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510(k) Data Aggregation

    K Number
    K133516
    Manufacturer
    Date Cleared
    2014-04-30

    (166 days)

    Product Code
    Regulation Number
    868.1400
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    CO2 Monitoring lines are intended to connect from a patient interface CO2 sampling port to the expired gas monitor.

    Device Description

    Flexicare's CO2 monitoring line is single patient use, small diameter tubing intended to be connected to a luer lock connector on a patient interface to allow for gas sampling from a patients exhaled breath by gas sampling equipment. The Gas monitoring/analysing device will feature a pump, which draws expired breath from the patient through the monitoring line and into the gas analyser. Flexicare's CO2 monitoring line is available with or without a 0.45um hydrophobic filter, which prevents the transfer of water vapour down the monitoring line and into the gas sampling equipment. Flexicare's CO2 monitoring lines feature clear construction to aid visual inspection of the device. The CO2 monitoring line is a single patient use device, designed for use with one patient over a single course of treatment. The CO2 monitoring line is supplied in a sealed poly bag in a non sterile state and is not to be sterilized. The Flexicare CO2 monitoring lines feature 2M & 3M length tubes.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and study information for the Flexicare CO2 monitoring line, based on the provided document:

    1. Table of Acceptance Criteria and Reported Device Performance

    TestStandard / Pre-determined Acceptance CriteriaReported Flexicare Device Performance
    Visual inspectionPre-determined Acceptance CriteriaAll samples pass
    Resistance to flowPre-determined Acceptance CriteriaAll samples pass
    Dimensional inspection. Length, ID, ODPre-determined Acceptance CriteriaAll samples pass
    LeakagePre-determined Acceptance CriteriaAll samples pass
    Performance - CO2 monitoringPre-determined Acceptance CriteriaAll samples pass
    Tensile testingPre-determined Acceptance CriteriaAll samples pass
    Luer connectors - Dimensional, leakage, connection, stress crackingISO 594-1 / BS EN 20594-1:1994, ISO 594-2 (BS EN 1707:1997)All samples pass
    Accelerated age testingASTM F1980All samples pass
    Cytotoxicity, Irritation, sensitizationBS EN ISO 10993-10:2010, BS EN ISO 10993-5:2009All samples pass
    GenotoxicityBS EN ISO 10993-3:2009All samples pass

    Specific Resistance to Flow Performance Details:

    • CO2 monitoring line (without filter):
      • Flexicare: 8.8 mbar at 100ml/min flow, 30.2 mbar at 300ml/min flow
      • Predicate: 15.2 mbar at 100ml/min flow, 51.2 mbar at 300ml/min flow
    • CO2 monitoring line (with filter):
      • Flexicare: 30.0 mbar at 100ml/min flow, 95.7 mbar at 300ml/min flow
      • Predicate: 33.4 mbar at 100ml/min flow, 114.5 mbar at 300ml/min flow

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

    The document does not explicitly state the specific number of samples used for each test (the sample size). However, it consistently states "All samples pass" for each test.

    The data provenance is from Flexicare Medical Limited, United Kingdom, as indicated by the manufacturer's details and the report being dated in the UK. The tests described are part of a premarket notification (510(k)) submission, meaning they were conducted specifically for this regulatory purpose. The nature of these tests (performance, dimensional, biocompatibility etc.) implies they are prospective in the sense that they were designed and executed to evaluate the new device against established criteria and a predicate device.

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

    This information is not provided in the document. The tests performed are primarily engineering and laboratory-based assessments of physical and functional characteristics against defined standards and criteria, rather than expert-driven clinical evaluations requiring ground truth establishment by medical experts.

    4. Adjudication Method for the Test Set

    This information is not applicable/not provided. The tests are objective measurements against standards or functional comparisons, not subjective clinical assessments requiring adjudication. The results are reported as "All samples pass," indicating direct conformance to acceptance criteria.

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

    No, an MRMC comparative effectiveness study was not done. The device is a CO2 monitoring line, which is a passive tubing device. The comparison studies focused on physical and functional equivalence to a predicate device, not on human reader performance with or without AI assistance.

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

    No, a standalone algorithm performance study was not done. The device does not involve any software or electronic components, therefore no algorithm is present to be evaluated.

    7. The Type of Ground Truth Used

    The "ground truth" for the device's performance is established by:

    • Pre-determined Acceptance Criteria: These are internal specifications or performance targets set by Flexicare.
    • International Standards: e.g., ISO 594-1, ISO 594-2, ASTM F1980, BS EN ISO 10993-3, -5, -10.
    • Comparison to a Predicate Device: The performance of the Flexicare device (e.g., resistance to flow, CO2 detection capability, leakage, tensile strength) was directly compared to the Intersurgical predicate device (K122075) to demonstrate similar or better performance.

    For the CO2 monitoring performance, the ground truth was whether the device could consistently detect CO2 from beneath the nostrils, similar to the predicate device. The document states: "Both manufacturers' devices detected CO2 consistently, proving substantial equivalence."

    8. The Sample Size for the Training Set

    This information is not applicable/not provided. The device is a simple mechanical tubing product and does not involve machine learning or AI, thus there is no "training set."

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

    This information is not applicable/not provided, as there is no training set.

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