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510(k) Data Aggregation
(449 days)
VASCA, INC.
The LifeSite Hemodialysis Access System provides fully implantable blood access for chronic (long term) hemodialysis. It is intended for use in patients who would otherwise be treated with standard cuffed hemodialysis catheters. A 70% isopropyl alcohol solution is used in conjunction with the LifeSite System for the localized cleansing of the access site (buttonhole), valve pocket and LifeSite valve.
The LifeSite Hemodialysis Access System is a dialysis access device comprised of two separate valves and cannulas. One valve/cannula is used as the draw and the other valveleannula is the return. The cannulas are placed in cither the internal or external jugular or subclavian veins. They are manufactured from radiopaque silicone. The cannula ends connect to the valves, which are placed in a subcutancous pocket. The values are manufactured from titanium and stainless steel. When accessed with a 14 gauge, fistula needle the valves internal pinch clamp opens allowing access to the vein via the cannula.
Here's an analysis of the provided text regarding the acceptance criteria and supporting studies for the LifeSite® Hemodialysis Access System:
1. Table of Acceptance Criteria and Reported Device Performance
The document provides acceptance criteria mainly through a simulated use test for device longevity and a clinical study for patient safety and equivalence.
Acceptance Criteria | Reported Device Performance |
---|---|
Simulated Use Testing: | |
Device functionality over long-term use (6000 actuations, approximately 38 years) | All valves operated properly for 6000 actuations. |
Leak-testing after every 100 actuations | No leaks were observed after every 100 actuations. |
Clinical Study: | |
Patient safety for chronic (long-term) hemodialysis use | Safe for use in patients who require chronic (long-term) hemodialysis when used with 70% isopropyl alcohol. |
Substantial equivalence to predicate device (LifeSite Hemodialysis Access System and Medical Components Inc. Tesio®-Cath Catheter) | Found to be substantially equivalent to the predicate device. |
2. Sample Size and Data Provenance
- Test Set (Clinical Study): 67 patients, with 25 of those patients on dialysis using LifeSite for 12 months in the alcohol trial.
- Data Provenance: The document does not explicitly state the country of origin. It is a clinical study, implying prospective data collection.
3. Number of Experts and Qualifications for Ground Truth
- The document does not mention the use of experts to establish a "ground truth" in the traditional sense of image interpretation or diagnostic accuracy for this device. The evaluation is based on direct device performance (simulated use) and clinical outcomes (patient safety and equivalence).
4. Adjudication Method
- Adjudication methods like 2+1 or 3+1 are typically used for establishing ground truth in diagnostic accuracy studies where expert consensus is needed to determine the true positive/negative status of a case. This is not applicable to the studies described for the LifeSite system, which focus on device function and clinical safety/equivalence.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- No, an MRMC comparative effectiveness study was not done. This type of study is relevant for evaluating the impact of AI on human reader performance in diagnostic tasks, which is not the purpose of the studies presented for the LifeSite Hemodialysis Access System.
6. Standalone Performance Study
- Yes, a form of standalone performance was done through the "Simulated use testing of the LifeSite Valve." This test evaluated the device's functionality and integrity (leak-testing) independent of human interaction during its long-term simulation. The clinical study also assesses the device's performance in a standalone capacity within patients, albeit with human use involved.
7. Type of Ground Truth Used
- Simulated Use Testing: The "ground truth" was the physical performance and integrity of the device itself (e.g., proper operation, absence of leaks).
- Clinical Study: The "ground truth" was established through patient safety outcomes and a comparison of the device's performance against a predicate device to determine substantial equivalence. This would involve clinical observations, adverse event tracking, and potentially various clinical measurements relevant to hemodialysis access.
8. Sample Size for the Training Set
- The document does not describe a "training set" in the context of an AI/machine learning model. The studies described are for the validation of a medical device, not the development of an algorithm.
9. How Ground Truth for the Training Set Was Established
- Not applicable, as no training set for an AI/machine learning model is described in the provided text.
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(90 days)
VASCA, INC.
The LifeSite® Hemodialysis Access System provides fully-implantable blood access for patients who require hemodialysis while waiting for creation and/or maturation of permanent access. A 70% isopropyl alcohol solution is used in conjunction with the LifeSite System for the localized cleansing of the injection site, valve pocket, and LifeSite valve.
The LifeSite Hemodialysis Access System consists of two primary components: (1) the LifeSite Hemodialysis Access Cannula, and (2) the LifeSite Hemodialysis Access Valve. The valve is surgically placed in a subcutaneous pocket. The cannula, placed into an internal jugular or subclavian vein, is connected to the valve by means of the barbed connector on the valve stem. Vascular access can be achieved by accessing the valve with a needle.
Accessories to the LifeSite Hemodialysis Access System, including a tunneler, introducer and Medisystems needle, will be packaged with the system and sold as a unit. Another accessory, the LifeSite Hemodialysis Cannula Exchange Kit will be sold separately.
Here's an analysis of the acceptance criteria and the study information for the VASCA LifeSite Hemodialysis Access System, based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria Category | Reported Device Performance |
---|---|
Safety and Effectiveness | Met all clinically relevant acceptance criteria. |
Comparison to Predicate (where applicable) | Performance was equivalent to or better than that of the relevant predicate. |
Leak Prevention | Addressed as a key safety concern. (Implied to be met based on overall performance). |
Adequate Flow Rates | Addressed as a key effectiveness concern. (Implied to be met based on overall performance). |
Connection Strength | Addressed as a key safety/effectiveness concern. (Implied to be met based on overall performance). |
2. Sample Size Used for the Test Set and Data Provenance
- Test Set Sample Size: A "prospective, randomized, multi-center clinical trial" was conducted. The exact number of patients or devices included in the trial is not specified in the provided document.
- Data Provenance: The study was a "multi-center clinical trial," implying data was collected from multiple clinical sites. The specific country of origin is not explicitly stated, but the FDA 510(k) submission context suggests it was likely in the United States, or at least compliant with US regulatory standards. The study was prospective and randomized.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
- The document describes a clinical trial comparing the device to a predicate. It does not mention the use of "experts" in the sense of establishing a ground truth for a test set that would typically involve image or data interpretation. Instead, the "truth" or efficacy was likely determined through clinical outcomes and assessments within the trial itself. Therefore, this section is not applicable in the traditional sense of expert consensus for a test set in this context. The clinical trial itself served as the mechanism to evaluate the device's performance.
4. Adjudication Method for the Test Set
- The document states it was a "prospective, randomized, multi-center clinical trial comparing efficacy." It does not explicitly describe an adjudication method for specific events or outcomes within the clinical trial. Clinical trials typically have predefined endpoints and assessment protocols, which would implicitly include how outcomes are determined and reviewed, but a specific "adjudication method" (e.g., 2+1 reader consensus for image interpretation) is not mentioned.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
- No, an MRMC comparative effectiveness study, which typically refers to studies involving multiple human readers interpreting cases with and without AI assistance, was not done. This study was a clinical trial comparing the device's efficacy against a predicate device.
6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done
- Not applicable. The device is a physical medical device (hemodialysis access system), not an algorithm or AI software. Therefore, the concept of "standalone algorithm performance" does not apply. The performance evaluation was based on a combination of in vitro testing and a clinical trial of the physical device.
7. Type of Ground Truth Used
- The "ground truth" for the clinical trial was established through clinical outcomes and efficacy observed directly in patients undergoing hemodialysis, as compared to a predicate device. This includes assessments of safety and efficacy parameters relevant to hemodialysis access (e.g., ability to prevent leaks, provide adequate flow rates, connection strength, and overall clinical performance).
8. Sample Size for the Training Set
- Not applicable. As the device is a physical medical device and not an AI/algorithm, there is no "training set" in the context of machine learning. The device design and in vitro testing contribute to its development, but not as a "training set."
9. How the Ground Truth for the Training Set Was Established
- Not applicable, as there is no "training set" for this physical medical device.
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