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510(k) Data Aggregation
(143 days)
CADD**®**- Solis Ambulatory Infusion Pump with Wireless Communication; CADD®-Solis Infusion Pump, Model 2110
CADD®- Solis Ambulatory Infusion Pump with Wireless Communication
CADD®-Solis Infusion Pump, Model 2110
The CADD®-Solis Pump is indicated for intravenous, intra-arterial, subcutaneous, intraperitoneal, in close proximity to nerves, into an intraoperative site (soft tissue, body cavity/surgical wound site), epidural space. The pump is intended for therapies that require a continuous rate of infermittent bolus, and/or with patientcontrolled demand doses.
PharmGuard® Administrator Medication Safety Software
The PharmGuard® Administrator Medication Safety Software allows the use of a computer to create therapy-based protocol libraries to be used with the CADD®-Solis Infusion Pump.
CADD® Administration Set
The CADD® Administration Set is designed for use with the CADD® Infusion pumps (except CADD®-Micro) to allow medication delivery from a flexible container.
Wireless Communication Module (CM)
The Wireless Communication Module is intended to be used as an accessory to provide wireless capability and battery power to a CADD®-Solis Infusion Pump, Model 2110
The CADD®- Solis Ambulatory Infusion Pump with Wireless Communication, which includes the CADD®-Solis Infusion Pump, Model 2110, the Wireless Communication Module (CM), and the PharmGuard® Administrator Medication Safety Software, work together to provide wireless communication between the pump and the server and are similar to currently marketed products.
The CADD®-Solis Infusion Pump, Model 2110 has a microprocessor and linear peristaltic pumping mechanism, similar in design to the Smiths Medical ASD, Inc. CADD®-Solis Ambulatory Infusion Pump, Version 3.0 (K130394). The user activates CADD®-Solis Infusion Pump, Model 2110 via a color LCD screen and keypad user interface. Commands are issued to the microprocessor by activating the user interface. Microprocessor actions are controlled by a program, which is contained in the pump's memory.
The CADD® Administration Set is designed for use with the CADD® Infusion pumps (except CADD®-Micro) to allow medication delivery from a flexible container. The Flow Stop feature is a set-based free flow protection component (i.e. Flow Stop) that is designed to occlude the tube if the set is accidentally placed onto the pump incorrectly or becomes detached from the pump. The Flow Stop is located on the set housing, which is attached to the pump.
The provided text is a 510(k) summary for the CADD®-Solis Ambulatory Infusion Pump with Wireless Communication. It focuses on demonstrating substantial equivalence to predicate devices rather than proving a new device meets specific, novel acceptance criteria through a dedicated study with statistical endpoints. Therefore, many of the requested categories for a rigorous clinical or performance study involving AI or human readers are not applicable or cannot be extracted from this type of regulatory document.
However, I can extract information related to the performance testing and how the device's modifications are verified.
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 present a formal table of specific acceptance criteria with corresponding performance metrics in a quantitative manner as one might expect from a statistically powered study. Instead, it states that "All the testing met the acceptance criteria." and "Device testing met pre-defined acceptance criteria and did not raise new or different question of safety or effectiveness." The criteria are largely described by adherence to relevant standards and a safety assurance case.
Aspect of Performance | Acceptance Criteria (Implied / Stated) | Reported Device Performance |
---|---|---|
Overall System Safety & Effectiveness | The CADD-Solis Ambulatory Infusion Pump System is reasonably safe for use in its intended environment by its intended users; modifications do not raise new or different questions of safety and effectiveness. | Achieved through non-clinical testing. |
Pump Firmware Update (Version 4.1) | Verified with software testing in accordance with IEC 62304:2006 (Medical device software life cycle process) and FDA's "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices." | Met acceptance criteria. |
Wireless Data Transmission (via CM) | Design Verification and Validation testing demonstrates the wireless data transmission as meeting the acceptance criteria and intended use. | Met acceptance criteria. |
CM Accessory Power Performance | Performance of the CM accessory was verified and validated through bench testing, demonstrating a similar type of power source to the predicate's standalone rechargeable battery pack. | Met acceptance criteria. |
PC Software Compatibility (Windows 8 support) | Verified with software testing in accordance with IEC 62304:2006 and FDA's software guidance. | Met acceptance criteria. |
Multi-line Drug Names (Software Feature) | Verified with software testing in accordance with IEC 62304:2006 and FDA’s software guidance. Validated with Human Factors testing (enhancing ease of use). | Met acceptance criteria; validated for ease of use. |
Profiles Function (Software Feature) | Verified with software testing in accordance with IEC 62304:2006 and FDA’s software guidance. Validated with Human Factors testing. | Met acceptance criteria; validated. |
Daylight Savings Time Auto Adjust Feature (Software) | Verified with software testing in accordance with IEC 62304:2006 and FDA’s software guidance. | Met acceptance criteria. |
Asset ID Feature (Software) | Verified with software testing in accordance with IEC 62304:2006 and FDA’s software guidance. Validated with Human Factors testing. | Met acceptance criteria; validated. |
Administration Sets (Intrathecal Use) | Freedom from unacceptable neurotoxicological risk (established through GLP pre-clinical neurotoxicity studies), appropriate chemical characterization, and toxicology assessment. Biocompatibility studies in accordance with ISO 10993-1:2009. | Met acceptance criteria. |
Basic Safety & Essential Performance of Infusion Pump | In accordance with IEC 60601-1. | Met acceptance criteria. |
Human Factors / Usability Engineering | Effectiveness of use error related mitigations in accordance with FDA's "Applying Human Factors and Usability Engineering to Medical Devices" and IEC 62366-1:2007. | Conducted and validated. |
Electrical and Electromagnetic Compatibility (EMC) | Compliance with IEC 60601-1, IEC 60601-1-12, IEC 60601-1-2, IEC 60601-1-6:2013, 2054 UL Standard for Safety Household and Commercial Batteries, IEC 62122, and "Medical Electrical Equipment and System Electromagnetic Immunity Test for Exposure to Radio Frequency Identification Readers." | Complies with listed standards. |
Software Verification and Validation | Per FDA's "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices," "Content of Premarket Submissions for Management of Cybersecurity in Medical Devices," and IEC 62304:2006. | Met acceptance criteria for V&V. |
Cleaning and Disinfection Validation | Confirmed that the new accessories meet cleaning and disinfection requirements. | Met acceptance criteria. |
Packaging and Shipping Verification | In accordance with ASTM D4169 Standard Practice for Performance Testing of Shipping Containers and Systems. | Conducted in accordance with the standard. |
2. Sample Size Used for the Test Set and the Data Provenance
The document does not specify a "test set" in the context of a statistical study with a defined sample size (e.g., number of patients or cases). The testing performed is described as "non-clinical performance testing," "design verification and validation testing," and "software testing." Provenance is not applicable to this type of testing (e.g., no patient data is mentioned).
3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts
Not applicable. This is a 510(k) submission for an infusion pump and its accessories, not an AI/diagnostic device that relies on expert interpretation of data to establish ground truth for a test set.
4. Adjudication Method for the Test Set
Not applicable for the same reasons as #3.
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 device is not an AI diagnostic tool and does not employ "human readers" in the context of interpreting medical images or data.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This refers to the performance of the device itself (the infusion pump system and its software/accessories) in delivering medication and communicating data. The non-clinical performance testing, design verification, and validation studies serve this purpose. The document states that these tests demonstrate "the device is substantially equivalent to the legally marketed predicate device."
7. The Type of Ground Truth Used
The "ground truth" for this device's performance is established by:
- Engineering specifications and design inputs: The device is tested against its own design requirements.
- Industry standards: Compliance with standards like IEC 60601-1, IEC 62304, ISO 10993-1, etc.
- Predicate device characteristics: The new device's performance characteristics are compared to those of the legally marketed predicate devices (K130394 and K040636) to demonstrate substantial equivalence.
- GLP (Good Laboratory Practice) pre-clinical studies: For the new intrathecal indication of the administration sets, studies were conducted to show freedom from unacceptable neurotoxicological risk.
8. The Sample Size for the Training Set
Not applicable. This device does not involve machine learning or AI models that require a "training set."
9. How the Ground Truth for the Training Set Was Established
Not applicable for the same reason as #8.
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