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510(k) Data Aggregation

    K Number
    K223171
    Date Cleared
    2022-11-10

    (30 days)

    Product Code
    Regulation Number
    876.1500
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    AquaPulse**®** Irrigation Tubing

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

    The 24 hour use AquaPulse® Irrigation Tubing (tubing and accessories to accommodate various GI endoscopes and irrigation pumps) is intended to provide irrigation via a sterile water bottle during gastrontestinal endoscopic procedures when used in conjunction with an irrigation pump.

    Device Description

    The AquaPulse® Irrigation Tubing is intended for 24-hour use and then discarded. The irrigation tubing is manufactured for use in conjunction with sterile water bottle, and together with irrigation pumps. The irrigation tubing is individually packed in sealed package, sold as a sterile device. The irrigation tubing is designed to the auxiliary water connector or biopsy irrigation accessory and to be inserted into pump head of the irrigation pump to provide irrigation through the auxiliary water channel to the distal end of endoscope.

    AI/ML Overview

    This document describes a 510(k) premarket notification for the AquaPulse® Irrigation Tubing. This is not a medical device that uses AI or machine learning.

    Therefore, most of the requested information regarding acceptance criteria and study proving device performance related to AI/ML (e.g., sample size for training/test sets, number of experts, adjudication methods, MRMC studies, standalone performance, ground truth for AI) is not applicable to this submission.

    Here's a breakdown of the applicable information based on the provided text, and an explanation of why other aspects are not present:


    Analysis of the Provided Document for Device Acceptance Criteria and Study

    The provided document is a 510(k) premarket notification for a medical device called "AquaPulse® Irrigation Tubing." This type of submission is for demonstrating "substantial equivalence" to a legally marketed predicate device, rather than proving novel efficacy or performance through extensive clinical trials as would be required for a completely new device or a device with new technology (like AI/ML).

    The core of this submission revolves around bench testing and biocompatibility testing to show that the modified device is as safe and effective as its predicate. It does not involve artificial intelligence or machine learning components.


    1. Table of Acceptance Criteria and Reported Device Performance

    Since this is not an AI/ML device, the "acceptance criteria" are related to manufacturing specifications, material properties, sterilization, and basic functional performance, rather than diagnostic accuracy or predictive power. The document summarizes these in comparison to a predicate device to establish substantial equivalence.

    SpecificationPredicate Device CharacteristicSubject Device CharacteristicSubstantial Equivalence (Acceptance)
    Product CodeOCXOCXIdentical (Met)
    Regulatory Classification22Identical (Met)
    Regulation No.21 CFR 876.150021 CFR 876.1500Identical (Met)
    Regulation DescriptionEndoscope and accessoriesEndoscope and accessoriesIdentical (Met)
    CompatibilityOlympus® OFP, Endo Status™ EGA-500 and Endogator® EGP-100 Irrigation PumpOlympus® OFP, Endo Status™ EGA-500 and Endogator® EGP-100 Irrigation PumpIdentical (Met)
    Intended UseThe 24 hour use AquaPulse® Irrigation Tubing... is intended to provide irrigation via a sterile water bottle during gastrointestinal endoscopic procedures when used in conjunction with an irrigation pump.The 24 hour use AquaPulse® Irrigation Tubing... is intended to provide irrigation via a sterile water bottle during gastrointestinal endoscopic procedures when used in conjunction with an irrigation pump.Identical (Met)
    Environment of UseHospital and/or clinicsHospital and/or clinicsIdentical (Met)
    Single Use, Disposable24-hour use then discard24-hour use then discardIdentical (Met)
    MaterialPolycarbonate and Polyvinyl ChloridePolycarbonate and Polyvinyl Chloride (Material not Made with DEHP)Substantial Equivalent (Met - notes specific material detail)
    PackagingIrrigation tubing is packaged in a sealed pouchIrrigation tubing is packaged in a sealed pouchIdentical (Met)
    Manufacturing MethodInjection molding and extrusionInjection molding and extrusionIdentical (Met)
    Backflow Prevention DesignDiaphragm in the connector allow pressurized water passing through in one-way but not the other wayDiaphragm in the connector allow pressurized water passing through in one-way but not the other wayIdentical (Met)
    SterilizationEO gasEO gasIdentical (Met)
    Shelf Life1 year3 yearsSubstantial Equivalent (Met - based on accelerated aging test)

    Reported Device Performance:

    • Flow Performance: "The bench testing was performed to support substantial equivalence such as verification tests on flow performances of modified devices. The performance data demonstrated that the subject devices met established specifications and it demonstrated substantial equivalence to the previously cleared predicate devices." (Section 9)
    • Sterilization: "The EO sterilization cycle has a Sterility Assurance Level (SAL) of 10⁻⁶. EO residuals on the components are below the maximum levels defined in ANSI/AAMI/ISO 10993-7 Biological Evaluation of Medical Devices - Part 7: Ethylene Oxide sterilization residuals." (Section 10)
    • Shelf Life: "The modified devices have a three (3) year shelf life, based on the design and existing sterile barrier data from the existing packaging integrity test and performance test were conducted after accelerated aging test. The test result can imply that the modified device can provide and maintain a sterile barrier and its intended performance for at least the claimed shelf life." (Section 11)
    • Biocompatibility: "The test result shows that the modified devices are biocompatible" in accordance with ISO 10993-1 for surface devices with mucosal membrane contact for limited duration (not more than 24 hours). (Section 12)

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

    • Sample Size for Test Set: Not specified in terms of number of units tested. For bench tests, it typically refers to a number of manufactured units subjected to specific physical and chemical tests (e.g., flow rate, material composition, sterilization validation samples, accelerated aging samples, biocompatibility samples). The document states "The test result shows that the modified devices are biocompatible" and "The performance data demonstrated that the subject devices met established specifications," implying samples were tested, but not the specific quantity.
    • Data Provenance: Not explicitly stated as "country of origin of the data." These are likely lab/bench test results generated by the manufacturer (GA Health Company Limited, Hong Kong, CHINA) or a contracted testing facility.
    • Retrospective or Prospective: Not applicable. These are laboratory/bench test results of physical properties and performance, not patient data.

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

    • Not applicable. This device does not generate diagnostic interpretations or clinical assessments that would require human expert ground truth establishment. The "ground truth" for this device's performance is established by meeting engineering specifications through bench testing and validated laboratory methods (e.g., flow rate measurements, sterility testing, chemical analysis for residuals, biocompatibility assays).

    4. Adjudication Method for the Test Set

    • Not applicable. As no expert interpretation or human assessment of results requiring consensus was involved, no adjudication method was used.

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

    • No. An MRMC study is designed to evaluate the impact of a diagnostic AI system on human reader performance. This device is an irrigation tubing, not a diagnostic imaging or AI system.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

    • Not applicable. This device is hardware and does not contain an algorithm.

    7. The Type of Ground Truth Used

    • Functional/Performance Specifications & Regulatory Standards: The "ground truth" here is adherence to engineering design specifications, validated sterilization parameters (SAL 10⁻⁶, EO residuals), biocompatibility standards (ISO 10993-1), and demonstrated performance equivalence (flow rate, shelf life) to the predicate device. This is based on objective measurements rather than clinical outcomes or expert review of images/data.

    8. The Sample Size for the Training Set

    • Not applicable. This is not an AI/ML device 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 model.

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