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510(k) Data Aggregation

    K Number
    K140387
    Date Cleared
    2014-12-23

    (312 days)

    Product Code
    Regulation Number
    868.1890
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The BRDSS-C is indicated for use in the care of adult patients and adolescent patients 17 years of age or older who weigh 40kg (88lbs) or more with 20% or more Total Body Surface Area (TBSA) burned, as a fluid resuscitation calculator for fluid recommendations. The BRDSS-C is intended to be initiated within 24 hours of the burn incident and completed by 72 hours post burn. The BRDSS-C is not indicated for use in patients who are less than 17 years of age.

    Device Description

    The Burn Resuscitation Decision Support System – Clinical (BRDSS-C) is a burn decision support software application for assisting healthcare professionals in managing fluid resuscitation of burn patients during the initial 24 - 72 hours post burn. The system provides hourly (or half-hour) fluid calculations and recommendations for patients with 20% or greater Total Body Surface Area (TBSA) burn injuries, in addition to providing users with a graphical user interface to display volume status, Intake and Output (I/O) volumes, and other relevant fluid balance information.

    AI/ML Overview

    The provided document is a 510(k) premarket notification for the Burn Resuscitation Decision Support System - Clinical (BRDSS-C), v. 1.0. This type of document primarily focuses on demonstrating substantial equivalence to a predicate device rather than providing detailed study results and acceptance criteria as would be found in a clinical trial report.

    Therefore, the information requested regarding acceptance criteria, specific performance metrics, sample sizes, expert qualifications, adjudication methods, multi-reader multi-case studies, standalone performance, and ground truth establishment is not fully available within the provided text.

    However, I can extract the available information and point out what is missing:


    1. Table of Acceptance Criteria and Reported Device Performance:

    The document does not explicitly state quantitative acceptance criteria or detailed performance metrics against those criteria. Instead, it demonstrates validation against software requirements and usability, and establishes substantial equivalence to a predicate device.

    Acceptance Criteria (based on software requirements & usability)Reported Device Performance
    Data intake validationPassed
    User warnings, alerts, and messagesPassed
    User interface requirementsPassed
    Functional requirementsPassed
    Error handling requirementsPassed
    Human factors usability requirementsCompliant with human factors usability requirements (demonstrated by a human factors study)
    Software verification and validationPassed (based on FDA's Quality System Regulation requirements under 21 CFR Part 820)
    Clinical user validationPassed (based on FDA's Quality System Regulation requirements under 21 CFR Part 820)
    Intended Use & Technical Features EquivalenceSubstantially equivalent to the predicate device (BRDSS - Burn Navigator) in terms of intended use and technical features; any differences do not raise new safety and effectiveness questions.

    Missing Information for this section: Specific quantitative thresholds for "passing" or "compliance" with software and usability requirements are not detailed. Performance metrics related to fluid calculation accuracy or clinical outcomes are also not provided.


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

    The document mentions "software verification and validation as well as clinical user validation" and a "human factors study." However, it does not specify the sample size for any test sets used in these validations or for the human factors study.

    It also does not specify the data provenance (e.g., country of origin, retrospective/prospective) for any data used in these validation efforts.


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

    The document does not describe the establishment of a "ground truth" for a specific test set in the context of clinical performance, as it is a fluid resuscitation calculator and relies on an established algorithm.

    For the "clinical user validation," it implies that burn care professionals were involved, but does not specify the number of experts or their qualifications used to evaluate the device. The device is "intended for use by healthcare professionals with burn care experience," suggesting that these individuals, or similar ones, would have been involved in the validation.


    4. Adjudication Method for the Test Set:

    Given that the document does not describe a clinical test set requiring ground truth, no adjudication method is mentioned or implied. The validation focuses on software functionality, usability, and equivalence to a predicate device running the same core algorithm.


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

    No MRMC comparative effectiveness study is mentioned. The device is a "decision support system" providing fluid recommendations, not an imaging analysis tool typically associated with MRMC studies. The focus is on the algorithm's calculation and the software's usability and safety, not on how human readers' performance improves with or without AI assistance in interpretation.


    6. Standalone Performance Study:

    The document describes the BRDSS-C as a "fluid resuscitation calculator for fluid recommendations" and a "burn decision support software application." Its validation is described as: "The BRDSS-C has passed software verification and validation as well as clinical user validation based on the FDA's Quality System Regulation requirements under 21 CFR Part 820."

    This indicates that its performance as a standalone algorithm (without human intervention in its core calculation logic) was indeed evaluated through software verification and validation testing. However, specific quantifiable metrics of this standalone performance (e.g., accuracy of fluid recommendations against a gold standard in a clinical dataset) are not provided in this summary. The evaluation focuses on whether the software correctly implements its algorithm and meets its functional and usability requirements.


    7. Type of Ground Truth Used:

    For the core function of the device (fluid calculations), the "ground truth" is inherently the mathematical output of the underlying burn decision support algorithm, which is the same as that used in the predicate device. The validation confirms that the software correctly implements this algorithm and provides accurate calculations based on the input.

    For software validation, the "ground truth" would be the defined software requirements and specifications. For human factors validation, it would be usability standards and successful task completion by representative users. Clinical outcomes data are not mentioned as a ground truth for the device's validation in this document.


    8. Sample Size for the Training Set:

    The BRDSS-C uses the same burn decision support algorithm as the predicate device (BRDSS - Burn Navigator). This existing algorithm would have been developed and "trained" (in a broader sense, meaning its parameters and logic established) prior to the development of the BRDSS-C.

    The document does not specify a sample size for a training set used to develop or re-train the algorithm for BRDSS-C, as it states the algorithm itself is the same.


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

    Since BRDSS-C utilizes an existing algorithm from its predicate, the document does not describe how a "ground truth" for a new "training set" was established for the BRDSS-C specifically.

    The original algorithm (used by both BRDSS and BRDSS-C) would have been developed based on medical knowledge, clinical guidelines for burn fluid resuscitation (e.g., Parkland formula variations), and potentially validated against historical patient data or expert consensus in its initial inception. However, this information is not detailed in the provided 510(k) summary for BRDSS-C.

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