets or training sets.
- Data provenance for AI/ML models.
- Number of experts or their qualifications for establishing ground truth for AI/ML models.
- Adjudication methods for AI/ML test sets.
- MRMC comparative effectiveness studies for AI/ML.
- Standalone performance of an AI/ML algorithm.
- Types of ground truth for AI/ML models.
- How ground truth for AI/ML training sets was established.
The document focuses on the functional testing performed on the modified SherpaPak systems to demonstrate their equivalence to predicate devices, including:
- Biocompatibility testing of new materials.
- Electrical Safety and EMC testing.
- Transportation testing (ASTM D4169-09).
- Thermal qualification to maintain specified temperature ranges (4°C - 8°C for up to 4 hours for cardiac, and 24 hours for kidney).
- Helium leak testing for seal integrity.
The "acceptance criteria" and "device performance" in this context are related to the physical and functional aspects of the transport system, particularly its ability to maintain organ temperature during transport and ensure sterility, rather than an AI/ML model's diagnostic or predictive performance.
The thermal qualification section implicitly describes a key performance characteristic and implied acceptance criteria:
- Acceptance Criteria (Implied from Thermal Qualification): Maintain donor organ storage temperature between 4°C and 8°C for:
- Cardiac Transport System: up to 4 hours
- Kidney Transport System: up to 24 hours (as stated in the Indications for Use and the predicate device description)
- Reported Device Performance: "This test was performed to demonstrate the system could meet this specification." (This implies successful demonstration, but quantitative results are not explicitly provided in the summary, only the duration the system "can maintain" the temperature in comparison to the predicate). The "Storage Temperature Duration" characteristic in the comparison table states that the Modified SherpaPak Cardiac/Kidney Transport System "Device can maintain 4°C to 8°C through 44 hours," which exceeds the 24-hour requirement for kidneys and 4-hour requirement for hearts, and also exceeds the predicate's 36-hour duration.
Since the request specifically asks for information relevant to an AI/ML device, and this document describes a physical transport system, I cannot fulfill the request as phrased based on the provided text.
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(33 days)
PARAGONIX TECHNOLOGIES, INC.
The Sherpa Pak Kidney Transport System is intended to be used for the static hypothermic preservation of kidney organs during transportation and eventual transplantation into a recipient, using cold storage solutions indicated for use with these organs.
The Sherpa Pak Kidney Transport System can maintain the donor organ storage temperature between 4℃ and 8℃ through 24 hours.
The Paragonix Sherpa Pak Kidney Transport System is a device intended to provide a safe, consistent method for cold ischemic storage and transport of donor organs to recipients for transplantation. The Sherpa Pak System consists of 1) an shipper which contains various non-ice based outer temperature controlled packaging elements, 2) an inner and outer hard shell container (i.e. Sherpa Pak/Sherpa Pak Shell) which provides a double, rigid barrier container in which the kidney is immersed and suspended in a Cold Storage Fluid cleared for use in storing and transporting donor organs and 3) a temperature display and timer to monitor temperature and elapsed time of transport, respectively. The device is identical to the cleared Sherpa Pak Kidney Transport System in all respects.
The purpose for this change is to allow the Paragonix Sherpa Pak Kidney Transport System to be distributed with any FDA-cleared, commercially-available preservation solution, as a Convenience Kit.
The provided document describes the Paragonix Sherpa Pak Kidney Transport System (K143054), which is a device for the static hypothermic preservation of kidney organs during transportation.
Based on the document, here's a breakdown of the acceptance criteria and the study that demonstrates the device meets them:
1. Table of Acceptance Criteria and Reported Device Performance:
Acceptance Criteria | Reported Device Performance |
---|---|
Maintain donor organ storage temperature between 4°C and 8°C through 24 hours. | "Thermal qualification demonstrated the ability of the Sherpa Pak Kidney Transport System to maintain the required temperature through 24 hours." (Page 6) |
Provide a transport system robust enough to protect the donor organ during transport. | "Specifically, testing to demonstrate that the Sherpa Pak Kidney Transport System provided a transport system robust enough to protect the donor organ during transport... was included." (Page 6) |
Meet design specifications, perform as intended, and be safe for its intended use. | "Descriptive information and laboratory bench testing were provided to demonstrate the device meets its design specifications, performs as intended, and is safe for its intended use. Additional biocompatibility testing was not necessary as there were no material changes from the device cleared under K133694." (Page 6) |
Biocompatibility for direct and indirect organ contact materials. | "Direct and indirect organ contact materials have been tested for biocompatibility." (Page 8) |
2. Sample Size Used for the Test Set and Data Provenance:
The document states: "Descriptive information and laboratory bench testing were provided to demonstrate the device meets its design specifications, performs as intended, and is safe for its intended use." (Page 6).
- Sample Size for Test Set: The exact sample size for the "laboratory bench testing" is not explicitly stated in the provided document. It refers generally to "testing".
- Data Provenance: The testing appears to be prospective bench testing conducted in a laboratory setting by the manufacturer, Paragonix Technologies, Inc. No information regarding country of origin of the data is provided, but the submission is to the US FDA.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Their Qualifications:
The document describes bench testing, which typically does not involve human expert adjudication of results in the same way clinical studies do. The ground truth for temperature maintenance and robustness would be established directly through measurements and engineering assessments, not expert consensus on interpretations. Therefore, this question is not applicable in the context of the testing performed as described.
4. Adjudication Method for the Test Set:
Not applicable. The testing described (thermal qualification, robustness testing) uses objective measurements and engineering standards, not human adjudication of a test set.
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 kidney transport system and not an AI-powered diagnostic or interpretive device that would be used by human readers.
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, not an algorithm.
7. The Type of Ground Truth Used:
The ground truth used for the acceptance criteria is based on objective physical measurements and engineering standards for temperature stability and physical robustness. For example, for temperature maintenance, the ground truth is simply whether the measured temperature stayed within 4°C and 8°C for 24 hours. For robustness, the ground truth would be determined by the intactness of the system and its ability to continue functioning after simulated transport conditions.
8. The Sample Size for the Training Set:
Not applicable. This is not an AI/machine learning device, so there is no concept of a "training set" in the context of its development and validation.
9. How the Ground Truth for the Training Set was Established:
Not applicable. As explained above, this is a physical device, not an AI/machine learning system.
Key takeaway regarding the study:
The submission for K143054 is a "Special 510(k)" for a modification to the previously cleared Sherpa Pak Kidney Transport System (K133694). The primary change is to allow the system to be distributed as a "Convenience Kit" with any FDA-cleared preservation solution. The document explicitly states: "The design, indications for use, principles of operation, technological characteristics, and packaging of the Sherpa Pak Kidney Transport System are exactly the same as the previously cleared Sherpa Pak Kidney Transport System (K133694)... As a result, no further testing is required." (Page 11).
Therefore, the study proving the device meets the acceptance criteria was primarily done for the original K133694 device. For K143054, the claim is substantial equivalence based on no material change to the device itself and its components/functionality, meaning the prior testing's results are considered applicable. The current submission relies on the prior approval and the concept of a "Convenience Kit" not requiring new testing for the combination of already-cleared components.
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(29 days)
PARAGONIX TECHNOLOGIES, INC.
The Sherpa Pak Cardiac Transport System is intended to be used for the static hypothermic preservation of hearts during transportation and eventual transplantation into a recipient using cold storage solutions indicated for use with the heart.
The intended organ storage time for the Sherpa Pak Cardiac Transport System is up to 4 hours.
Donor hearts exceeding clinically accepted static hypothermic preservation times should be evaluated by the transplant surgeon to determine transplantability in accordance with accepted clinical guidelines and in the best medical interest of the intended recipient.
The Paragonix Sherpa Pak Cardiac Transport System is a device intended to provide a safe, consistent method for cold ischemic storage and transport of donor hearts to recipients for transplantation. The Sherpa Pak System consists of 1) an outer shipper which contains various non-ice based temperature controlled packaging elements, 2) an inner and outer hard shell container (i.e. Sherpa Pak/Sherpa Pak Shell) which provides a double, rigid barrier container in which the heart is immersed and suspended in a Cold Storage Fluid cleared for use in storing and transporting donor organs and 3) a temperature display and timer to monitor temperature and elapsed time of transport, respectively. The device is identical to the cleared Sherpa Pak Cardiac Transport System in all respects.
Here's an analysis of the provided text regarding the Paragonix Sherpa Pak Cardiac Transport System, focusing on acceptance criteria and the supporting study information:
It's important to note that this document is a 510(k) premarket notification summary, which focuses on demonstrating substantial equivalence to a predicate device rather than presenting a detailed clinical study for a novel device with specific acceptance criteria in the same way a PMA (Premarket Approval) submission would.
Key takeaway from the document: The applicant is seeking to distribute the existing Sherpa Pak Cardiac Transport System (K133432) as a "Convenience Kit" with any FDA-cleared, commercially-available preservation solution. The core device itself (the transport system) has no design changes. Therefore, the document largely refers to the prior clearance (K133432) for performance data.
1. Table of Acceptance Criteria and Reported Device Performance
Since this is a Special 510(k) for a "Convenience Kit" that involves no design changes to the core device, the acceptance criteria are not presented in a classic statistical hypothesis testing format for a performance study. Instead, the "acceptance criteria" are implied by the demonstration that the modified device (the kit) performs identically to the predicate device in terms of temperature maintenance and organ protection, and that the combination with other cleared solutions is safe and effective.
Acceptance Criteria (Implied) | Reported Device Performance (from prior clearance K133432, referenced by the current submission) |
---|---|
Maintain required temperature range for static hypothermic preservation of hearts. (Specific temperature range not stated, but implied to be appropriate for organ preservation). | "Thermal qualification demonstrated the ability of the Sherpa Pak Cardiac Transport System to maintain the required temperature through 12 hours." (Found in "Functional Testing" section on page 6). The intended organ storage time is stated as "up to 4 hours." The 12-hour thermal qualification exceeds the stated intended use storage time, providing a safety margin. |
Provide a robust transport system to protect the donor organ during transport. | "Testing to demonstrate that the Sherpa Pak Cardiac Transport System provided a transport system robust enough to protect the donor organ during transport..." (Found in "Functional Testing" section on page 6). Details of "robustness" testing (e.g., shock, vibration) are not explicitly described in this summary but were presumably part of K133432. The device description mentions "an inner and outer hard shell container (i.e. Sherpa Pak/Sherpa Pak Shell) which provides a double, rigid barrier container." |
Biocompatibility of direct and indirect heart contact materials. | "Direct and indirect heart contact materials have been tested for biocompatibility." (Found in "Device Characteristic Comparison" table on page 7, under "Biocompatibility"). |
Sterilization effectiveness for relevant components. | "Sherpa Pak, Sherpa Pak Shell, and Heart connector are sterilized by gamma irradiation." (Found in "Device Characteristic Comparison" table on page 7, under "Sterilization"). |
Compatibility with FDA-cleared preservation solutions. | The entire premise of this Special 510(k) is to demonstrate that using the device with any FDA-cleared, commercially-available preservation solution (e.g., Celsior, Custodiol HTK) does not change its substantial equivalence, classifying it as a "Convenience Kit." The comparison tables show that these solutions are themselves cleared for organ storage and preservation. The core transport system, which maintains temperature and provides physical protection, is unchanged. Therefore, the combination is deemed safe and effective based on the prior clearance of its components. |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: The document does not specify a sample size for a new test set in this Special 510(k). The functional testing described ("Thermal qualification" and "robustness") refers to tests performed for the original K133432 clearance. The details of those tests, including sample sizes, are not provided in this summary.
- Data Provenance: Not explicitly stated as retrospective or prospective, nor does it mention a country of origin. This type of engineering bench testing is typically prospective, conducted in a lab setting.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of those Experts
Not applicable in the context of this device. The "ground truth" for this device's performance relates to physical parameters like temperature maintenance and structural integrity, which are established through engineering tests, not expert interpretation of medical images or clinical outcomes. Clinical efficacy would be evaluated in PAI (Premarket Approval Inspection) rather then 510K.
4. Adjudication Method for the Test Set
Not applicable. This device's performance is measured objectively against engineering specifications (e.g., temperature range, structural robustness), not requiring expert adjudication in the way medical image analysis or clinical endpoint determination might.
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 device for organ transport, not an AI-powered diagnostic or assistive technology involving human readers.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This device does not involve an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
The "ground truth" for the performance of the Sherpa Pak Cardiac Transport System is based on engineering specifications and physical measurements. This includes:
- Temperature measurements in controlled environments (thermal qualification).
- Mechanical testing (implied by "robustness" testing).
- Biocompatibility testing against established standards.
- Sterilization validation.
8. The sample size for the training set
Not applicable. This device does not utilize machine learning or AI, so there is no training set.
9. How the ground truth for the training set was established
Not applicable. As there is no training set, there is no ground truth for it.
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(171 days)
PARAGONIX TECHNOLOGIES, INC.
The Sherpa Pak Kidney Transport System is intended to be used for the static hypothermic preservation of kidney organs during transportation and eventual transplantation into a recipient using cold storage solutions indicated for use with this organ.
The Sherpa Pak Kidney Transport System can maintain the donor organ storage temperature between 4°C and 8°C through 24 hours.
The Paragonix Sherpa Pak Kidney Transport System is a device intended to provide a safe, consistent method for cold ischemic storage and transport of donor kidney organs to recipients for transplantation. The Sherpa Pak Kidney Transport System consists of 1) an outer shipper which contains various non-ice based temperature controlled packaging elements, 2) an inner and outer hard shell container (i.e. Sherpa Pak/Sherpa Pak Shell) which provides a double, rigid barrier container in which the donor kidney is immersed and suspended in a Cold Storage Fluid cleared for use in storing and transporting donor organs and 3) a temperature display and timer to monitor temperature and elapsed time of transport, respectively. The device is identical to the cleared Sherpa Pak Cardiac Transport System with the exception of the indications for use specific to donor organs, and removal of a connector in the canister component.
Acceptance Criteria and Device Performance for Paragonix Sherpa Pak Kidney Transport System
Here's a breakdown of the acceptance criteria and the study details for the Paragonix Sherpa Pak Kidney Transport System, based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
Device Characteristic | K133694 Acceptance Criteria (Indications for Use) | Reported Device Performance (Functional Testing/Substantial Equivalence) |
---|---|---|
Intended Use | Organ storage and preservation for transplantation. | "The design, intended use, principles of operation, and technological characteristics of the Sherpa Pak Kidney Transport System are substantially equivalent to the previously cleared Sherpa Pak Cardiac Transport System (K123326). The intended use of the subject device is the same as all the cited predicates..." "testing conducted to demonstrate that the subject device performs as intended and is substantially equivalent to the predicate devices in terms of its ability to safely store and transport a donor organ at a clinically acceptable temperature range to a recipient for transplantation." |
Storage Temperature | Maintain donor organ storage temperature between 4°C and 8°C. | "Specifically, testing to demonstrate that the Sherpa Pak Kidney Transport System provides a transport system robust enough to protect the donor organ during transport and maintain temperature throughout the duration of transport..." "Device can maintain 4° C to 8° C through 24 hours" (stated in the "Intended storage time" table, implying it meets this in testing). |
Storage Duration | Through 24 hours. | "Device can maintain 4° C to 8° C through 24 hours" (stated in the "Intended storage time" table, implying it meets this in testing). |
Organ Type | Kidney organs. | "The Sherpa Pak Kidney Transport System is intended to be used for the static hypothermic preservation of kidney organs..." This is part of the device's specific indication, thus the device is designed and tested for this. |
Preservation Method | Static hypothermic preservation. | "The Sherpa Pak Kidney Transport System is intended to be used for the static hypothermic preservation..." "Mode of Operation: Static cold ischemic storage." |
Safety and Performance | Safe, consistent method for cold ischemic storage and transport of donor kidney organs. No explicit criteria, but expected. | "Descriptive information and laboratory bench testing were provided to demonstrate the device meets its design specifications, performs as intended, and is safe for its intended use." "Additional biocompatibility testing was not necessary as there were no material changes from the device cleared under K123326." "Substantial equivalence is based upon descriptive characteristics of the various cited predicate devices and upon the testing conducted to demonstrate that the subject device performs as intended and is substantially equivalent to the predicate devices in terms of its ability to safely store and transport a donor organ at a clinically acceptable temperature range to a recipient for transplantation." |
2. Sample Size Used for the Test Set and Data Provenance
The provided document does not specify a sample size for a "test set" in the context of clinical data for algorithmic performance. The testing described is laboratory bench testing and refers to a "descriptive information and laboratory bench testing" approach to demonstrate the device meets design specifications and perform as intended.
There is no mention of data provenance (e.g., country of origin, retrospective/prospective) for a test set, as clinical data for performance assessment (e.g., organ viability post-transport) is not described as being part of the submission for determining substantial equivalence regarding its temperature maintenance capabilities. The focus is on the physical and functional characteristics of the transport system itself.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of those Experts
Not applicable. This device is a medical device for organ transport, not an AI/diagnostic software. No "ground truth" established by experts in the context of diagnostic accuracy is mentioned.
4. Adjudication Method for the Test Set
Not applicable. There is no mention of an adjudication method for a test set, as the testing described focuses on bench-top performance of the device's physical functions.
5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study was done
Not applicable. This is not a comparative effectiveness study involving human readers or AI assistance. It describes a medical device for organ transport.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This is a medical device for organ transport, not an algorithm.
7. The type of ground truth used
The "ground truth" can be inferred from the stated performance goals:
- Temperature Maintenance: The ability to consistently maintain the temperature of a simulated/actual organ (or the internal environment of the device) between 4°C and 8°C for 24 hours. The ground truth would be the actual measured temperature by calibrated sensors.
- Physical Protection/Robustness: The ability to protect the donor organ during transport. The ground truth would be the structural integrity of the device and its contents after simulated transport conditions.
- Biocompatibility: The materials being non-toxic and compatible with the organ. The ground truth would rely on established biocompatibility testing standards and results from a predicate device.
8. The sample size for the training set
Not applicable. This is a medical device, not an AI model requiring a training set.
9. How the ground truth for the training set was established
Not applicable. This is a medical device, not an AI model.
Summary of the Study that Proves Acceptance Criteria:
The key study information provided is:
- Type of Study: Descriptive information and laboratory bench testing.
- Purpose: To demonstrate that the device meets its design specifications, performs as intended, and is safe for its intended use.
- Specific Tests: Testing was conducted to demonstrate the system's robustness to protect the donor organ during transport and its ability to maintain the specified temperature range (4°C to 8°C) for the duration of transport (24 hours).
- Biocompatibility: No new biocompatibility testing was deemed necessary because there were no material changes from the previously cleared Sherpa Pak Cardiac Transport System (K123326), implying the previous device's biocompatibility data was leveraged.
- Basis for Equivalence: Substantial equivalence was based on these descriptive characteristics and testing, comparing the Sherpa Pak Kidney Transport System to its predicate, the Sherpa Pak Cardiac Transport System (K123326), as well as other predicate devices for context (Avid Medical Custom Procedure Tray and CoStorSol Cold Storage Solution).
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(108 days)
PARAGONIX TECHNOLOGIES, INC.
The Sherpa Pak Cardiac Transport System is intended to be used for the static hypothermic preservation of hearts during transportation and eventual transplantation into a recipient using cold storage solutions indicated for use with the heart.
The intended organ storage time for the Sherpa Pak Cardiac Transport System is up to 4 hours.
Donor hearts exceeding clinically accepted static hypothermic preservation times should be evaluated by the transplant surgeon to determine transplantability in accordance with accepted clinical guidelines and in the best medical interest of the intended recipient.
The Paragonix Sherpa Pak Cardiac Transport System is a device intended to provide a safe, consistent method for cold ischemic storage and transport of donor hearts to recipients for transplantation. The Sherpa Pak System consists of 1) an outer shipper which contains various non-ice based temperature controlled packaging elements. 2) an inner and outer hard shell container (i.e. Sherpa Pak/Sherpa Pak Shell) which provides a double, rigid barrier container in which the heart is immersed and suspended in a Cold Storage Fluid cleared for use in storing and transporting donor hearts and 3) a temperature display and timer to monitor temperature and elapsed time of transport. respectively. The changes made to the currently cleared device are labeling changes only. The device subject to this notification is identical to that cleared under K123326.
The provided document is a 510(k) premarket notification for a medical device called the "Paragonix Sherpa Pak Cardiac Transport System." It describes a device intended for the cold ischemic storage and transport of donor hearts.
The key finding from the document is that the submission is for a labeling change only. The device itself has not changed and is identical to a previously cleared device (K123326). Therefore, the substantial equivalence determination is based on the prior clearance and the fact that the labeling change does not alter the device's intended use or technological characteristics.
This means the current document does not contain a new study proving the device meets new acceptance criteria, as the device itself hasn't changed. The original device's performance data and acceptance criteria would be in the K123326 submission, which is not provided here.
Based on the provided text, here's what can be extracted and inferred:
1. A table of acceptance criteria and the reported device performance
Since this is a labeling change and the device is identical to the cleared predicate (K123326), no new acceptance criteria or performance data are presented in this document. The document states:
- "The device subject to this notification is identical to that cleared under K123326." {1}
- "The testing performed in support of the original 510(k) continues to be supportive of the modified device." {1}
- "The design, intended use, principles of operation, and technological characteristics of the Sherpa Pak Cardiac Transport System are substantially equivalent to the previously cleared Sherpa Pak Cardiac Transport System. The labeling change does not alter the device's intended use. There were no changes to the device itself and it is identical to the device cleared under K123326." {1}
The stated "Intended Use" and "Indications for Use" from the document are:
Acceptance Criteria (from "Indications for Use") | Reported Device Performance (from "Functional Testing" and "Summary of Substantial Equivalence") |
---|---|
Intended Use: Organ storage and preservation for transplantation. | Met by substantial equivalence to K123326. Device design, intended use, principles of operation, and technological characteristics are identical. |
Indications for Use: |
- Static hypothermic preservation of hearts during transportation and eventual transplantation.
- Use with cold storage solutions indicated for the heart.
- Intended organ storage time: up to 4 hours.
- Donor hearts exceeding clinically accepted static hypothermic preservation times should be evaluated by the transplant surgeon. | Met by substantial equivalence to K123326. The device did not change, only the labeling. The original testing for K123326 supports these indications. |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
Not applicable for this submission. This 510(k) is for a labeling change, not a new performance study. The document explicitly states: "Functional Testing: The premarket notification was submitted for a labeling change to the device. The device did not change in any respect otherwise. The testing performed in support of the original 510(k) continues to be supportive of the modified device." {1}
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)
Not applicable. As noted above, no new performance study was conducted for this 510(k) submission.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. No new performance study was conducted.
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 physical transport system, not an AI-assisted diagnostic tool.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This device is a physical transport system, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
Not applicable. No new performance study was conducted. Performance for the device would likely be assessed through engineering testing (e.g., temperature stability, integrity) and potentially clinical outcomes data from the original K123326 submission, but this information is not in the provided document.
8. The sample size for the training set
Not applicable. This device is a physical transport system and does not involve AI or machine learning that would require a training set.
9. How the ground truth for the training set was established
Not applicable. As above, no training set is relevant for this type of device.
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(103 days)
PARAGONIX TECHNOLOGIES, INC.
The Sherpa Pak Cardiac Transport System is intended to be used for the static hypothermic preservation of hearts, up to 4 hours, during transportation and eventual transplantation into a recipient, using cold storage solutions indicated for use with the heart.
The Paragonix Sherpa Pak Cardiac Transport System is a device intended to provide a safe, consistent method for cold ischemic storage and transport of donor hearts to recipients for transplantation. The Sherpa Pak System consists of 1) an outer shipper which contains various non-ice based temperature controlled packaging elements, 2) an inner and outer hard shell container (i.e. Sherpa Pak/Sherpa Pak Shell) which provides a double, rigid barrier container in which the heart is immersed and suspended in a Cold Storage Fluid cleared for use in storing and transporting donor hearts and 3) a temperature display and timer to monitor temperature and elapsed time of transport, respectively.
Here's a breakdown of the acceptance criteria and study information for the Paragonix Sherpa Pak Cardiac Transport System based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance:
The document does not explicitly state quantitative "acceptance criteria" for the device's performance in a table format. Instead, it describes general design specifications and functional testing outcomes.
Characteristic | Acceptance Criteria (Implied / Desired Outcome) | Reported Device Performance |
---|---|---|
Protection during Transport (Robustness) | Device should be robust enough to protect the heart during transport. | Testing demonstrated the Sherpa Pak System provided a transport system robust enough to protect the heart during transport. |
Temperature Maintenance | Device should maintain temperature throughout the duration of transport. | Testing demonstrated the Sherpa Pak System maintained temperature throughout the duration of transport. |
Biocompatibility | Direct and indirect heart contact materials must be biocompatible (non-toxic, non-sensitizing, etc.). | Biocompatibility testing including cytotoxicity, systemic toxicity, genotoxicity, sensitization, and intracutaneous testing was performed. Direct and indirect heart contact materials have been tested for biocompatibility. (Implied: results were acceptable, as the device was cleared). |
Intended Use Period | Static hypothermic preservation of hearts up to 4 hours. | The Sherpa Pak Cardiac Transport System is intended to be used for static hypothermic preservation of hearts, up to 4 hours. The marketing clearance implies that the device demonstrated it can achieve this. |
UNOS Policy 5 Compliance | Conformity to UNOS Policy 5 for organ storage and preservation. | The device's "Meets UNOS Policy 5" characteristic is listed as "Yes" in the comparison table. |
Sterilization | Specific components (Sherpa Pak, Sherpa Pak Shell, Heart connector) should be sterilized. Other parts non-sterile. | Sherpa Pak, Sherpa Pak Shell, and Heart connector are sterilized by gamma irradiation. All other components are non-sterile. (This is a design characteristic that was met, rather than a performance outcome in the same way as temperature). |
Single Use/Reuse | Entire system is single use/patient only. | The entire system is single use/patient only. (This is a design characteristic that was met, rather than a performance outcome in the same way as temperature). |
Overall Performance | Performs as intended and is safe for its intended use, substantially equivalent to predicate devices. | The testing conducted demonstrated that the subject device performs as intended and is substantially equivalent to the predicate devices in terms of its ability to safely store and transport a donor heart at a clinically acceptable temperature range to a recipient for transplantation. |
2. Sample Size Used for the Test Set and Data Provenance:
The document states: "Descriptive information, laboratory bench testing, and biocompatibility testing were provided to demonstrate the device meets its design specifications, performs as intended, and is safe for its intended use."
- Sample Size: The document does not specify any sample sizes for the functional or biocompatibility testing conducted. It refers to "testing" generically.
- Data Provenance: The data provenance (e.g., country of origin, retrospective or prospective) is not mentioned. The testing described appears to be internal lab testing rather than clinical study data.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications:
- Number of Experts: This information is not provided. The "ground truth" for this device's performance primarily relates to objective physical parameters (temperature stability, structural integrity, biocompatibility) rather than expert interpretation of images or clinical outcomes.
- Qualifications of Experts: This information is not provided.
4. Adjudication Method for the Test Set:
- Adjudication Method: This information is not provided. Given the nature of the tests (bench testing, biocompatibility), there is no indication of an adjudication process typically associated with subjective assessments or clinical outcomes.
5. Multi Reader Multi Case (MRMC) Comparative Effectiveness Study:
- No, a Multi Reader Multi Case (MRMC) comparative effectiveness study was not done or mentioned. This type of study is typically relevant for diagnostic imaging devices where human readers interpret results, and the AI's impact on their performance is being evaluated. This device is a transport system, not a diagnostic tool.
6. Standalone (Algorithm Only) Performance Study:
- Yes, a standalone performance study was done in the sense that the "Functional Testing" described ("testing to demonstrate that the Sherpa Pak System provided a transport system robust enough to protect the heart during transport and maintained temperature throughout the duration of transport") and "biocompatibility testing" were evaluations of the device itself, independent of human interaction during the test. There is no "algorithm" in the conventional AI sense for this device.
7. Type of Ground Truth Used:
The ground truth used was based on objective measurements and laboratory standards:
- Functional Testing: Measuring whether the device maintained temperature, its structural integrity under stress (robustness), and protection of the "heart" (simulated or actual, not specified but likely simulated for bench testing).
- Biocompatibility Testing: Adherence to established standards for cytotoxicity, systemic toxicity, genotoxicity, sensitization, and intracutaneous reactivity.
- UNOS Policy 5: Assessed against a defined policy standard.
8. Sample Size for the Training Set:
This device is a physical medical device, not an AI/machine learning algorithm that requires a "training set" in the computational sense. Therefore, the concept of a training set sample size is not applicable.
9. How the Ground Truth for the Training Set Was Established:
As there is no AI/machine learning algorithm with a training set for this device, how ground truth for a training set was established is not applicable.
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