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510(k) Data Aggregation

    K Number
    K222167
    Date Cleared
    2022-10-18

    (89 days)

    Product Code
    Regulation Number
    876.5665
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Reprocessing Products Corporation (RPC)

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

    E-Z Chek® Residual Chlorine Test Strips (K100-0101B) provide accurate and convenient means of measuring the concentration of free chlorine remaining in water when rinsing out equipment following disinfection. A rapid screening qualitative method will detect levels above 0.5ppm (mg/L) while the 30 second semi-quantitative method allows interpolation of concentration between 0ppm and 5ppm. The qualitative method can be used to determine that chlorine has been adequately rinsed from the equipment. The semi-quantitative method may be useful when corrective measures are undertaken on equipment retaining higher levels of chlorine for extended periods and for testing any containers disinfected with free chlorine (bleach).

    Device Description

    Reprocessing Products Corporation (RPC) E-Z Chek® Residual Chlorine Test Strips (K100-0101B) is semi-quantitative or qualitative, reagent test strip comprised of a pad impregnated with chemicals, which change color upon contact with free chlorine and combined chlorine (monochloramines). The pad is attached to a plastic strip for handling.

    AI/ML Overview

    The Reprocessing Products Corporation (RPC) E-Z Chek® Residual Chlorine Test Strips (K100-0101B) are designed to provide an accurate and convenient method for measuring the concentration of free chlorine remaining in water after rinsing equipment following disinfection.

    Here's an analysis of the acceptance criteria and the study conducted for the device:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document doesn't explicitly state quantitative acceptance criteria for device performance. Instead, it focuses on demonstrating that the subject device consistently generates color change that meets the color blocks for reference solution concentrations, similar to the predicate device. The performance is assessed qualitatively (for detecting levels above 0.5 ppm) and semi-quantitatively (for interpolating concentrations between 0 ppm and 5 ppm).

    From the "Non-clinical Performance Data" section:
    "The test data confirms the subject device and the predicate device consistently generates color change which meets the color block(s) for the reference solution concentrations tested. This data demonstrates appropriate performance for the detection of residual free chlorine in rinse water that was used in disinfection of hemodialysis equipment fluid pathways."

    Given this, the table would look like this:

    Acceptance Criterion (Implied)Reported Device Performance
    Consistently generate color change that meets reference color blocks for tested solution concentrations.Achieved: The test data confirms the E-Z Chek® Residual Chlorine Test Strips consistently generate color change which meets the color blocks for the reference solution concentrations tested.
    Appropriately perform for the detection of residual free chlorine in rinse water used in hemodialysis equipment disinfection.Achieved: The data demonstrates appropriate performance for the detection of residual free chlorine in rinse water that was used in disinfection of hemodialysis equipment fluid pathways, indicating it functions as intended for both qualitative (detecting > 0.5 ppm) and semi-quantitative (interpolating 0-5 ppm) methods.

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

    The document does not explicitly state the sample size used for the test set. It mentions "reference solution concentrations tested" implicitly indicating multiple concentrations were used. The data provenance is not specified (e.g., country of origin, retrospective/prospective), but it is a non-clinical performance study.

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

    The document does not mention the use of experts to establish ground truth for the test set. The ground truth appears to be established by using "reference solution concentrations," which implies a controlled laboratory setting where the actual chlorine concentrations are known.

    4. Adjudication Method for the Test Set:

    No adjudication method is described. The comparison is against "color block(s) for the reference solution concentrations tested," suggesting a direct visual comparison by the test personnel.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done:

    No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. The study is a non-clinical performance evaluation comparing the subject device's color change against known reference solutions and its predicate device. This device is a test strip, not an AI-assisted diagnostic tool, so such a study would not be applicable.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done:

    No, a standalone (algorithm only) performance study was not done. This device is a manual test strip that requires human observation and interpretation of color change to determine chlorine levels. It does not involve an algorithm.

    7. The Type of Ground Truth Used:

    The ground truth used is based on known, controlled reference solution concentrations of free chlorine in water. These are prepared solutions with precisely measured amounts of chlorine.

    8. The Sample Size for the Training Set:

    This device is a chemical test strip, not a machine learning or AI-driven product. Therefore, there is no "training set" in the context of algorithm development. The performance data is generated through testing the strips against various known concentrations.

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

    As there is no training set for this chemical test strip, this question is not applicable. The device's performance is inherently based on its chemical reactivity and the visual interpretation of the resulting color change against a predefined color chart.

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    K Number
    K132344
    Date Cleared
    2014-02-25

    (211 days)

    Product Code
    Regulation Number
    876.5665
    Reference & Predicate Devices
    N/A
    Why did this record match?
    Applicant Name (Manufacturer) :

    REPROCESSING PRODUCTS CORPORATION (RPC)

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

    The Reprocessing Products Corporation (RPC) E-Z Chek® Ozone Test Strips (K100-0111) are designed to indicate the presence of ozone in water used in hemodialysis. The test strips will measure equal to 0.0, 0.05, 0.1, 0.2, 0.3, 0.4, and >0.5 mg/L.

    Device Description

    Device is semi-quantitative, reagent test strip comprised of a pad impregnated with chemicals, which change color upon contact with Ozone. The pad is attached to a plastic strip for handling.

    AI/ML Overview

    Here's an analysis of the provided text regarding the E-Z Chek® Ozone Test Strips, focusing on acceptance criteria and the study:

    1. Table of Acceptance Criteria and Reported Device Performance

    Based on the provided text, the acceptance criteria are implicitly performance-driven, relating to the ability of the test strips to accurately detect and differentiate ozone concentrations.

    Acceptance Criteria (Stated)Reported Device Performance
    Designed to indicate the presence of ozone in water used in hemodialysis.The data confirms the product consistently generates color change which meets the color block for the reference solution concentration. These data demonstrate appropriate performance for use in hemodialysis water used in treatment. (Implies successful indication of ozone presence)
    Will measure equal to 0.0, 0.05, 0.1, 0.2, 0.3, 0.4, and >0.5 mg/L. (Specificity of measurable concentrations)The data confirms the product consistently generates color change which meets the color block for the reference solution concentration. (Implies accuracy across the specified range when compared to reference solutions.)
    Will detect ozone concentrations equal to and above 0.0 ppm (mg/L) for Ozone in water used to prepare dialysate. (Lower detection limit)The data confirms the product consistently generates color change which meets the color block for the reference solution concentration. (Implies successful detection at or above 0.0 ppm.)
    Produce a color change which correlates to the concentration of ozone in the test water. (Accuracy and correlation)The data confirms the product consistently generates color change which meets the color block for the reference solution concentration. (This directly addresses the correlation and accuracy of the color change.)

    Study Information:

    The provided document offers a high-level summary of the device's performance but lacks detailed information about the specific study design and methodology. Due to this limitation, many of the requested points cannot be fully addressed.

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

    • Sample Size: Not specified in the provided text. The document states "The data confirms the product consistently generates color change...", but does not provide numbers of tests, samples, or replicates.
    • Data Provenance: Not specified. It's highly probable the testing was conducted internally by Reprocessing Products Corporation, but the location and whether it was retrospective or prospective is not mentioned.

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

    • Number of Experts: Not applicable/not specified. This device is a chemical test strip with a visual color change. The ground truth would be established by preparing water samples with known, precise concentrations of ozone (reference solutions), not by expert interpretation of the test strip results in a clinical setting.
    • Qualifications of Experts: Not applicable.

    4. Adjudication Method for the Test Set

    • Adjudication Method: Not applicable. As noted above, the assessment likely involves comparing the color change on the strip to a pre-defined color chart, with the "ground truth" being the known ozone concentration of the reference solution. This is a direct chemical measurement, not a subjective interpretation requiring adjudication.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and Effect Size

    • MRMC Study: No, an MRMC study was not done. These studies are typically for imaging or diagnostic devices where human readers interpret results, often with and without AI assistance to measure reader improvement. The E-Z Chek® Ozone Test Strips are a direct chemical test.
    • Effect Size of Human Reader Improvement: Not applicable.

    6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done

    • Standalone Performance: While the principle of comparing the strip's color to a color chart is "standalone" in that a human is reading the result from the strip itself, there isn't an "algorithm" in the typical sense of AI/machine learning. The device is the algorithm (chemical reaction + color change). The performance data is the standalone performance of the physical test strip.

    7. The Type of Ground Truth Used

    • Type of Ground Truth: The ground truth used would be reference solutions with known, precisely measured concentrations of ozone. The test strips' color changes are then compared against these known concentrations. This is implied by the statement "The data confirms the product consistently generates color change which meets the color block for the reference solution concentration."

    8. The Sample Size for the Training Set

    • Sample Size for Training Set: Not applicable/not specified. Chemical test strips are developed through chemical formulation and calibration, not typically by training a machine learning model on a "training set" of data in the way an AI-powered diagnostic device would be. The development likely involved numerous trials to achieve the desired chemical reaction and color scale, but this isn't a "training set" in the AI sense.

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

    • How Ground Truth for Training Set Was Established: Not applicable in the context of an AI training set. For chemical test strip development, the "ground truth" in development would be the precisely prepared and verified ozone concentrations of water samples used to calibrate the color scale and ensure the chemical reagents react appropriately. This typically involves analytical chemistry techniques to confirm the actual ozone levels in control solutions.
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