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510(k) Data Aggregation

    K Number
    K243898
    Date Cleared
    2025-04-11

    (113 days)

    Product Code
    Regulation Number
    876.5665
    Reference & Predicate Devices
    N/A
    Why did this record match?
    Device Name :

    Chlorine Sentinel II

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

    The Chlorine Sentinel II is intended for use by hemodialysis professionals as a secondary chlorine device to provide continuous monitoring of Combined Chlorine. It is not intended to replace the primary method of monitoring chlorine as part of the hemodialysis water treatment system. It functions completely independent of the water treatment system does not come into direct contact with feed water used to prepare dialysate.

    Device Description

    Chlorine Sentinel II is a complete system that attaches to the drain of a hemodialysis water treatment system sample port. It detects dissolved combined chlorine in concentrations at or above 10 PPB by primary detection technology. It self-monitors for maintenance-required conditions and loss of electrical power.

    The Chlorine Sentinel II is self-testing. It uses chlorinated city water to automatically test the chlorine detecting functionality of the device once a day and records if the test passed, failed to detect chlorine, or didn't rinse out after detecting chlorine.

    The device is designed to use as little water as possible. The sampling water is only used for the length of time that it takes for the chlorine test to be completed. The customer determines how frequently the test needs to be taken from every 5 minutes to every 20 minutes. The user also sets the start time and end time for each day of the week.

    The Chlorine Sentinel II has two combined chlorine concentration set points. The user can set a warning set-point at a value of 0.01 PPM to 0.09 PPM. Once the chlorine concentration exceeds this value, the device will alarm at 2-HZ to warn the user of chlorine present at that set-point. The second set-point is factory set at 0.10 PPM.

    A chlorine concentration equal to or above the 0.10 PPM set-point will activate the buzzers and the red chlorine alarm indicators at 5 HZ for as long as the condition exists. The buzzers can only be muted for 3 minutes (then automatically reset) for as long as the condition exists. The alarms can be by-passed. When by-passed the pulsing lights will turn solid and the buzzer will double click over 15 minutes.

    The front cover of the device has two screens. The screen of the chlorine monitor indicates the presence of combined chlorine when the value is not 0.000. The touch screen is used to enter user data and show the statuses of the device.

    AI/ML Overview

    This FDA 510(k) clearance letter for the Chlorine Sentinel II provides limited specific details on acceptance criteria and study methodologies, particularly concerning clinical performance. The focus is on demonstrating substantial equivalence to a predicate device through technological comparison and bench testing.

    Here's an analysis based on the provided document:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly state numerical acceptance criteria for clinical performance that can be directly compared to reported device performance metrics like sensitivity, specificity, or accuracy. Instead, the substantial equivalence is drawn based on similar intended use, technological characteristics, and performance verified through bench testing.

    Based on the "Detailed Comparison of the Subject and Predicate Devices" (Page 8-10) and "Testing" (Page 14), here's a synthesis of what can be inferred about performance:

    Feature/MetricAcceptance Criteria (Implied)Reported Device Performance
    Intended UseSame as Predicate: Secondary chlorine monitor for combined chlorine in hemodialysis feed water.Stated as identical to Predicate for "Chlorine Sentinel II."
    Chlorine Detection RangeSimilar to Predicate: 0.05 mg/L to 0.15 mg/L Cl₂> 0.01 mg/L (subject device's detection range, which is broader than the predicate's stated 0.05-0.15 mg/L, but still within a functional range)
    Chlorine Level Alarm0.1 mg/L Cl₂Sets alarm at 0.1 mg/L Cl₂ (factory set).
    Warning Chlorine Set-pointAbility to set a custom warning (0.01 PPM – 0.09 PPM).User can set a warning set-point (0.01 PPM – 0.09 PPM).
    LinearityConformance to CLSI standard EP06-A."Linearity Study to CLSI standard EP06-A" performed, implying conformance.
    Limit of Blank, Quantitation, DetectionConformance to CLSI standard EP17-A2."Limit of Blank, Limit of Quantitation, Limit of Detection Study to CLSI standard EP17-A2" performed, implying conformance.
    Electrical Safety / EMCConformance to IEC 61010-1 and IEC 60601-1-2:2020.Testing performed in accordance with these standards, implying conformance.
    Shelf-LifeReagent shelf-life maintained."Shelf-life testing has been performed for the ammonium sulfate reagent used in the predicate device," implying maintenance if applicable for the current device.
    Software ValidationSoftware validated as safe and effective."Software validation has been performed for the software component of the Chlorine Sentinel II," implying validation.
    Self-TestingAutomatic daily testing with pass/fail notification.Automatic daily testing with notifications.

    Note: The document primarily focuses on technological equivalence and adherence to safety/testing standards rather than presenting quantitative performance metrics against specific clinical acceptance criteria for sensitivity, specificity, or accuracy in a diagnostic context. This device is a water purification system component, not a diagnostic tool.

    2. Sample Size for Test Set and Data Provenance

    The document describes "Performance – Bench" testing but does not specify a "test set" in the context of clinical data, nor does it provide a sample size in terms of number of cases or data provenance (country, retrospective/prospective). The studies are bench-level evaluations of the device's technical specifications and linearity.

    3. Number of Experts and Qualifications for Ground Truth

    The document does not mention the use of experts to establish ground truth for a test set. The validation appears to be against established analytical standards (CLSI EP06-A, EP17-A2) for linearity and detection limits, and engineering standards for safety and electromagnetic compatibility.

    4. Adjudication Method

    As there is no mention of human expert review or a "test set" in a clinical sense, there is no adjudication method described.

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

    No MRMC study was done, as this device is a water purification system component and not a diagnostic device involving human interpretation of medical images or data. Therefore, there is no effect size reported for human readers improving with AI assistance.

    6. Standalone (i.e., algorithm only without human-in-the-loop performance) Study

    The device operates standalone in its function of monitoring chlorine. The "Performance – Bench" testing described would fall under a standalone performance evaluation, but not in the sense of a medical AI algorithm. It's a measurement device whose performance is assessed against technical specifications and analytical standards.

    7. Type of Ground Truth Used

    The ground truth used for performance validation appears to be:

    • Analytical Standards: CLSI standard EP06-A for linearity and CLSI standard EP17-A2 for limit of blank, limit of quantitation, and limit of detection.
    • Functional Specifications: The device's ability to detect chlorine at specified concentrations (e.g., 0.10 PPM alarm, 0.01 PPM warning) and perform self-tests.
    • Engineering Standards: IEC 61010-1 for electrical safety and IEC 60601-1-2:2020 for electromagnetic compatibility.

    This is not "expert consensus, pathology, or outcomes data" as typically seen in diagnostic device clearances.

    8. Sample Size for the Training Set

    The document does not mention a "training set" as it would be understood for machine learning or AI algorithms. The device's operation is based on a polarographic sensor and PLC control, not a learned model from a dataset.

    9. How Ground Truth for the Training Set Was Established

    Not applicable, as there is no training set in the context of machine learning or AI for this device.

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