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510(k) Data Aggregation
(240 days)
The CDI System 500 provides continuous, on-line monitoring of the extracorporeal partial pressure of oxygen and carbon dioxide, pH, potassium, oxygen saturation, hematocrit, hemoglobin and temperature. In addition, calculated values of base excess, bicarbonate, oxygen saturation, and oxygen consumption may also be provided. These parameters are displayed at either actual temperature or adjusted to 37°C. For documentation purposes, the system 500's integral printer provides a hard copy of displayed parameters.
The CDI™ System 500 is an AC-powered (battery back-up) microprocessor-based device used with the following components/accessories:
- CDI™ 500 Monitor .
- Arterial and/or Venous Blood Parameter Modules (BPM) .
- CDI™ H/S Probe .
- CDI™ 540 Gas Calibrator and Calibration Gases (A and B) .
- CDI™ 510H Shunt Sensor .
- Shunt Bypass Line .
- CDI™ H/S Cuvette with or without extension tubing .
- Monitor Mounting Hardware (Pole Clamp and Cable Head Bracket) .
- . Printer Paper
The CDI™ System 500 measures blood parameters in real time by utilizing a microprocessor based monitor, electro-optics modules (i.e., BPM and H/S probe), fluorescence chemistry technology, and optical reflectance technology. The electrooptics modules connect the monitor to the disposables (i.e., shunt sensor or cuvette) which are inserted into the extracorporeal circuit. Light is emitted from the modules, and the optical responses from the blood via the sensor(s) are measured by the monitor. The blood parameters are measured or calculated by the CDI™ 500 Monitor in real time, and displayed to the user via a graphical LCD display.
The provided text describes a 510(k) summary for the CDI™ Blood Parameter Monitoring System 500, a device for continuous, on-line monitoring of various blood parameters during cardiopulmonary bypass. The submission is for "Modifications to previously cleared system" and aims to demonstrate substantial equivalence to predicate devices K123039 and K972962.
Here's an analysis of the acceptance criteria and study information:
Acceptance Criteria and Reported Device Performance
The document states that the performance testing was conducted to "verify/validate the changes to the CDI™ System 500". The conclusion section further states that the modified device has "substantially equivalent performance specifications as compared to the predicate device." However, no specific quantitative acceptance criteria or detailed results of device performance metrics (e.g., accuracy, precision for each parameter like pH, pO2, pCO2, etc.) are provided in this summary. The document only broadly mentions "System verification testing in a blood loop to simulate clinical use."
Since specific acceptance criteria and detailed device performance are not explicitly stated in the provided text, the table below will reflect the information that is present:
| Parameter/Test | Acceptance Criteria | Reported Device Performance |
|---|---|---|
| Overall System Performance | Substantially equivalent to previously cleared predicate devices | Substantially equivalent to predicate devices K123039 and K972962 |
| Software Verification and Validation Testing | Successful completion of testing | Performed and verified |
| System Verification Testing | Successful simulation of clinical use in a blood loop | Performed and validated |
Study Information
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Sample size used for the test set and the data provenance:
- Sample Size: Not explicitly stated. The document mentions "System verification testing in a blood loop to simulate clinical use," but does not specify the number of blood samples, runs, or test conditions.
- Data Provenance: Not explicitly stated, though the testing was described as "in a blood loop," implying an in-vitro or ex-vivo setting rather than live human subjects. This suggests controlled laboratory conditions. The country of origin for the data is not mentioned. It is a retrospective summary of testing performed for the 510(k) submission.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable/Not mentioned. The testing described is "System verification testing in a blood loop to simulate clinical use." This typically involves comparing the device's measurements against a reference method or standard in the blood loop, not against expert interpretation of data generated by the device itself. Therefore, ground truth would likely be established by precise laboratory reference measurements rather than expert consensus on device output.
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Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- Not applicable/Not mentioned. Adjudication methods are typically used in studies involving human interpretation (e.g., image reading) to resolve discrepancies. This study focuses on the technical performance of a monitoring device against reference values in a lab setting, where disagreement on "ground truth" (e.g., from a calibrated reference sensor) is not resolved by adjudication.
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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. An MRMC comparative effectiveness study is not relevant to this device. This device is a blood parameter monitoring system, not an AI-assisted diagnostic imaging or interpretation tool that assists human readers.
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If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
- Since this is a monitoring device, its primary function is standalone performance (i.e., the accuracy of its measurements). The "System verification testing" would have assessed the standalone performance of the device in measuring blood parameters in a simulated environment. While not explicitly called "standalone performance," this is the nature of the testing described for such a device.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- Based on the description "System verification testing in a blood loop to simulate clinical use," the ground truth would most likely be established by reference laboratory methods or highly accurate and calibrated reference sensors/analyzers used to measure the blood parameters (pH, pO2, pCO2, K+, SO2, Hct, Hgb, Temperature) in the blood loop. This ensures an objective and reliable comparison against the device's readings.
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The sample size for the training set:
- Not applicable/Not mentioned. This is a monitoring device based on electro-optics modules, fluorescence chemistry, and optical reflectance technology, incorporating a microprocessor for calculations. It's not described as a machine learning or AI-driven algorithm that requires a "training set" in the conventional sense (i.e., for supervised learning). While its internal algorithms and calibrations are developed, this typically involves engineering and validation against physical and chemical principles and reference standards, not a "training set" of patient data.
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How the ground truth for the training set was established:
- Not applicable for the reason given in point 7. For algorithms within such a device, "ground truth" during development would be established through meticulous engineering, physical modeling, chemical principles, and calibration against known standards and reference measurements.
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(53 days)
The CDI System 500 provides continuous, on-line monitoring of the extracorporeal partial pressure of oxygen and carbon dioxide, pH, potassium, oxygen saturation, hematocrit, hemoglobin and temperature. In addition, calculated values of base excess, bicarbonate, oxygen saturation, and oxygen consumption may also be provided. These parameters are displayed at either actual temperature or adjusted to 37°C. For documentation purposes, the system 500's integral printer provides a hard copy of displayed parameters.
The CDI™ System 500 is an AC-powered (battery back-up) microprocessor-based device used with the following components/accessories:
- CDI™ 500 Monitor
- Arterial and/or Venous Blood Parameter Modules (BPM)
- CDI™ Hematocrit/Saturation (H/S) Probe
- CDI™ 540 Gas Calibrator and Calibration Gases (A and B)
- CDI™ 510H Shunt Sensor
- Shunt Bypass Line
- CDI™ H/S Cuvette with or without extension tubing
- Monitor Mounting Hardware (Pole Clamp and Cable Head Bracket)
- Printer Paper
The CDI™ System 500 measures blood parameters in real time by utilizing a microprocessor based monitor, electro-optics modules (i.e., BPM and H/S probe), fluorescence chemistry technology, and optical reflectance technology. The electrooptics modules connect the monitor to the disposables (i.e., shunt sensor or cuvette) which are inserted into the extracorporeal circuit. Light is emitted from the modules, and the optical responses from the blood via the sensor(s) are measured by the monitor. The blood parameters are measured or calculated by the CDI™ 500 Monitor in real time, and displayed to the user via a graphical LCD display.
Here's an analysis of the provided text regarding acceptance criteria and the supporting study:
The provided document describes a 510(k) submission for a modification to the Terumo CDI™ System 500, a blood parameter monitoring system. The core of this submission is to demonstrate substantial equivalence to a predicate device, specifically focusing on a design change to improve the robustness of the Blood Parameter Module (BPM) Probe Cable-Head against moisture ingress.
Therefore, the acceptance criteria and the study primarily revolve around verifying the effectiveness and safety of this specific design change, rather than proving performance metrics for all blood parameters. The document explicitly states: "This design change did not alter the device indication for use or performance specifications."
1. Table of Acceptance Criteria and Reported Device Performance:
| Acceptance Criteria | Reported Device Performance/Verification Outcome |
|---|---|
| The BPM Probe Cable-Head functions as expected even in the presence of high humidity (85% RH) | "The design change was verified to meet predefined acceptance criteria and assure that: The BPM Probe Cable-Head functions as expected even in the presence of high humidity (85% RH)" (Section 4: 510(k) Summary, "Verification Testing on Device Modification") |
| The design change does not introduce new safety risks | "The design change was verified to meet predefined acceptance criteria and assure that: The design change does not introduce new safety risks" |
| The design change is effective over the expected life of the BPM probe cable-head | "The design change was verified to meet predefined acceptance criteria and assure that: The design change is effective over the expected life of the BPM probe cable-head" |
2. Sample size used for the test set and the data provenance:
- Sample Size: The document does not explicitly state the sample size used for the verification testing. It only generally refers to "Design control activities identified the requirements for the design change, which drove the design change verification activities."
- Data Provenance: Not specified. There is no mention of country of origin, or whether the study was retrospective or prospective. Given the nature of a design change verification, it would likely be prospective testing conducted in a controlled environment.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- The document does not mention the use of experts to establish ground truth for this specific verification testing. The testing appears to be objective engineering verification rather than a clinical study requiring expert interpretation of results.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- There is no mention of an adjudication method. This type of method is typically used in clinical trials where there's subjectivity in interpreting results and multiple readers are involved. For engineering verification of moisture ingress and function, such a method would not be applicable.
5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, and what was the effect size of how much human readers improve with AI vs without AI assistance:
- No, an MRMC comparative effectiveness study was not done. This device is a blood parameter monitor; it does not involve AI or human interpretation of images or complex data in a way that would necessitate an MRMC study. The verification focuses on the hardware's robustness.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
- This question is not applicable as the device is a measurement system, not an algorithm-based diagnostic or AI-driven tool. The "standalone performance" here refers to the device's ability to measure parameters, which is the inherent function it performs without human interpretation in the loop. The verification covered the robustness of a particular component.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- The ground truth for this design modification verification would be objective engineering measurements and functional tests. For example:
- Functional performance: The device successfully provides accurate blood parameter readings after exposure to high humidity (ground truth derived from reference methods for blood gas analysis).
- Safety: Absence of electrical malfunction or other hazards after moisture exposure (ground truth defined by safety standards and direct observation).
- Expected life: The component continues to perform functionally for a defined duration under simulated conditions (ground truth against design durability specifications).
- The document implies that the "predefined acceptance criteria" themselves represent the ground truth for success in these tests.
8. The sample size for the training set:
- This question is not applicable as the device is not an AI/ML model that requires a training set. The "design change" refers to a hardware modification, not a software algorithm that learns from data.
9. How the ground truth for the training set was established:
- This question is not applicable for the same reasons as #8.
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