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510(k) Data Aggregation

    Why did this record match?
    Device Name :

    Catheter; ViewFlex™ Eco Reprocessed ICE Catheter; Advisor™ HD Grid Mapping Catheter, Sensor Enabled™; Advisor
    ™ HD Grid X Mapping Catheter, Sensor Enabled™; Agilis™ NxT Steerable Introducer; Agilis™ NxT Steerable

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

    ViewFlex™ Xtra ICE Catheter
    The ViewFlex™ Xtra ICE Catheter is indicated for use in adult and adolescent pediatric patients to visualize cardiac, structures, blood flow and other devices within the heart.

    ViewFlex™ Eco Reprocessed ICE Catheter
    The ViewFlex™ Eco Reprocessed Catheter is indicated for use in adult and adolescent pediatric patients to visualize cardiac structures, blood flow and other devices within the heart.

    Advisor™ HD Grid Mapping Catheter, Sensor Enabled™
    The Advisor™ HD Grid Mapping Catheter, Sensor Enabled™, is indicated for multiple electrode electrophysiological mapping of cardiac structures in the heart, i.e., recording or stimulation only. This catheter is intended to obtain electrograms in the atrial and ventricular regions of the heart.

    Advisor™ HD Grid X Mapping Catheter, Sensor Enabled™
    The Advisor™ HD Grid X Mapping Catheter, Sensor Enabled™, is indicated for multiple electrode electrophysiological mapping of cardiac structures in the heart, i.e., recording or stimulation only. This catheter is intended to obtain electrograms in the atrial and ventricular regions of the heart.

    Agilis™ NxT Steerable Introducer
    The Agilis™ NxT Steerable Introducer is indicated for the introduction of various cardiovascular catheters into the heart, including the left side of the heart, during the treatment of cardiac arrhythmias.

    Agilis™ NxT Steerable Introducer Dual-Reach™
    The Agilis™ NxT Steerable Introducer Dual-Reach™ is indicated for the introduction of various cardiovascular catheters into the heart, including the left side of the heart, during the treatment of cardiac arrhythmias.

    Device Description

    The Agilis™ NxT Steerable Introducer Dual-Reach™ is a sterile, single-use device that con-sists of a dilator and steerable introducer, which is designed to provide flexible catheter positioning in the cardiac anatomy. The inner diameter of the steerable introducer is 13F. The steerable introducer includes a hemostasis valve to minimize blood loss during catheter intro-duction and/or exchange. It has a sideport with three-way stopcock for air or blood aspiration, fluid infusion, blood sampling, and pressure monitoring. The handle is equipped with a rotating collar to deflect the tip clockwise ≥180° and counterclockwise ≥90°. The steerable introducer features distal vent holes to facilitate aspiration and minimize cavitation and a radiopaque tip marker to improve fluoroscopic visualization.

    AI/ML Overview

    This FDA 510(k) clearance letter (K251211) and its accompanying 510(k) summary pertain to a change in workflow for several existing cardiovascular catheters, specifically allowing for a "Zero/Low Fluoroscopy Workflow."

    The key phrase here is "Special 510(k) – Zero/Low Fluoroscopy Workflow". This type of submission is for modifications to a previously cleared device that do not significantly alter its fundamental technology or intended use, but rather introduce a change in how it's used or processed.

    Crucially, this submission does NOT describe a new AI/software device that requires extensive performance testing against acceptance criteria in the manner you've outlined for AI/ML devices. Instead, it's about demonstrating that existing devices, when used with a new, less-fluoroscopy-dependent workflow, remain as safe and effective as before.

    Therefore, many of the questions you've asked regarding acceptance criteria, study details, ground truth, and expert adjudication are not applicable to the information provided in this 510(k) document. The document explicitly states:

    • "Bench-testing was not necessary to validate the Clinical Workflow modifications."
    • "Substantial Equivalence of the subject devices to the predicate devices using the zero/low fluoroscopy workflow has been supported through a summary of clinical data across multiple studies in which investigators used alternative visualization methods."

    This indicates that the "study" proving the device (or rather, the new workflow) meets acceptance criteria is a summary of existing clinical data where alternative visualization methods were already employed, rather than a prospective, controlled study of a new AI algorithm.

    Based on the provided document, here's what can be answered:

    1. A table of acceptance criteria and the reported device performance:

    • Acceptance Criteria: The implicit acceptance criterion is that the devices, when used with "zero/low fluoroscopy workflow," maintain substantial equivalence to their predicate devices in terms of safety and effectiveness. This means they must continue to perform as intended for visualizing cardiac structures, blood flow, mapping, or introducing catheters.
    • Reported Device Performance: The document states that "Substantial Equivalence... has been supported through a summary of clinical data across multiple studies in which investigators used alternative visualization methods." This implies that the performance (e.g., adequate visualization, successful mapping, successful catheter introduction) was maintained. Specific quantitative metrics of performance (e.g., accuracy, sensitivity, specificity, or inter-reader agreement for a diagnostic AI) are not provided or applicable here as this is not an AI/ML diagnostic clearance.

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

    • Sample Size: Not specified. The document refers to "a summary of clinical data across multiple studies." This suggests an aggregation of results from existing (likely retrospective) patient data where alternative visualization techniques (allowing for "zero/low fluoroscopy") were already utilized clinically. It's not a new, single, prospectively designed test set for an AI algorithm.
    • Data Provenance: Not specified regarding country of origin or specific patient demographics. It is implied to be clinical data collected from studies where these types of procedures were performed using alternative visualization. The data would be retrospective as it's a "summary of clinical data" that already exists.

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

    • Not applicable in the context of this 510(k). Ground truth in an AI/ML context typically refers to adjudicated labels for images or signals. Here, the "ground truth" is inferred from standard clinical practice and outcomes in the historical data summarized. There's no mention of a specific expert panel for new ground truth establishment for a diagnostic AI.

    4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:

    • Not applicable. This is not a study requiring adjudication of diagnostic outputs by multiple readers.

    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. This is not an AI-assisted diagnostic device. The workflow change is about using alternative non-fluoroscopic imaging modalities (e.g., intracardiac echocardiography, electro-anatomical mapping systems), not about AI improving human reader performance.

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

    • No. This is not an AI algorithm. The predicate devices are physical catheters.

    7. The type of ground truth used:

    • The "ground truth" is inferred from clinical outcomes and established clinical practice using the devices with alternative visualization methods in real-world scenarios. It's not a specific, adjudicated dataset for an AI algorithm. The performance of the devices (such as successful navigation, visualization, and mapping) under the "zero/low fluoroscopy" workflow is assumed to be equivalent to their performance under full fluoroscopy, as demonstrated by prior clinical use where such methods were employed.

    8. The sample size for the training set:

    • Not applicable. There is no AI model being trained discussed in this document.

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

    • Not applicable. No training set for an AI model.

    In summary:

    This 510(k) is for a workflow modification for existing medical devices (catheters), not for an AI/ML diagnostic or assistive software. Therefore, the detailed data performance evaluation typically required for AI models against specific acceptance criteria (as requested in your template) is not presented or relevant in this clearance letter. The "proof" relies on the concept of substantial equivalence to previously cleared predicate devices, supported by a summary of existing clinical data that used alternative visualization methods, implying that the devices function safely and effectively even with reduced fluoroscopy.

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    K Number
    K241372
    Manufacturer
    Date Cleared
    2024-07-09

    (55 days)

    Product Code
    Regulation Number
    870.1220
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Advisor™ HD Grid X Mapping Catheter, Sensor Enabled™

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

    The Advisor™ HD Grid X Mapping Catheter, Sensor Enabled™, is indicated for multiple electrode electrophysiological mapping of cardiac structures in the heart, i.e., recording or stimulation only. This catheter is intended to obtain electrograms in the atrial and ventricular regions of the heart.

    Device Description

    The AdvisorTM HD Grid X Mapping Catheter, Sensor EnabledTM, is a sterile, single use, irrigated, high-density mapping catheter with a 7.5F shaft and an 8F distal shaft deflectable section. It is available in a D-F bi-directional curve model that is deflected using the actuator located on the catheter handle. The catheter working length is 110 cm. The device consists of a paddle-shaped distal tip with 16 electrodes, two paddle magnetic sensors, two distal shaft ring electrodes, two shaft magnetic sensors, polymer braided shaft, handle, fluid lumen extension with a luer, and an electrical connector. The catheter also has an insertion tool intended to compress and guide the distal paddle into, and withdraw from, the hemostasis valve of an introducer sheath. The catheter is intended to be used with the EnSiteTM X EP System and other accessories, including the connecting cable and commercially available irrigation pumps.

    AI/ML Overview

    This document is a 510(k) summary for the Advisor™ HD Grid X Mapping Catheter, Sensor Enabled™. It states that the device is substantially equivalent to a predicate device and includes a summary of non-clinical testing.

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

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly provide a table of acceptance criteria alongside specific quantitative device performance metrics. Instead, it states:

    Acceptance Criteria (General Statement)Reported Device Performance (General Statement)
    Bench design verification activities were performed and met their respective acceptance criteria.Testing included dimensional, visual, mechanical integrity, simulated use, electrical, packaging, and shelf-life testing to assess substantial equivalence. Additionally, biocompatibility testing was conducted per the voluntary consensus standards under ISO 10993 and met all the biocompatibility endpoints for a medical device category for an external communicating medical device with limited (≤24 hour) circulating blood contact.

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

    The document describes "bench design verification activities" and "biocompatibility testing." These are typically conducted in a lab environment using manufactured samples of the device.

    • Sample Size for Test Set: Not explicitly stated in terms of number of devices or data points, but implies standard engineering and biocompatibility test sample sizes.
    • Data Provenance: The tests are "bench design verification activities" and "biocompatibility testing." This typically refers to retrospective testing on manufactured devices, not prospective clinical studies with human or animal subjects. The origin is likely the manufacturer (Abbott Medical, Plymouth, MN, USA).

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

    This information is not provided in the document. Bench and biocompatibility testing typically rely on standardized protocols and measurements, rather than expert consensus on "ground truth" in the way clinical studies might.

    4. Adjudication Method for the Test Set

    This information is not provided. Adjudication methods like 2+1 or 3+1 are relevant for clinical trials involving human interpretation of data, which is not the type of testing described here.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    No. The document explicitly states "Non-Clinical Testing Summary" and focuses on bench and biocompatibility tests. It does not mention any clinical studies, MRMC studies, or human reader performance.

    6. Standalone (Algorithm Only) Performance Study

    No. The device is a physical catheter, not an AI algorithm. Therefore, a standalone algorithm performance study is not applicable.

    7. Type of Ground Truth Used (Expert Consensus, Pathology, Outcomes Data, etc.)

    The ground truth for the non-clinical testing would be the physical and chemical specifications and performance standards outlined in the design and verification protocols for the device components and overall system, as well as the established safety criteria in ISO 10993 for biocompatibility. This is not "expert consensus," "pathology," or "outcomes data" in the clinical sense.

    8. Sample Size for the Training Set

    This information is not applicable. The device is a physical medical instrument, not a machine learning model that requires 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 type of device.

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