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510(k) Data Aggregation

    K Number
    K192540
    Date Cleared
    2020-05-01

    (228 days)

    Product Code
    Regulation Number
    884.6110
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Kitazato ET Catheters are intended for ultrasound guided introduction of embryos into the uterine cavity following in vitro fertilization.

    Device Description

    Kitazato ET Catheters are sterile, single-use catheters for use in embryo transfer procedures. The catheter is used to hold and deliver embryos to the uterine cavity during a procedure. Catheters are available in 3Fr and 4Fr sizes, both of which are provided in lengths of 220 mm and 250 mm, as well as one version that is 3Fr and 400 mm length that has the same uterine insertion depth as the other device versions, but allows the user to be positioned further from the patient during a procedure. Devices also include versions with and without an echo reflective chip in the tip of the catheter. The echo reflective chip aids in visualization of the catheter during a transfer procedure; all transfer procedures are to be done under ultrasound guidance. Both the Type 2 devices also include a stainless steel or polyimide core to provide additional rigidity to the catheter. The guide is used to navigate the pathway through the cervical canal to allow for easier catheter insertion Guides are provided with a 30° pre-curved distal shaft and are available in lengths of 170 mm and 200 mm. Guides also include a styrene elastomer stopper to aid in positioning the targeted uterine insertion depth. The guides are also available with a straight or bulb tip design, and with and without an echo reflective chip in the tip of the guide. An obturator with a length of 170 mm or 200 mm is provided with the Type 2 versions of the device to prevent ingress of fluid into the guide lumen during guide insertion. The Stylet is an optional accessory used when additional rigidity is needed during insertion of the guide through the cervix, and is provided in two lengths, 170 mm and 200 mm. The stainless steel core of the Stylet can be shaped to aid in guide delivery through the cervix.

    AI/ML Overview

    This document describes a 510(k) premarket notification for the Kitazato ET Catheters. The focus of the provided text is on demonstrating the substantial equivalence of the Kitazato ET Catheters to a legally marketed predicate device (Guardia™ Access Embryo Transfer Catheter Sets). As such, the information provided is geared towards comparing the new device to an existing one, rather than establishing the performance of a novel AI/software medical device against defined acceptance criteria in the way a traditional clinical study would for an AI-powered diagnostic.

    Therefore, the requested information about "acceptance criteria and the study that proves the device meets the acceptance criteria" in the context of an AI medical device (e.g., sample size for test set, data provenance, number of experts, adjudication method, MRMC study, standalone performance, type of ground truth, training set sample size and ground truth establishment) is largely not applicable to this submission.

    This submission is for a physical medical device (catheters) and relies on bench testing and biocompatibility studies to show substantial equivalence, not a clinical study involving human readers and AI performance.

    However, I can extract information related to relevant non-clinical performance and "acceptance criteria" where applicable to this physical device, as described in the document.


    Acceptance Criteria and Device Performance for Kitazato ET Catheters (Physical Device)

    This submission focuses on demonstrating substantial equivalence of a physical medical device (embryo transfer catheters) to a predicate device, primarily through non-clinical performance data. Therefore, the "acceptance criteria" are related to established norms for medical device safety and performance rather than AI-specific metrics like AUC, sensitivity, or specificity in a diagnostic context.

    Here's the relevant information based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria CategorySpecific Test/CriterionReported Device Performance / Evaluation Method
    SterilizationValidated per ISO 11137-1:2006(R)2010 &A1:2013 and ISO 11137-2:2013Studies performed to support substantial equivalence.
    BiocompatibilityEvaluated per ISO 10993-1: 2018 and 2016 FDA GuidanceStudies performed to support substantial equivalence.
    - CytotoxicityMet ISO 10993-5:2009
    - SensitizationMet ISO 10993-10:2010
    - Intracutaneous reactivityMet ISO 10993-10:2010
    Endotoxin< 20 EU/device (per AAMI/ANSI ST72:2011; USP <85>)Met: < 20 EU/device
    Packaging & Transport- Transportation Simulation per ASTM D4169-16Assessment of packaging and contents after conditioning; bubble leak test per ASTM F2096-11 after conditioning.
    - Package Integrity (Visual Inspection)Per ASTM F1866/F1886M-09
    - Package Integrity (Dye Penetration)Per ASTM F1929-15
    - Package Integrity (Seal Strength)Per ASTM F88/F88M-15
    Embryo CompatibilityMouse Embryo Assay (MEA): 1-cell, ≥ 80% blastocyst at 96h (before and after aging)Met: 1-Cell MEA: ≥80% blastocysts at 96h
    Bench PerformanceAll predetermined acceptance criteria were metStudies performed before and after aging.
    - Dimensional Verification (against device input requirements)Met: Devices measured and verified against device input requirements.
    - Appearance (no burrs, scratches, or foreign objects)Met: Devices visually inspected.
    - Tensile Strength (greater than pre-determined acceptance criterion)Met: Testing demonstrated value greater than pre-determined acceptance criterion.
    - Luer Taper Inspection (assess connection)Met: Visual inspection to assess connection.
    - Colorfastness (legible depth marking after friction)Met: Testing demonstrated legible depth marking after friction testing (100 rubs at 200g load weight).
    - Echo Test (maintenance of echo chip band)Met: Testing demonstrated maintenance of echo chip band in accordance with pre-determined acceptance criterion.

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

    • Not Applicable in the traditional sense of an AI/ML test set. The "tests" here are non-clinical bench and lab experiments on the physical device components and assembled units (e.g., sterilization validation, biocompatibility, mechanical testing, Mouse Embryo Assay).
    • Data Provenance: The studies are described as "performed to support substantial equivalence." The source of the materials and specific lab locations are not specified beyond the manufacturer (Kitazato Corporation) and their correspondent (Emergo Global Consulting, LLC) being based in Japan and the USA respectively. These are prospective tests of the manufactured device.

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

    • Not Applicable. Ground truth, in the context of expert consensus for image or data interpretation, is not relevant here as this is a physical device submission. The "ground truth" for these tests comes from established international standards (ISO, ASTM, AAMI/ANSI, USP) and verified laboratory procedures.

    4. Adjudication Method for the Test Set:

    • Not Applicable. Adjudication methods are typically for resolving discrepancies in expert interpretations (e.g., in MRMC studies for AI). Here, the tests follow defined protocols with measurable outcomes.

    5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study was done:

    • No. An MRMC study is not relevant for this type of physical medical device submission.

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

    • No. This is a physical medical device, not an algorithm.

    7. The Type of Ground Truth Used:

    • For this physical device, the "ground truth" is derived from:
      • Established Industry Standards: Compliance with ISO, ASTM, AAMI/ANSI, and USP standards.
      • Laboratory Measurements and Biological Assays: Objective measurements (e.g., dimensions, tensile strength) and biological assays (e.g., Mouse Embryo Assay, cytotoxicity testing) with predefined acceptance limits.

    8. The Sample Size for the Training Set:

    • Not Applicable. This is not an AI/ML device where a "training set" would be used to develop an algorithm.

    9. How the Ground Truth for the Training Set was Established:

    • Not Applicable. See point 8.

    Summary for this specific FDA Submission (K192540):

    The FDA 510(k) clearance for the Kitazato ET Catheters is based on demonstrating substantial equivalence to an existing legally marketed predicate device. This is achieved through a comprehensive set of non-clinical performance tests, including sterilization validation, biocompatibility studies, endotoxin testing, packaging and transportation simulation, and specific bench performance tests (dimensional verification, appearance, tensile strength, Luer taper inspection, colorfastness, echo test). Additionally, a Mouse Embryo Assay (MEA) is performed to confirm the device's compatibility with embryos. The "acceptance criteria" are the successful completion of these tests in accordance with relevant international and national standards, with all predetermined criteria reported as met. The study design is not a clinical AI performance study, but a series of laboratory and bench tests on the physical device.

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    K Number
    K162878
    Date Cleared
    2017-07-13

    (272 days)

    Product Code
    Regulation Number
    884.6110
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Kitazato ET Catheters are intended for ultrasound guided introduction of embryos into the uterine in vitro fertilisation.

    Device Description

    Kitazato ET Catheters are sterile, single-use catheters for embryo transfer. The ET Catheters consist of a transfer catheter, guide catheter, and a stylet sheath. The Transfer catheter (hereafter referred to as 'catheter' or 'ET Catheter') is composed of a catheter shaft, a connector and a shaft protective sleeve (protector). The catheter types include a normal catheter (Type1, EC-PRO Normal), a catheter with a stainless outer stiffener (Type2, EC-PRO Supported), a catheter with Echo Line (Type3, EC-PRO Master), and a catheter that has both the stainless outer stiffener and the echo line (Type4, EC-PRO Master Supported), all of which are offered in lengths of 18cm and 23cm, and various versions (v1-v8). A corresponding Trial catheter of the same length is provided for all four Types of the Kitazato ET Catheters. The Guide catheter is offered both with a straight shaft and a 30° pre-curved distal shaft. The Stylet Cannula (Type5) is an optional accessory used when additional rigidity is needed during insertion of the cannula through the cervix, and is offered in two lengths, 13.5 cm and 18.5 cm.

    During the implantation procedure of the embryo into the uterus, the catheter is introduced into the uterine cavity through the cervix, then the embryo is delivered into the uterine cavity by plunging the syringe that is coupled at the connector end of the catheter via a 6% taper luer lock. A syringe is not included with the Kitazato ET Catheters.

    AI/ML Overview

    The provided text describes the Kitazato ET Catheters, an embryo transfer catheter, and its substantial equivalence to a predicate device. It includes non-clinical performance data to support its safety and effectiveness.

    Here's the information requested, based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    Test TypeAcceptance CriteriaReported Device Performance
    Biocompatibility
    CytotoxicityPass (ISO 10993-5:2009)Passed
    SensitizationPass (ISO 10993-10:2010)Passed
    IrritationPass (ISO 10993-10:2010)Passed
    Mouse Embryo Assay (MEA)≥ 80% expanded to blastocyst at 96 hours (1-Cell MEA)Passed (1-cell mouse embryos, ≥ 80% expanded blastocysts at 96 hrs)
    Endotoxin< 20 EU/device< 20 EU/device (conforms to specification)
    Sterilization ValidationConformance to ISO 11135:2014 & ISO 10993-7:2008Passed
    Dimensional VerificationFinal sterile devices conform to dimensional specifications; luer connectors conform to ISO 594-1 and ISO 594-2Passed
    Appearance TestingPass visual inspection for scratches, burrs, and foreign objectsPassed
    Mechanical Tensile TestingMet established specificationsTensile strength met the established specifications
    Depth Mark Color-fastnessClearly legible after soaking in saline for 24 hours and 100 cycles of rubbingRemained clearly legible
    Package IntegrityPass dye penetration, seal strength, and visual inspection per ASTM 1929-15, ASTM 1866/F 1886M-09, and ASTM F88/F88M-15Passed
    Transport TestingPackaging maintained device integrityPackaging maintained device integrity
    Shelf Life TestingMaintained performance for 3 years (tensile strength, dimension, appearance, sterility, endotoxin, MEA, and color fastness)Established three (3) year shelf life following real time aging; parameters assessed (tensile strength, dimension, appearance, sterility, endotoxin, MEA, and color fastness)

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

    The document describes non-clinical performance testing of the device itself and does not involve human subjects or clinical data for a "test set" in the context of AI/diagnostic algorithm evaluation. Therefore, details regarding sample size for a test set and data provenance (country of origin, retrospective/prospective) are not applicable here. The testing was performed on the device prototypes and manufactured units.

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

    This information is not applicable as the study is a non-clinical device performance test and does not involve establishing ground truth from human expert interpretations of data (e.g., medical images).

    4. Adjudication Method for the Test Set

    This information is not applicable as the study is a non-clinical device performance test and does not involve adjudication of expert interpretations.

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

    No, a multi-reader multi-case (MRMC) comparative effectiveness study was not done. The document describes non-clinical performance testing of a medical device (catheter), not an AI algorithm intended to assist human readers. Therefore, an effect size of human readers' improvement with vs. without AI assistance is not applicable.

    6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study

    No, a standalone performance study in the context of an AI algorithm was not done. This document pertains to the physical performance characteristics of a medical catheter, not an AI or diagnostic algorithm.

    7. Type of Ground Truth Used

    For the non-clinical performance tests, the "ground truth" used are the defined specifications and standards for the device's physical, chemical, and biological properties. This includes:

    • ISO standards (e.g., ISO 10993 for biocompatibility, ISO 11135 for sterilization, ISO 11607 for packaging)
    • ANSI/AAMI standards (e.g., ANSI/AAMI ST72 for endotoxin)
    • ASTM standards (e.g., ASTM D4169 for transport, ASTM F88/F88M-15 for seal strength)
    • JIS standards (e.g., JIS L 0849 / JIS L 0803 for color-fastness)
    • Internal established specifications for tensile strength, dimensions, and appearance.
    • Biological assays (Mouse Embryo Assay) with specific biological endpoints (blastocyst development rate).

    8. Sample Size for the Training Set

    This information is not applicable. The document does not describe the development or testing of an AI algorithm, so there is no training set in that context. The "training" for the device would be its design and manufacturing process, and performance is tested against established specifications.

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

    This information is not applicable. As there is no AI algorithm training set, there is no ground truth established for it in this context.

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