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510(k) Data Aggregation

    K Number
    K133957
    Manufacturer
    Date Cleared
    2014-04-14

    (112 days)

    Product Code
    Regulation Number
    868.5965
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    DISPOSABLE ADJUSTABLE PEEP VALVE MR CONDITIONAL USE

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

    Single patient use adjustable positive end expiratory pressure (PEEP) valves for use in hospital, transport, emergency, and post hospital care to evaluate end lung pressure above atmospheric at the end of exhalation in constant and intermittent gas flow conditions. For use with neonates to adults.

    Device Description

    The proposed Galemed Disposable Adjustable PEEP valves are identical to their predicate PEEP Valves, K.082092, except we have replaced some components that were magnetic with nonmagnetic material in order to meet the requirements for MR conditional environments of use. Otherwise the PEEP valves are identical.

    Galemed disposable adjustable PEEP valves elevate the pressure in a patient's lungs above atmospheric pressure at the end of exhalation.

    The Galemed disposable adjustable PEEP valve for use in MR environments is identical to our predicate, K082092, disposable PEEP valve, except we have replaced the materials in 2 components, a push rod and the springs to materials which are less magnetic. Other than these 2 changes, the device is identical to the predicate. These changes / modifications have been evaluated and demonstrated that they do not alter nor change the performance or safety profile of the new device as compared to the predicates.

    AI/ML Overview

    This 510(k) summary describes a Disposable Adjustable PEEP Valve for use in MR environments. The submission claims substantial equivalence to two predicate devices: the Galemed PEEP valve (K.082092) and the Mercury Medical PEEP Valve (K081266) for its MR conditional characteristics.

    Here's a breakdown of the requested information:

    1. Table of Acceptance Criteria and Reported Device Performance

    Feature/TestAcceptance Criteria (Predicate / Recognized Standard)Reported Device Performance
    MR Conditional (ASTM F2052-02)Deflection not more than 45 degrees in a 3 Tesla MR suite.The proposed device did not deflect this far and thus met the requirements.
    LeakageAfter setting to 5 cm H₂O and pressurizing, the pressure drop shall not be in excess of 2 cmH₂O within 5 seconds after reaching 5 cmH₂O.Met the pass/fail criteria (before and after age testing).
    Pressure / Resistance AccuracyAt flow rates of 2, 3, 5, 10, and 15 lpm, when set to 5 cmH₂O, resistance should be 5 +2.5/-2 cmH₂O; when set to 20 cmH₂O, resistance should be 20 +2.5/-2 cmH₂O.Met its performance specifications criteria (after being subjected to a number of conditions).
    Drop TestNo specific criteria mentioned, but implied to be sufficient to prevent leakage and maintain pressure/resistance performance.Met the pass/fail criteria for leakage and pressure/resistance.
    Environmental Conditions (High/Low Temperature)No specific criteria mentioned, but implied to be sufficient to maintain performance specifications.Met its performance specifications criteria.
    TransportationNo specific criteria mentioned, but implied to be sufficient to maintain performance specifications.Met its performance specifications criteria.
    Age TestingNo specific criteria mentioned, but implied to be sufficient to maintain performance specifications.Met its performance specifications criteria.
    MR Conditional (Predicate Mercury)May be used in a Magnetic Resonance (MR) environment, not to exceed a 1.5 Tesla or less. Spatial gradient of 450 gauss/cm or less.May be used in a Magnetic Resonance (MR) environment, not to exceed a 3.0 Tesla. Spatial gradient of 720 gauss/cm or less. (Claimed improvement over predicate)

    Notes on Acceptance Criteria:

    • For Leakage, Pressure/Resistance Accuracy, Drop Test, Environmental Conditions, Transportation, and Age Testing, the document states "met the pass/fail criteria" or "met its performance specifications criteria" without explicitly detailing the numerical boundaries of these criteria in the provided text. The criteria are only fully detailed for the MR Conditional test.
    • The MR Conditional acceptance criteria for the proposed device (3.0 Tesla, 720 gauss/cm) represent an improvement in capability over the Mercury Medical predicate (1.5 Tesla, 450 gauss/cm).

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

    The document does not explicitly state the numerical sample size for the test sets used in the non-clinical testing (e.g., how many PEEP valves were tested for leakage, MR compatibility, etc.). It refers to "the device" or "the sample," implying at least one, but without specific counts.

    • Sample Size: Not explicitly stated (implied to be one or more for each test).
    • Data Provenance: The tests were performed by the manufacturer, Galemed Corp., in China, as indicated by the company address. These appear to be prospective tests performed specifically for this 510(k) submission.

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

    This device is a medical device, not an AI or diagnostic imaging device. Therefore, the concept of "ground truth established by experts" as typically applied to AI models for classification or detection tasks does not directly apply here. The "ground truth" for this device's performance is objective measurements against engineering specifications and recognized standards (e.g., ASTM F2052-02).

    4. Adjudication Method for the Test Set

    Not applicable. As described in point 3, this is not a diagnostic device requiring expert adjudication of results. Performance is measured against predefined objective physical and engineering criteria.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done, and the Effect Size of Human Reader Improvement with AI vs. Without AI Assistance

    Not applicable. This is a physical medical device (PEEP valve), not an AI or imaging system, so an MRMC study is irrelevant.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done

    Not applicable. This is a physical medical device.

    7. The Type of Ground Truth Used

    The "ground truth" for the device's performance is objective engineering measurements against:

    • Recognized Standards: Specifically, ASTM F2052-02 for MR conditional properties.
    • Performance Specifications: Internal specifications for leakage, pressure/resistance accuracy, and durability (drop test, environmental, transportation, age testing). These specifications are based on the predicate device's performance and industry requirements for PEEP valves.

    8. The Sample Size for the Training Set

    Not applicable. This is a physical medical device, not an AI model requiring a training set. The device itself is manufactured, and its performance is verified through testing, not trained.

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

    Not applicable, as there is no training set for a physical medical device.

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