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510(k) Data Aggregation

    K Number
    K251216
    Date Cleared
    2025-06-04

    (47 days)

    Product Code
    Regulation Number
    868.1400
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The CO2 Sampling lines are the single patient, disposable device intended for monitoring expired gases from the patient.
    Environment of use – hospital, sub-acute, and pre-hospital settings.
    Patient population – Patients requiring expired gas monitoring.

    Device Description

    Barbaras Development Inc. CO2 Sampling lines are the accessories in breathing system and intended for sampling of exhaled gases for monitoring, typically end-tidal CO2.

    The Barbaras Development Inc. CO2 sampling lines are used to connect between the patient's end of the breathing system and the distant analyzer, such as the capnograph monitor, along this tube, the patient's breath is continuously sampled. the gas sampling is exhaust only and there is no gas flow back to patient.

    The Barbaras Development Inc. CO2 Sampling Lines are a disposable, single patient use that allow to sample of patients exhaled gases. It consists of flexible extruded plastic tubes with and standard connectors on each end. We will present several different configurations like have the filter or without filter in the middle which have been tested and compared to predicates.

    The Barbaras Development Inc. CO2 Sampling Lines are offered in the following models: 0184 CO2 Sampling line, 0184T CO2 Sampling line, 0139 CO2 Sampling line, 0182 CO2 Sampling line.

    Gas sampling devices are not specific to a particular exhaled gas monitor. Almost all gas sampling line are connected to the monitor via a standard luer fitting, whether it is a female or male fitting.

    AI/ML Overview

    The provided FDA 510(k) clearance letter details the clearance of CO2 Sampling lines manufactured by Barbaras Development Inc. The clearance is based on substantial equivalence to a predicate device, Tylenol Medical Instruments Co., Ltd - K181981 - CO2 sampling line, and a reference device, ProMedic – Gas Sampling Lines – K023579.

    It's important to note that this document is a 510(k) summary for a medical device that is an accessory (CO2 sampling lines) and not an AI/ML powered diagnostic or prognostic tool. Therefore, many of the requested elements, such as MRMC studies, effect size of AI assistance, standalone algorithm performance, number of experts for ground truth, adjudication methods, and training set details, are not applicable to this type of device and are not present in the provided text. The evaluation focuses on physical characteristics, material compatibility, and basic performance parameters against established standards.

    Here's the breakdown of the available information based on your request:

    1. Table of Acceptance Criteria and Reported Device Performance

    The provided document describes "Non-Clinical Testing Summary" and "Performance testing" categories, indicating that these were the acceptance criteria for the device. The reported performance is generally stated as "performed equivalent to the predicate" and "All testing demonstrated that the subject devices are substantially equivalent to the predicate." No specific numerical results are provided in this summary.

    Acceptance Criteria CategorySpecific Tests/CriteriaReported Device Performance
    Material/DesignBiocompatibility (Cytotoxicity, Sensitization, Irritation)Similar to predicate, met ISO 10993 testing requirements for skin contact (limited duration < 24 hours). The gas sampling line is exhaust only with no gas flow back to the patient.
    Mechanical/PhysicalAge testingPerformed equivalent to the predicate.
    Mechanical testingPerformed equivalent to the predicate.
    Luer FittingMeets ISO 80369-7. (Predicate used ISO 594-2, but subject device meets the updated standard)
    Flow / leaksMeets ISO 80601-2-55. (Referred to as "Back pressure (Resistance to flow)" in the subject device's testing)
    Strength of bondsPerformed equivalent to the predicate. (Referred to as "Bond strength (Tensile strength of connections)" in the subject device's testing)
    Tensile StrengthPerformed equivalent to the predicate. (Referred to as "Bond strength (Tensile strength of connections)" in the subject device's testing)
    Functional EquivalenceIndications for UseSimilar to predicate, both monitor exhaled gases.
    Environment of UseIdentical to predicate (hospital, sub-acute, pre-hospital).
    Patient PopulationSimilar to predicate (pediatrics to adults/neonates).
    Duration of UseSimilar to predicate (single patient, disposable, less than 24h).
    PrescriptiveSimilar; both are prescription devices.
    Mode of OperationSimilar (conduit from patient interface to monitor).
    Gas sampling connectionSimilar (Luer slip fit or luer lock).
    Sampling tubing specsSubject device IDs (1.0 & 1.5 mm) fall within range of predicate (1.10 mm) and reference (1.27 mm & 1.524 mm). Lengths differ but are generally comparable as sample lines.
    MaterialsSimilar (PVC tubing, Polypropylene/ABS connectors).

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

    The document does not specify the sample size used for the non-clinical testing (test set) or any specific data provenance beyond the general statement that testing was performed.

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

    Not applicable. This device is a passive accessory (CO2 sampling line) and does not involve subjective interpretation or diagnosis by experts to establish a "ground truth" as would be the case for an AI-powered diagnostic device. Its performance is measured against engineering standards and functional equivalence.

    4. Adjudication Method for the Test Set

    Not applicable. There is no "ground truth" established by experts that would require an adjudication method for this type of device. Performance is determined by objective physical and functional tests against industry standards.

    5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

    Not applicable. This letter is for a CO2 sampling line, which is a physical accessory, not an AI-powered medical device.

    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 or AI.

    7. The type of ground truth used

    The "ground truth" for this device's performance evaluation is established through objective engineering standards and performance specifications (e.g., ISO 80369-7 for luer fittings, ISO 80601-2-55 for flow/leaks, and ISO 10993 for biocompatibility) and comparative functional equivalence to legally marketed predicate devices.

    8. The sample size for the training set

    Not applicable. This device does not involve a training set as it is not an AI/ML or algorithm-based device.

    9. How the ground truth for the training set was established

    Not applicable. This device does not involve a training set.

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