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510(k) Data Aggregation

    K Number
    K143213
    Date Cleared
    2015-07-10

    (242 days)

    Product Code
    Regulation Number
    868.5165
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The INOmax DSIR® Plus MRI delivery system is indicated for delivery of INOMAX® (nitric oxide for inhalation) therapy gas into the inspiratory limb of the patient breathing circuit in a way that provides a constant on of nitric oxide (NO), as set by the user, to the patient throughout the inspired breath. The INOmax DSIR® Plus MRI is indicated for use only with MR Conditional ventilators validated to be compatible, as identified in the device labeling.

    The INOmax DSIR® Plus MRI is indicated for continuous integrated monitoring of inspired 02, NO2, and NO.

    The INOmax DSIR® Plus MRI is considered MR Conditional with the use of 1.5 Tesla static magnetic field scanners ONLY in areas where the field strength is less than 100 gauss.

    The target patient population is controlled by the drug labeling for INOMAX® and is currently neonates. The primary targeted clinical setting is a clinical 1.5 Tesla and 3.0 Tesla diagnostic imaging environment.

    Device Description

    The INOmax DSIR® uses a "dual-channel" design to provide delivery of INOMAX®. The first channel has the delivery CPU, the flow controller and the injector module to ensure the accurate delivery of NO. The specially designed injector module enables tracking of the ventilator waveforms and the delivery of a synchronized and proportional dose of NO. The second channel is the monitoring system, which includes a separate monitor CPU, the gas cells (NO, NO2, and O2 cells) and the user interface including the display and a comprehensive alarm system. The dual-channel approach to delivery and monitoring permits INOMAX® delivery independent of monitoring but also allows the monitoring system to shut down INOMAX® delivery if the monitored NO concentration exceeds 100 ppm for 12 consecutive seconds. The delivery system can also shut down delivery if it detects certain serious problems with the monitoring system.

    The INOmax DSIR Plus MRI incorporates a battery that provides up to 6 hours of uninterrupted NO delivery in the absence of an external power source.

    The INOmax DSIR Plus MRI includes a backup NO delivery capability that provides a fixed flow of 250 mL/min of NO, which along with user supplied 10 L/min of oxygen, provides 20 ppm of NO to a patient breathing circuit. The INOblender® can also be used for backup.

    AI/ML Overview

    The provided document is a 510(k) summary for the INOmax DSIR® Plus MRI, a nitric oxide administration apparatus. It outlines the device description, intended use, technological characteristics, and a comparison to a predicate device, as well as a summary of nonclinical tests performed.

    However, the document does not contain the specific information requested about acceptance criteria and a study proving the device meets those criteria in the context of typical AI/ML medical device submission requirements.

    Here's why and what information can be extracted or deduced:

    This document describes a hardware medical device, not an AI/ML powered software or diagnostic device. Therefore, the concepts of "acceptance criteria" and "device performance" as typically discussed for AI/ML models (e.g., sensitivity, specificity, AUC) are not directly applicable in the same way. The "performance" here refers to the device's functional operation meeting engineering specifications.

    Let's address each point based on the available information:


    1. A table of acceptance criteria and the reported device performance

    • Acceptance Criteria (Deduced from testing goals): The document implies acceptance criteria are related to the device's functional performance:

      • O2 dilution: The device should not unacceptably dilute oxygen concentration.
      • Effect on delivered pressures: The device should not adversely affect ventilator delivered pressures.
      • INOmax DSIR® delivery accuracy: The device should accurately deliver Nitric Oxide.
      • NO2 generation: The device should not generate unacceptable levels of Nitrogen Dioxide.
      • MRI Compatibility: Device classified as MR Conditional for 1.5 Tesla and 3.0 Tesla static magnetic field scanners in areas where field strength is less than 100 gauss (via ASTM standards and other tests).
      • Electrical Safety & EMC: Conformity to IEC 60601-1 and IEC 60601-1-2.
      • Alarm Systems: Conformity to IEC 60601-1-8.
      • Software Functionality: Software version 3.1.2 meets specified requirements.
      • Usability: Meets human factors engineering requirements (ANSI/AAMI HE75).
      • Backup delivery: Provides fixed flow of 250 mL/min of NO.
    • Reported Device Performance:

      • "The INOmax DSIR® performed within published specifications when used with each of the ventilators in both primary and backup delivery."
      • "The INOmax DSIR® Plus MRI meets its system level requirements and that the new/modified features function as specified."
      • Compliance with specific FDA recognized consensus standards (IEC 60601-1, IEC 60601-1-2, IEC 60601-1-8, ASTM F2052-06, ASTM F2119-07, ASTM F2503-13).

    Table of (Deduced) Acceptance Criteria and Performance:

    Acceptance Criteria (Inferred)Reported Device Performance
    Functional Safety & Compatibility:
    O2 dilution acceptablePerformed within published specifications when used with ventilators.
    No adverse effect on delivered pressuresPerformed within published specifications when used with ventilators.
    INOmax DSIR® delivery accuracyPerformed within published specifications when used with ventilators; measured values on the INOmax DSIR® were recorded and anomalies noted.
    Acceptable NO2 generationPerformed within published specifications when used with ventilators.
    MR Conditional for 1.5T/3.0T static fields (<100 gauss)Classification as MR Conditional with the use of 1.5 Tesla and 3.0 Tesla static magnetic field scanners ONLY in areas where the field strength is less than 100 gauss. Compliance with ASTM F2052-06, ASTM F2119-07, ASTM F2503-13. Cart-mounted Gauss Alarms (100 Gauss) included.
    Electrical Safety & Quality:
    Electrical safety (Basic Safety and Essential Performance)Conformity to IEC 60601-1:2005.
    Electromagnetic Compatibility (EMC)Conformity to IEC 60601-1-2:2007.
    Alarm System performanceConformity to IEC 60601-1-8:2006.
    Software meets requirements and functions as specifiedVerification confirmed the INOmax DSIR® Plus MRI meets its system level requirements and that new/modified features function as specified.
    Usability (Human Factors Engineering)Formative usability study conducted per ANSI/AAMI HE75. Meets system level requirements.
    Backup NO delivery capability (250 mL/min NO, 20 ppm with O2)Device includes a backup NO delivery capability providing a fixed flow of 250 mL/min of NO; performed within specifications in backup delivery.
    6 hours uninterrupted NO delivery on batteryIntegrates a battery that provides up to 6 hours of uninterrupted NO delivery. (Performance implies this function was confirmed).

    Regarding AI/ML specific questions (2-9), the following applies since this is not an AI/ML device:

    2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    • Not applicable as this is a hardware device. Testing involved physical device performance and compatibility with other medical equipment, not analysis of a data set. The document mentions "Five INOmax DSIR® settings were used [0 (baseline), 5. 10. 20. 40. and 80 ppm] for each mode of ventilation, as well as the Backup mode." This describes test parameters, not a patient sample size or data provenance.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

    • Not applicable. Ground truth for a hardware device's functional performance is established through engineering and medical device standards (e.g., accuracy of gas delivery, safety limits). Not expert interpretation of data.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    • Not applicable. This concept pertains to resolving discrepancies in expert labeling or diagnoses for AI/ML ground truth.

    5. 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

    • Not applicable. This is not an AI/ML device intended to interpret data for human readers.

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

    • Not applicable. This is a standalone medical device, but not in the context of an algorithm's performance.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    • For a hardware device, "ground truth" relates to its adherence to established engineering specifications, safety standards, and functional requirements. For example, the ground truth for "NO delivery accuracy" would be calibration standards and expected physical/chemical properties.

    8. The sample size for the training set

    • Not applicable. This device does not have a "training set" in the context of AI/ML.

    9. How the ground truth for the training set was established

    • Not applicable. This device does not have a "training set" for AI/ML.
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