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510(k) Data Aggregation

    K Number
    K161504
    Manufacturer
    Date Cleared
    2017-01-06

    (219 days)

    Product Code
    Regulation Number
    876.5540
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Cook Turbo-Flo® HD Acute Hemodialysis Catheter Set/Tray is intended for acute hemodialysis, apheresis and hemofiltration via percutaneous insertion into the subclavian, jugular, or femoral veins. The device is a short-term use catheter (less than 30 days).

    Device Description

    The Cook Turbo-Flo® HD Acute Hemodialysis Catheter Set/Tray is a short-term, 12 Fr, radiopaque polyurethane central venous catheter with two independent, noncommunicating lumens. Lengths of 15, 20, and 25 cm are available based on the anatomical needs of the patient.

    AI/ML Overview

    This FDA 510(k) summary describes a medical device, a hemodialysis catheter, and its substantial equivalence to a predicate device. It does not contain information about an AI/ML-based device or a study proving its performance against specific acceptance criteria in the manner requested.

    However, I can extract the information provided about the Cook Turbo-Flo® HD Acute Hemodialysis Catheter Set/Tray and frame it as if it were describing a device's performance against acceptance criteria, using the available data. It's important to note that this is an analogy and not a direct fit for explaining an AI/ML device's validation.

    Here's an interpretation based on the provided text, modified to fit the requested format for a device validation, specifically focusing on the "Validation testing" mentioned.


    The document describes the Cook Turbo-Flo® HD Acute Hemodialysis Catheter Set/Tray and its validation testing, which ensures reliable design and performance. The primary change from the predicate device (K122091) is the removal of a hydrophilic coating, and the validation tests were conducted to demonstrate that this modification does not impact safety or effectiveness.

    1. Acceptance Criteria and Reported Device Performance

    The device underwent "Validation testing" to ensure reliable design and performance. The acceptance criteria and reported performance for specific parameters were as follows:

    Performance ParameterAcceptance CriterionReported Device Performance
    PreparationRating scale should be "adequate" or "good" in a three-point scale.Pre-determined acceptance criterion was met.
    IntroductionRating scale should be "adequate" or "good" in a three-point scale.Pre-determined acceptance criterion was met.
    PushabilityRating scale should be "adequate" or "good" in a three-point scale.Pre-determined acceptance criterion was met.
    TrackabilityRating scale should be "adequate" or "good" in a three-point scale.Pre-determined acceptance criterion was met.
    FlexibilityRating scale should be "adequate" or "good" in a three-point scale.Pre-determined acceptance criterion was met.
    RadiopacityRating scale should be "adequate" or "good" in a three-point scale.Pre-determined acceptance criterion was met.
    Blood DrawRating scale should be "adequate" or "good" in a three-point scale.Pre-determined acceptance criterion was met.
    InfusionRating scale should be "adequate" or "good" in a three-point scale.Pre-determined acceptance criterion was met.
    InteractionRating scale should be "adequate" or "good" in a three-point scale.Pre-determined acceptance criterion was met.
    WithdrawalRating scale should be "adequate" or "good" in a three-point scale.Pre-determined acceptance criterion was met.
    InspectionRating scale should be "adequate" or "good" in a three-point scale.Pre-determined acceptance criterion was met.
    BiocompatibilityNo impact on biocompatibility from the modification.Testing results indicate the modification does not impact biocompatibility.

    Study Details:

    1. Sample size used for the test set and the data provenance:

      • Sample Size: The document states "When tested in an animal model that simulates clinical use." It does not specify the exact number of animals used for the validation testing.
      • Data Provenance: The study was conducted retrospectively or prospectively cannot be determined from the document. The country of origin for the animal model data is not specified.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

      • This document describes a physical medical device and its performance in an animal model, not an AI/ML device requiring expert ground truth for image interpretation or diagnosis. Therefore, the concept of "experts" to establish ground truth in this context is not directly applicable as it would be for an AI/ML study. The evaluation likely involved veterinary or technical personnel assessing the catheter's performance based on predefined objective criteria in the animal model.
    3. Adjudication method (e.g., 2+1, 3+1, none) for the test set:

      • Adjudication methods like 2+1 or 3+1 are typical for human-in-the-loop or expert consensus studies for AI/ML. For a physical device animal study, the method of assessing the "adequate" or "good" rating is not detailed but would likely involve direct observation and measurement, potentially with a single or small team of trained evaluators. No specific adjudication method is mentioned.
    4. 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. This study is for a physical medical device and does not involve AI assistance, human readers, or an MRMC study design.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

      • No. This study pertains to the physical performance of a medical catheter in an animal model, not an algorithm.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

      • The "ground truth" for this device's performance was established through direct observation and qualitative assessment ("rating scale... 'adequate' or 'good'") within an animal model simulating clinical use. This is a functional performance assessment rather than a diagnostic accuracy assessment.
    7. The sample size for the training set:

      • This concept is not applicable for a physical medical device's validation testing described here. No "training set" for an algorithm is mentioned or implied. Design control activities and pre-clinical testing would have informed the device's design, but not in the sense of an algorithm training set.
    8. How the ground truth for the training set was established:

      • Not applicable, as there is no training set for an algorithm in this context. The "ground truth" for the device's design would have been established through engineering specifications, previous predicate device performance, and clinical requirements for hemodialysis catheters.

    Summary of Limitations based on the Document:

    The provided text is a 510(k) summary for a physical medical device, not an AI/ML algorithm. Therefore, many of the requested details about AI/ML study design (e.g., algorithm performance, human reader studies, training sets, expert consensus for ground truth) are not present or directly applicable. The document confirms that "appropriate design control activities" and "appropriate validation test" were performed, and the device met its pre-determined acceptance criterion regarding functional performance in an animal model and biocompatibility.

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