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510(k) Data Aggregation
(246 days)
Q'Apel Medical, Inc.
The Neurovascular Access System Family is indicated for the introduction of interventional devices into the peripheral and neuro vasculature. It is not intended for use in coronary arteries.
The subject Neurovascular Access System Family consists of sterile, single-use catheters and accessories that are used together to facilitate the insertion and guidance of an appropriately sized interventional device into a selected vessel in the peripheral and neurovasculature. The Neurovascular Access System is comprised of the Neurovascular Access Catheter, Access Tool, Peel Away Introducer and Dilator. The Neurovascular Access System Family is offered in various lengths to accommodate physician preferences and anatomical variations. The distal end of the catheter is coated with hydrophilic coating to reduce friction during use and a radiopaque marker on the distal tip that is visible under fluoroscopy.
This document is a 510(k) Summary for a medical device called the "Neurovascular Access System Family." It details the device's characteristics, intended use, and compares it to legally marketed predicate devices to demonstrate substantial equivalence.
Here's a breakdown of the requested information based on the provided text:
1. A table of acceptance criteria and the reported device performance
Test Name | Objective | Test Method / Standard or Guidance | Acceptance Criteria (Implied by "Pass") | Reported Device Performance |
---|---|---|---|---|
Visual Surface Requirements | To demonstrate that the device meets the visual surface requirements. | ISO 10555-1 2013, Section 4.4 | Device meets visual surface requirements. | Pass |
Dimensional Verification | To demonstrate that the device meets the dimensional requirements. | ISO 10555-1 2013, Section 4.5 | Device meets dimensional requirements. | Pass |
Liquid Leakage Under Pressure | To demonstrate that the device passes the liquid leakage under pressure test. | ISO 10555-1 2013, Section 4.7.1, Annex C | Device passes liquid leakage test. | Pass |
Hub Aspiration Air Leakage | To demonstrate that the device passes the hub aspiration air leakage test. | ISO 10555-1 2013, Section 4.7.2, Annex D | Device passes hub aspiration test. | Pass |
Simulated Use and Usability | To demonstrate that the device passes testing specified in the simulated use test protocol. Simulated use testing includes usability assessment with multiple physicians. | FDA guidance: "Peripheral Percutaneous Transluminal Angioplasty (PTA) and Specialty Catheters - Premarket Notification (510(k)) Submissions", April 2023 | Device passes simulated use and usability protocols. | Pass |
Flex Fatigue | To demonstrate that the device passes the flex fatigue test. | FDA guidance: "Peripheral Percutaneous Transluminal Angioplasty (PTA) and Specialty Catheters - Premarket Notification (510(k)) Submissions", April 2023 | Device passes flex fatigue test. | Pass |
Torque Test | To demonstrate the torque strength of the device. | FDA guidance: "Peripheral Percutaneous Transluminal Angioplasty (PTA) and Specialty Catheters - Premarket Notification (510(k)) Submissions" April 2023 | Device demonstrates adequate torque strength. | Pass |
Tip Deflection | To demonstrate that the tip deflection is comparable to the predicate device. | FDA Guidance: "Peripheral Percutaneous Transluminal Angioplasty (PTA) and Specialty Catheters - Premarket Notification (510(k)) Submissions" April 2023 | Tip deflection is comparable to predicate. | Pass |
Device Removal Forces | To demonstrate that the removal forces are comparable to the predicate device. | FDA Guidance: "Peripheral Percutaneous Transluminal Angioplasty (PTA) and Specialty Catheters - Premarket Notification (510(k)) Submissions" April 2023 | Removal forces are comparable to predicate. | Pass |
Peak Tensile Strength Testing | To demonstrate that the device passes the peak tensile strength testing including all bonds and joints. | ISO 10555-1 2013, Section 4.6, Annex B | Device passes peak tensile strength testing. | Pass |
Flow Rate | To demonstrate that the flow rate is comparable to the predicate device. | ISO 10555-1 2013: Section 4.9 | Flow rate is comparable to predicate. | Pass |
Corrosion Resistance | To demonstrate that the device has no visual evidence of corrosion. | ISO 10555-1 2013, Section 4.5, Annex A | No visual evidence of corrosion. | Pass |
Radiopacity | To demonstrate that the distal marker band is clearly visible under typical fluoroscopic imaging conditions. | ISO 10555-1 2013, Section 4.2; ASTM F640-12 | Distal marker band is clearly visible. | Pass |
Kink Resistance | To demonstrate that shaft kink resistance is comparable to the predicate device and clinically relevant for the intended anatomical locations for use. | FDA Guidance: "Peripheral Percutaneous Transluminal Angioplasty (PTA) and Specialty Catheters - Premarket Notification (510(k)) Submissions" | Shaft kink resistance is comparable to predicate and clinically relevant. | Pass |
Particulates and Coating Integrity | To demonstrate the quantity and size of particles generated during simulated use are comparable to the predicates and reference devices. | FDA Guidance: "Peripheral Percutaneous Transluminal Angioplasty (PTA) and Specialty Catheters - Premarket Notification (510(k)) Submissions" | Particulates and coating integrity are comparable to predicates. | Pass |
Dynamic Burst | To demonstrate that the device withstands dynamic burst strength. | ISO 10555-1 2103, Annex G | Device withstands dynamic burst strength. | Pass |
Static Burst | To demonstrate that the device passes static burst pressure as specified in the test protocol. | ISO 10555-1 2013, Section F | Device passes static burst pressure. | Pass |
Shelf Life | Repeated bench tests after accelerated aging to demonstrate that the device performance is maintained over the proposed shelf-life (6 months). | ASTM D4332-22, ASTM D4169-22, ASTM F1980-21, ASTM F1886 / F1866M-16, ASTM 2096-11 (2019), ASTM F88/F88M:21 | Device performance maintained over 6-month shelf-life. | Pass |
Biocompatibility Tests:
Test Name | Objective (Implied) | Test Method / Standard or Guidance | Acceptance Criteria (Implied by "Results") | Reported Device Performance |
---|---|---|---|---|
Cytotoxicity | Assess cell toxicity. | ISO 10993-5 | No reactivity observed. | Non-cytotoxic |
Sensitization | Assess potential for allergic reactions. | ISO10993-10 | No evidence of delayed dermal contact sensitization. | Non-sensitizing |
Intracutaneous Reactivity | Assess localized irritation. | ISO 10993-23 | Scores from test article extracts were acceptable ( |
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(344 days)
Q'Apel Medical, Inc.
072 Aspiration Catheter: As part of the 072 Aspiration System, the 072 Aspiration Catheter with a compatible suction pump is indicated for use in the revascularization of patients with acute ischemic stroke secondary to intracranial large vessel occlusive disease (within the internal carotid, middle cerebral - M1 and M2 segments, basilar, and vertebral arteries) within 8 hours of symptom onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA therapy are candidates for treatment.
Aspiration Tubing: As part of the 072 Aspiration System, the Aspiration Tubing is intended to connect the 072 Aspiration Catheter to a compatible suction pump.
The 072 Aspiration Catheter is a single lumen, variable stiffness catheter. The catheter has a hydrophilic coating to reduce friction during use. The catheter includes radiopaque markers on the distal end for angiographic visualization and a Luer hub on the proximal end allowing attachments for flushing and aspiration. The Delivery Tool is an optional accessory for use with the 072 Aspiration Catheter and should be removed prior to aspiration. The 072 Aspiration Catheter, Delivery Tool. Rotating Hemostasis Valve, and Flow Switch are included in the package. The Aspiration Tubing is provided in a separate package. For the aspiration source, the 072 Aspiration Catheter is used in conjunction with a compatible suction pump with prespecified performance parameters that is connected using the Aspiration Tubing.
Here's a breakdown of the acceptance criteria and study information for the Q'Apel Medical, Inc. 072 Aspiration System, based on the provided document:
1. Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria are generally phrased as meeting "predetermined acceptance criteria" or specific ISO standards. The reported device performance for all bench tests and animal studies is "Pass," indicating that all samples met the defined criteria.
Note: For bench tests, specific numerical acceptance criteria are not detailed in the provided summary, only the general statement that "All samples met the predetermined acceptance criteria." For biocompatibility, the specific numerical acceptance criteria are listed.
Test Category | Acceptance Criteria (as stated) | Reported Device Performance |
---|---|---|
Bench Testing | ||
Visual Surface Requirement | Device meets visual surface requirements. | Pass |
Packaging Visual Inspection | Packaging meets visual inspection. | Pass |
Dimensional/Visual Inspection | Device dimensions conform to specifications. | Pass |
Liquid Leakage Under Pressure | Catheter joint strength meets freedom from leakage requirements of ISO 10555-1:2013, Annex C. | Pass |
Hub Aspiration Air Leakage | Device passes hub aspiration air leakage test of ISO 10555-1:2013, Annex D. | Pass |
Simulated Use | Effectiveness of device at retrieval of soft and firm clots and mechanical integrity after multiple passes. | Pass |
Flex Fatigue | Meets minimum value per specification for multiple passes in the simulated use model. | Pass |
Track and Advance Force | Test specimens meet track and advance force criteria. | Pass |
Tip Deflection | Test specimens meet tip deflection forces criteria and compare favorably to predicate catheters. | Pass |
Torque | Number of revolutions to failure of the Catheter in simulated anatomy meets criteria. | Pass |
Tip Elongation and Compression | Test specimens meet tip elongation and compression criteria. | Pass |
Peak Tensile | Tensile strength of catheter sections and bonds meets criteria after simulated use. | Pass |
Particulates, Coating Integrity | Integrity of hydrophilic coating evaluated after multiple insertion/withdrawal cycles, and particulates measured during simulated use compared to reference device, meet criteria. | Pass |
Flow Rate | Flow rate through a catheter meets ISO 10555-1, Annex E. | Pass |
Aspiration Flow Rate | Aspiration flow rate through the aspiration catheter meets criteria when connected to a constant vacuum source. | Pass |
Kink Resistance | Test specimen segments formed into a defined bend diameter meet kink resistance criteria. | Pass |
Corrosion Resistance | No visible corrosion immediately after Corrosion Testing procedure based on ISO 10555-1, Annex A. | Pass |
Radiopacity | Marker band is fluoroscopically visible. | Pass |
Burst Pressure-Static | Tested per ISO 10555-1:2013, Annex F, after simulated use, meets criteria. | Pass |
Burst Pressure-Dynamic | Minimum value per specification. | Pass |
Connectors for Intravascular | Hubs tested per ISO 80369-7. | Pass |
Lumen Collapse | Aspiration Catheter samples meet lumen patency under maximum applied vacuum pressures. | Pass |
Manual Syringe Injection Peak Pressure | Measure peak pressure during manual injection of contrast media with a syringe, meets criteria. | Pass |
Aspiration Tubing Bench Testing | ||
Dimensional/Visual Inspection | Aspiration Tubing meets all dimensional and visual specifications. | Pass |
Tensile Strength | Aspiration Tubing meets existing tensile strength specifications. | Pass |
Simulated Use Test | Aspiration Tubing passes testing specified in the simulated use test protocol. | Pass |
Resistance to Collapse and Leakage at Maximum Aspiration Pressures | Aspiration Tubing resistance to collapse at maximum aspiration pressure meets testing specified in the test protocol and does not show signs of leakage at maximum aspiration pressure. | Pass |
Flow Switch Functionality Testing | Flow Control Switch completely and immediately stops fluid flow after a specified number of ON/OFF cycles. | Pass |
Biocompatibility Testing (072 Aspiration Catheter and Delivery Tool) | ||
Cytotoxicity - MEM Elution | The achievement of a numerical grade greater than 2 is considered a cytotoxic effect. (Implicit acceptance: numerical grade ≤ 2) | Non-cytotoxic |
Sensitization | Magnusson and Kligman grades of 1 or greater in the test group generally indicate sensitization, provided grades of less than 1 are seen in control animals. If grades of 1 or greater are noted in control animals, then the reactions of test animals which exceed the most severe reaction in control animals are presumed to be due to sensitization. (Implicit acceptance: no statistically significant sensitization compared to control) | Non-sensitizing |
Irritation: Intracutaneous Reactivity | The requirements of the test were met if the final test article score was ≤ 1.0. | Non-irritating |
Acute Systemic Toxicity | If using five animals per group, the test article meets the requirement of the test if: 1. Two or more animals from the test group die. 2. Animal behavior, such as convulsions or prostration, occurs in two or more animals from the test group. 3. A final (end of study) body weight loss > 10% occurs in three or more animals from the test group. (Implicit acceptance: none of these conditions occurred) | Non-toxic |
Material Mediated Pyrogenicity | The requirements of the test were met if no rabbit showed an individual rise in temperature of 0.5 °C or more above its respective baseline temperature throughout the duration of the test. | Non-pyrogenic |
ASTM Hemolysis- Direct | The positive control's mean hemolytic index above the negative control must be ≥ 5% for the direct method. The negative control must display a mean hemolytic index of |
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(136 days)
Q'apel Medical, Inc.
The SelectFlex Neurovascular Access System Family is indicated for the introduction of interventional devices into the peripheral and neurovasculature.
The subject SelectFlex Neurovascular Access System Family is a line extension to expand the previously cleared device (K211893) by offering a new SelectFlex III 064 Neurovascular Access Catheter with a diameter of 6F, a 6F dilator, an introducer sheath, and a 4.5F Access Tool that can be used with the catheter to access the desired anatomy. The 4.5F Access Tool is an accessory provided with the SelectFlex III 064 Neurovascular Access Catheter and is packaged in the same sterile pouch with the SelectFlex III 064 Neurovascular Access Catheter and accessories as part of the SelectFlex Neurovascular Access System Family.
The provided text is a 510(k) Summary for a medical device (SelectFlex Neurovascular Access System Family) and does not describe a study that proves the device meets specific acceptance criteria in the context of an AI/human-in-the-loop diagnostic system. Instead, it describes nonclinical performance testing (bench testing) and biocompatibility testing conducted to demonstrate substantial equivalence to a legally marketed predicate device.
Therefore, many of the requested items (e.g., sample sized for the test set in an AI study, number of experts for ground truth, MRMC study, standalone performance, training set details) are not applicable to this document.
However, I can extract the acceptance criteria (goals) and reported performance (results) from the nonclinical performance data section.
Here's the information based on the provided text:
1. A table of acceptance criteria and the reported device performance
For the SelectFlex Neurovascular Access System Family (including the SelectFlex III 064 Neurovascular Access Catheter, 6F Dilator, and 4.5F Access Tool where applicable):
Test Name | Acceptance Criteria (Goal) | Reported Device Performance (Result) |
---|---|---|
Visual Surface Requirements | To demonstrate that the device meets the visual surface requirements. | Pass: All samples met the predetermined acceptance criteria. |
Dimensional Verification | To demonstrate that the device meets the dimensional requirements. | Pass: All samples met the predetermined acceptance criteria. |
Liquid Leakage Under Pressure | To demonstrate that the device passes the liquid leakage under pressure test. | Pass: All samples met the predetermined acceptance criteria. |
Hub Aspiration Air Leakage | To demonstrate that the device passes the hub aspiration air leakage test. | Pass: All samples met the predetermined acceptance criteria. |
Simulated Use/Usability | To demonstrate that the device passes testing specified in the simulated use test protocol. Simulated use testing includes usability assessment with multiple physicians. | Pass: All samples met the predetermined acceptance criteria. |
Flex Fatigue | To demonstrate that the device passes the flex fatigue test. | Pass: All samples met the predetermined acceptance criteria. |
Inflation Fatigue | To demonstrate that the device passes the inflation fatigue test. | Pass: All samples met the predetermined acceptance criteria. |
Burst Volume | To demonstrate that the device passes the burst volume test – tested to 2x the inflation volume. | Pass: All samples met the predetermined acceptance criteria. |
Torque Test | To demonstrate the device's ability to rotate 720 degrees (2 full revolutions) at the proximal end. | Pass: All samples met the predetermined acceptance criteria. |
Tip Deflection | To demonstrate that the tip deflection is comparable to the predicate device. | Pass: All samples met the predetermined acceptance criteria. |
Device Removal in Support and Tracking Modes | To demonstrate that the forces in both support and tracking modes are comparable to the predicate device. | Pass: All samples met the predetermined acceptance criteria. |
Peak Tensile Testing | To demonstrate that the device passes the peak tensile strength testing including all bonds and joints. | Pass: All samples met the predetermined acceptance criteria. |
Flow Rate | To demonstrate that the flow rate is comparable to the predicate device. | Pass: All samples met the predetermined acceptance criteria. |
Corrosion Resistance | To demonstrate that the device has no visual evidence of corrosion. | Pass: All samples met the predetermined acceptance criteria. |
Radiopacity | To demonstrate that the marker band is positioned at the distal tip of the catheter and is clearly visible under typical fluoroscopic imaging conditions. | Pass: All samples met the predetermined acceptance criteria. |
Particulates, Coating Integrity, Lubricity, Durability | To demonstrate the quantity and size of particles generated during simulated use are comparable to the predicate and reference devices. | Pass: All samples met the predetermined acceptance criteria. |
Static Burst | To demonstrate that the device passes static burst as specified in the test protocol. | Pass: All samples met the predetermined acceptance criteria. |
Shelf Life | To demonstrate that the device performance is maintained over the proposed shelf-life (6 months). | Pass: All samples met the predetermined acceptance criteria. |
Biocompatibility Testing:
Test Name | Acceptance Criteria (Goal) | Reported Device Performance (Result) | Conclusion |
---|---|---|---|
Cytotoxicity | Absence of reactivity | No reactivity was observed with the test article at 24 and 48 hours. | Non-cytotoxic |
Sensitization | No evidence of sensitization | The test article extracts showed no evidence of delayed dermal contact sensitization in the guinea pig maximization test. | Non-sensitizing |
Intracutaneous Reactivity | No irritation | The scores from test article extracts were 0 from the saline extract and 0 from the sesame seed oil extract. | Non-irritant |
Acute Systemic Toxicity | No abnormal clinical signs/toxicity | No abnormal clinical signs indicative of toxicity were observed for 72 hours. All animals were alive at the end of 72 hours and body weight changes were within acceptable parameters. | Non-toxic |
Material Mediated Pyrogenicity | No significant temperature rise | No rabbit temperature rise ≥ 0.5 °C. | Non-pyrogenic |
Hemolysis - Direct Contact and Extract Method | Non-hemolytic | Blank corrected hemolytic index: 0.15, 0.13. | Non-hemolytic |
Complement Activation | Results within acceptable range | Results within acceptable range as compared to the controls. | Not a Sc5b-9 complement activator |
Thrombogenicity | No adverse effects/thrombus | No adverse effects or clinical signs during test period and no thrombus score ≥ 2 for either test or control device. | Non-thrombogenic |
2. Sample sized used for the test set and the data provenance
The document does not specify sample sizes for each particular test, only stating "All samples" or providing a conclusion based on the samples tested. The data provenance is "bench testing" and "biocompatibility testing," which are laboratory-based tests of the device itself, not clinical data or data from human subjects.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable. This is a medical device performance and biocompatibility study, not an AI diagnostic study relying on expert ground truth. However, for "Simulated Use/Usability," it states "usability assessment with multiple physicians," but specific numbers or qualifications are not provided.
4. Adjudication method for the test set
Not applicable.
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. No AI component is mentioned.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done
Not applicable. No AI component is mentioned.
7. The type of ground truth used
For nonclinical performance, the "ground truth" is defined by established engineering and material science standards (e.g., ISO 10555-1, FDA guidance documents, ASTM D4332, AAMI TIR42, ISO 10993 series for biocompatibility). The device's physical properties and interactions are measured against these objective criteria.
8. The sample size for the training set
Not applicable. There is no AI training set as this is a device performance study.
9. How the ground truth for the training set was established
Not applicable. There is no AI training set.
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(45 days)
Q'Apel Medical Inc
The SelectFlex Neurovascular Access System Family is indicated for the introduction of interventional devices into the peripheral and neurovasculature.
The SelectFlex Neurovascular Access System Family consists of sterile, single-use intravascular catheters used to facilitate access to target vasculature during interventional procedures. The system is composed of a SelectFlex Neurovascular Access Catheter, a 3cc Mode Control Syringe, a 7Fr Peel Away Introducer, Luer Activated Valve and a Dilator (only for versions with a Long Hydrophilic coating to ease dermal entry). The SelectFlex Neurovascular Access Catheter comes in usable lengths of 95, 105 or 115cm. The SelectFlex Neurovascular Access Catheter has variable stiffness along its length and has a dual mode stiffness mechanism on the distal portion of the catheter that is activated by the user allowing the device to transition between tracking and support modes. The distal end of the SelectFlex Neurovascular Access Catheter comes in two options of a short hydrophilic coating length of 11.5cm or a long hydrophilic coating length of 30cm.
The provided FDA 510(k) summary for the SelectFlex Neurovascular Access System Family describes non-clinical performance data (bench testing) to demonstrate substantial equivalence to a predicate device, rather than a study involving human subjects or AI performance metrics. Therefore, many of the requested elements pertaining to AI studies, ground truth establishment, expert adjudication, and MRMC studies are not applicable or cannot be extracted from this document.
Here's the information that can be extracted and a clear indication where the requested information is not available in the document:
1. Table of Acceptance Criteria and Reported Device Performance
Test Description | Acceptance Criteria (Implied) | Reported Device Performance |
---|---|---|
Visual Surface Requirements (catheter and dilator) | All samples meet pre-determined acceptance criteria | PASS (All samples met the pre-determined acceptance criteria) |
Dimensional Verification (catheter and dilator) | All samples meet pre-determined acceptance criteria | PASS (All samples met the pre-determined acceptance criteria) |
Simulated Use/Usability | All samples meet pre-determined acceptance criteria | PASS (All samples met the pre-determined acceptance criteria) |
Flexion Fatigue | All samples meet pre-determined acceptance criteria | PASS (All samples met the pre-determined acceptance criteria) |
Inflation Fatigue | All samples meet pre-determined acceptance criteria | PASS (All samples met the pre-determined acceptance criteria) |
Burst Volume | All samples meet pre-determined acceptance criteria | PASS (All samples met the pre-determined acceptance criteria) |
ISO 80369-7: Small Bore Connectors for Hypodermic Applications | All samples meet pre-determined acceptance criteria | PASS (All samples met the pre-determined acceptance criteria) |
Particulate Count | All samples meet pre-determined acceptance criteria | PASS (All samples met the pre-determined acceptance criteria) |
Peak Tensile Testing (catheter and dilator) | All samples meet pre-determined acceptance criteria | PASS (All samples met the pre-determined acceptance criteria) |
Note: The document states "All samples met the pre-determined acceptance criteria" for each test, implying that the acceptance criteria were defined prior to testing, but the specific quantitative or qualitative criteria for each test (e.g., maximum allowable particulate count, specific tensile strength values, specific pass/fail conditions for visual inspection) are not explicitly detailed in this summary.
2. Sample size used for the test set and the data provenance
The document does not specify the exact sample size for each bench test beyond "All samples." It states "Simulated use testing includes a usability assessment with multiple physicians" but does not give a number for the physicians or the number of simulated cases.
Data Provenance: The data is from non-clinical bench testing and simulated use conditions, not from human clinical data or retrospective/prospective studies on patient data.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable. This is not an AI performance study requiring ground truth established by experts. For the "Simulated Use/Usability" test, it mentions "multiple physicians," but their specific number or qualifications are not provided as they are assessing usability, not establishing ground truth on patient data.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. This is not an AI performance study requiring adjudication of expert readings.
5. If a multi-reader, multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
No MRMC comparative effectiveness study was done. This document describes the substantial equivalence of a physical medical device (catheter system) based on bench testing, not an AI software.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
Not applicable. This document does not describe an AI algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
Not applicable. For the non-clinical bench tests, "ground truth" would be objective measurements against engineering specifications and industry standards (e.g., ISO 10555-1: 2013, ISO 80369-7) rather than clinical ground truth types like pathology or expert consensus.
8. The sample size for the training set
Not applicable. This document does not describe an AI system that requires a training set.
9. How the ground truth for the training set was established
Not applicable. This document does not describe an AI system.
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