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510(k) Data Aggregation

    K Number
    K231900
    Manufacturer
    Date Cleared
    2023-07-25

    (27 days)

    Product Code
    Regulation Number
    880.5860
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    A-TAP (previously called Arthrotap)

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

    The A-TAP is intended for use by healthcare professionals for general purpose fluid aspiration/injection.

    Device Description

    The A-TAP device is a fluid switching medical device consisting of a clear plastic barrel body, a sliding rod, two 6% female Luer lock connections, and one 6% male Luer lock connection. The internal surface of the device barrel body is lubricated with polydimethylsiloxane (silicone). The A-TAP is a single-use only, disposable, non-pyrogenic and sterilized by Gamma irradiation.

    AI/ML Overview

    The provided text is a 510(k) summary for the A-TAP device, which is a fluid switching medical device. The submission is a Special 510(k) due to modifications made to the previously cleared Arthrotap device (K201816) by Elcam Medical.

    The acceptance criteria and study proving the device meets these criteria concern the physical and biological characteristics of the device, not an AI/ML-driven diagnostic or prognostic tool. Therefore, the questions related to AI/ML performance metrics, sample sizes for training/test sets for AI, expert adjudication of ground truth, and MRMC studies are not applicable in this context.

    This document details the tests performed to demonstrate that the modified A-TAP device is substantially equivalent to its predicate.

    Here's a breakdown of the relevant information provided:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document lists performance tests conducted to demonstrate substantial equivalence, implying that passing these tests served as the acceptance criteria. The "Reported Device Performance" is stated by the successful completion of all listed tests.

    Acceptance Criteria (Measured by Passing Standard/Method)Reported Device Performance
    Biocompatibility:All tests successfully passed
    Cytotoxicity (ISO 10993-5)
    Irritation (ISO 10993-10)
    Sensitization (ISO 10993-10)
    Acute Systemic Toxicity (ISO 10993-11)
    Material-Mediated Pyrogenicity (ISO 10993-11/USP)
    Hemolysis (ISO 10993-4)
    Non-Clinical (Bench) Testing:All tests successfully passed
    ISO 7886-1:2017 (Sterile hypodermic syringes for single use)
    ISO 80369-7:2021 (Small-bore connectors for liquids and gases)
    ISO 8536-10:2015 (Infusion equipment for medical use)
    ANSI/AAMI/ISO 11737-1:2018 (Sterilization of Health Care Products - Microbiological Methods - Part 1)
    ANSI/AAMI/ISO 11737-2:2019 (Sterilization of Medical Devices - Microbiological Methods - Part 2)
    Sterilization and Shelf-Life:All tests successfully passed
    ANSI/AAMI/ISO TIR13004:2013 (R2016)/ ISO 13004:2022 (Radiation - Substantiation of Selected Sterilization Dose)
    ANSI/AAMI/ISO 11137-1:2006/(R)2015 [Including: Amendment 1 (2013) and Amendment 2 (2019)] (Sterilization of Health Care Products - Radiation - Part 1)
    USP Bacterial Endotoxin
    Package Integrity:All tests successfully passed
    ASTM F 1980-16 (Accelerated Aging of Sterile Barrier Systems)
    ASTM D 4169-16 (Performance Testing of Shipping Containers and Systems)
    ASTM F2096-11 (Reapproved 2019) (Detecting Gross Leaks in Packaging)
    ASTM F88/F88M-21 (Seal Strength of Flexible Barrier Materials)
    USP Particulate Matter in Injections

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

    The document concerns a physical medical device and its components, not a data-driven AI/ML model for which test sets from patients are required. Therefore, typical "sample sizes" in the context of clinical data for AI are not applicable. The tests performed are laboratory-based, often involving a certain number of device units or material samples as specified by the respective ISO/ASTM standards. The data provenance is laboratory testing conducted by or for Elcam Medical. The document does not specify country of origin for the testing itself, nor if it was retrospective or prospective in the clinical sense, as it refers to engineering verification and validation testing.

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

    Not applicable. Ground truth for a physical device's performance (e.g., material compatibility, structural integrity, sterility) is established by adherence to recognized international and national standards (ISO, ASTM, USP) and the results of the specified tests, rather than expert consensus on clinical data.

    4. Adjudication Method for the Test Set:

    Not applicable for a physical device. Performance is determined by meeting the pass/fail criteria defined within the referenced standards.

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

    Not applicable. This type of study is relevant for diagnostic imaging AI, not for a fluid switching device.

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

    Not applicable for a physical medical device without AI components.

    7. The Type of Ground Truth Used:

    The ground truth used for proving the device meets acceptance criteria is based on standardized test methods and their defined performance criteria. For example, biocompatibility is evaluated against specific biological responses according to ISO standards, and mechanical integrity is evaluated against criteria set by ISO or ASTM standards. This is not derived from expert consensus, pathology, or outcomes data in the typical clinical sense, but from engineering and material science principles.

    8. The Sample Size for the Training Set:

    Not applicable. This device does not involve an AI/ML algorithm that requires a training set.

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

    Not applicable, as there is no training set for an AI/ML algorithm.

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    K Number
    K201816
    Device Name
    ARTHROTAP
    Date Cleared
    2020-10-16

    (107 days)

    Product Code
    Regulation Number
    880.5860
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    ARTHROTAP

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

    The ARTHROTAP is intended for use by healthcare professionals for general purpose fluid aspiration.

    Device Description

    The ARTHROTAP is a fluid switching medical device consisting of a clear plastic barrel body, a sliding rod, two 6% female Luer lock connections, and one 6% male Luer lock connection. The internal surface of the ARTHROTAP device barrel body is lubricated with polydimethylsiloxane (silicone). The ARTHROTAP is single-use only, non-pyrogenic, and sterilized by electron beam irradiation.

    AI/ML Overview

    The medical device in question, ARTHROTAP, is a fluid switching medical device intended for general purpose fluid aspiration/injection. The document describes its substantial equivalence to a predicate device, the ANUTRA Feedback Aspiration Syringe (K143757), based on a comparison of technological characteristics and performance testing.

    Here's a breakdown of the requested information based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria are generally established by meeting relevant ISO and ASTM standards. The reported device performance indicates that ARTHROTAP successfully passed these tests.

    Acceptance Criteria CategorySpecific Tests/Standards MetReported Device Performance
    General Syringe PerformanceISO 7886-1:2017 (Sterile hypodermic syringes for single use) sections covering: General, Limits for Acidity or Alkalinity, Limits for Extractable Metals, Lubricant, Barrel, Piston/plunger assembly (Annex B), Nozzle, Freedom from air and liquid leakage (Annex B & D), Force to operate piston (Annex E), Fit of plunger in barrel, Packaging, Labeling.ARTHROTAP passed all applicable sections, demonstrating its general safety and functionality as a single-use fluid aspiration/injection device. Sections for graduated capacity and scale were not applicable as ARTHROTAP does not have these features. Dead space was also not applicable. The device successfully demonstrated the ability to hold a seal.
    Small-Bore ConnectorsISO 80369-7:2016 (Small-bore connectors) and ISO 80369-20:2015 (Common Test Methods) sections covering: Dimensional Requirements, Liquid leakage from fitting assembly under pressure (Annex C), Sub-atmospheric Air leakage into fitting assembly during aspiration (Annex D), Stress Cracking (Annex E), Resistance to separation from axial load (Annex F), Resistance to separation from unscrewing (Annex G), Resistance to overriding (Annex H).ARTHROTAP successfully met these standards, ensuring secure and leak-free connections to other medical devices like syringes and needles, addressing potential concerns about its multiple Luer connectors compared to the predicate.
    Sterile Barrier PackagingASTM F1980-16 Environmental Conditioning, ASTM D4169-16 Distribution Simulation, Label Inspection for overall adhesion and legibility, ASTM F2096-11 Standard Test Method for Detecting Gross Leaks in Porous Medical Packaging by Internal Pressurization (Bubble Leak), ASTM F88 / F88M-15 Standard Test Method for Seal Strength of Flexible Barrier Materials.Packaging tests demonstrated that the ARTHROTAP maintains its sterility and integrity throughout environmental conditioning and distribution, and its labels are durable and legible. The device achieves a level of safety equivalent to the predicate.
    BiocompatibilityISO 10993-1:2009 (Biocompatibility) sections covering: Cytotoxicity by Elution Test, Maximization Test for Delayed Hypersensitivity, Intracutaneous Reactivity, Acute Systemic Toxicity, Evaluation of Hemocompatibility: Interaction with Blood. Also, ISO 10993-12 & USP (Pyrogenicity), USP 40 Bacterial Endotoxin (LAL), USP Particulate Matter In Injections.ARTHROTAP was tested and found to meet all specified biological requirements as outlined in ISO 10993-1 and FDA guidance. This included all tests conducted on the predicate plus additional tests for Pyrogenicity and LAL, demonstrating safety substantially equivalent or better than the predicate. The device is safe for patient contact.
    SterilizationBioburden (ANSI/AAMI/ISO 11737-1:2006), Bioburden Validation (ANSI/AAMI/ISO 11737-1:2006), VD Maximum Dose (ANSI/AAMI/ISO TIR13004:2013), Sterility Verification (ANSI/AAMI/ISO 11737-2:2009/(R) 2014), Dose Mapping (ISO 11137-1:2006), Device Sterilization (ANSI/AAMI/ISO 11737-2:2009/(R) 2014).Sterilization testing demonstrated the safety of ARTHROTAP concerning sterility, using established and recognized methods. While not explicitly listed for the predicate, these tests confirm the ARTHROTAP's sterility. The use of e-beam irradiation, a "Category A" method, is considered equivalent to gamma irradiation used for the predicate.

    2. Sample size used for the test set and the data provenance

    The document does not specify the exact sample sizes used for each individual test. It states that "Performance testing of ARTHROTAP was conducted and evaluated in accordance with [various ISO and ASTM standards]".

    The data provenance is from non-clinical testing conducted by the manufacturer, Accuro Technologies Inc., to demonstrate substantial equivalence to a legally marketed predicate device. This is typically laboratory-based testing, not human patient data. The country of origin of the data is not explicitly stated, but the manufacturer is based in Canada.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    This information is not applicable to this type of device and study. The "ground truth" for the performance tests outlined (e.g., leakage, material strength, biocompatibility) is determined by meeting the quantitative and qualitative requirements of the respective international standards (ISO, ASTM). This is not typically established by human expert consensus or qualifications in the same way clinical imaging or diagnostic device studies do.

    4. Adjudication method for the test set

    This information is not applicable. Adjudication methods (like 2+1, 3+1) are usually relevant for expert consensus on clinical findings, particularly in studies involving interpretation of medical images or symptoms. The described tests for ARTHROTAP are objective performance and safety evaluations against established technical 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

    There is no mention of an MRMC comparative effectiveness study, AI assistance, or human readers. This device is a fluid switching component, not a diagnostic imaging or AI-powered device.

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

    There is no mention of any algorithm-only or AI-related performance testing. The ARTHROTAP is a physical medical device, not a software algorithm.

    7. The type of ground truth used

    The "ground truth" for this device's evaluation is based on established objective technical standards (ISO and ASTM) and biocompatibility guidelines. For example:

    • Performance: Meeting specified limits for leakage, operating force, dimensional requirements, etc., as defined by the international standards.
    • Biocompatibility: Absence of cytotoxicity, sensitization, irritation, systemic toxicity, hemolysis, particulate matter, and detection of pyrogens/endotoxins, as per ISO 10993 and USP standards.
    • Sterilization: Demonstration of sterility assurance level (SAL) according to ISO standards.

    8. The sample size for the training set

    This information is not applicable. The ARTHROTAP is a physical medical device, not a machine learning model, so there is no concept of a "training set."

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

    This information is not applicable, as there is no training set for this device.

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