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510(k) Data Aggregation

    K Number
    K193088
    Manufacturer
    Date Cleared
    2020-10-23

    (352 days)

    Product Code
    Regulation Number
    880.5440
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    MaxZero Extension Sets with Needle-Free Connector(s)

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

    The MaxZero™ extension set with needle-free connector(s) is for single use only. The MaxZero™ extension set with needle-free connector(s) may be used for direct injection, intermittent infusion, continuous infusion or aspiration of drugs, blood and fluids.

    Device Description

    The MaxZero™ Extension Sets with Needle-Free Connector(s) are intravascular extension sets intended for single patient use, including pediatrics and immunocompromised patients, for direct injection, intermittent infusion continuous infusion or aspiration of drugs, blood and fluids. The MaxZero™ Extension Sets with Needle-Free Connector(s) are sterile single patient devices that can be used for up to seven (7) days and 200 activations. All extension sets included in this submission are not made from natural rubber latex or DEHP.

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for a medical device, the MaxZero™ Extension Sets with Needle-Free Connector(s). This type of submission relies on demonstrating "substantial equivalence" to a predicate device, rather than proving independent effectiveness through clinical trials in the same way a new drug or novel medical device might.

    Therefore, the "acceptance criteria" and "study that proves the device meets the acceptance criteria" in this context refer to the engineering and performance tests performed to demonstrate that the new device (subject device) is as safe and effective as the previously cleared predicate device, despite some differences.

    Here's an analysis of the provided information within the framework of your request:

    Acceptance Criteria and Reported Device Performance

    The acceptance criteria are not explicitly stated in a quantitative table with corresponding numerical results in the provided document. Instead, the document discusses various performance tests conducted according to established ISO standards and FDA guidance, with a general statement that "All test results met their acceptance criteria." The table provided on pages 5-6 outlines various characteristics of the subject device and compares them to the predicate device, indicating "Equivalence" or "Different" with explanations.

    Based on the information, the acceptance criteria are implicitly derived from the relevant ISO standards and FDA guidance documents, which define the expected performance metrics for intravascular administration sets. The "reported device performance" refers to the fact that the device passed these tests.

    Implied Acceptance Criteria and Reported Performance (extracted from comparison and performance discussion):

    Performance CharacteristicImplied Acceptance Criteria (based on predicate/standards)Reported Device Performance (as stated in document)
    Regulation Number21 CFR 880.5440Met (Same as predicate)
    Regulation NameIntravascular Administration SetMet (Same as predicate)
    ClassClass IIMet (Same as predicate)
    Product CodeFPAMet (Same as predicate)
    SterilityMust be sterile (E-Beam)Met (Sterilization by E-Beam)
    PurityNon-PyrogenicMet (Non-pyrogenic)
    Material SafetyNot made with DEHP, Not natural latex rubberMet (Not made with DEHP, not natural latex rubber)
    Usable LifeUp to 7 days, 200 activationsMet (Up to 7 days, 200 activations)
    DisinfectionDisinfectable with 70% Isopropyl AlcoholMet
    BiocompatibilityISO 10993-1 compliantMet (Conducted per ISO 10993 series)
    LeakageMust not leak (per ISO 594-1/2)Met acceptance criteria
    Separation ForceMust meet spec (per ISO 594-1/2)Met acceptance criteria
    Unscrewing TorqueMust meet spec (per ISO 594-1/2)Met acceptance criteria
    Ease of AssemblyMust meet specMet acceptance criteria
    Resistance to OverridingMust meet specMet acceptance criteria
    Stress CrackingMust meet specMet acceptance criteria
    Particulate ContaminationMust meet USPMet acceptance criteria
    Tensile StrengthMust meet specMet acceptance criteria
    Male Conical FittingMust meet specMet acceptance criteria
    Protective CapsMust meet specMet acceptance criteria
    Chemical RequirementsMust meet specMet acceptance criteria
    Biological RequirementsMust meet specMet acceptance criteria
    Fluid Filter PerformanceMust perform as intended (for filtered models)Met acceptance criteria
    UV Light ResistanceBlocks minimum 90% of UV light (250-450 nm)Met (Proposed new component performance)
    Flow TestingMust meet spec (microbore/minibore)Met acceptance criteria
    ClampsMust meet spec (internal excess pressure, fluid path)Met acceptance criteria
    Peak Pressure TestingMust meet specMet acceptance criteria
    Priming VolumeVaries (range from 0.7mL – 2.0mL reported)Met (Different from predicate, but acceptable)
    Vacuum Integrity-2.9 psi vacuum reportedMet (Different from predicate, but acceptable)
    Maximum Pressure30 psi (non-pressure rated sets per ISO 8536)Met (Different from predicate, but acceptable)
    Shelf Life1 Year (subject device) vs 3 Years (predicate)Met (Acceptable for substantial equivalence)
    Air Water Interface VisibilityPass (Clear Tubing)Met acceptance criteria
    Microbial IngressMust not permit microbial ingressMet acceptance criteria

    Note: The document explicitly states "Design Control activities have been conducted and have confirmed the different technological characteristics of the proposed device do not raise different questions of safety and effectiveness" for the characteristics where the subject device differs from the predicate (e.g., device length, materials, configurations, physical specifications, filter size, tubing bore, bonding agent, priming volume, vacuum integrity, maximum pressure, shelf life, light resistance of amber tubing). This indicates that the differences were evaluated and found to be acceptable for substantial equivalence.


    Study Details (as applicable to a 510(k) for a Class II device)

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

    • Sample Size: Not explicitly stated in the provided abstract for each specific test. However, typical non-clinical performance testing for medical devices involved in 510(k) submissions would use a predetermined number of samples for each test type (e.g., n=3, n=5, n=10, or more, depending on the test and statistical rationale).
    • Data Provenance: The data is from non-clinical bench testing ("CareFusion performed design verification performance testing"). There is no mention of country of origin for the testing itself, but given it's an FDA submission, the testing would be expected to adhere to international and potentially US-specific standards. The nature of the testing is prospective as it's part of design verification for a new device.

    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    • Not applicable in this context. This is a non-clinical, engineering/performance study assessing a physical medical device's functional characteristics (e.g., leakage, tensile strength, flow rate, material compatibility). "Ground truth" established by human experts (like radiologists for image analysis) is not relevant to this type of device and study. The "ground truth" here is the pass/fail criteria defined by the recognized consensus standards (e.g., ISO, ASTM, USP) and the device's design specifications.

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

    • None. This is not a study involving human interpretation or subjective assessment that would require an adjudication method. The test results are quantitative physical measurements or qualitative pass/fail outcomes against pre-defined engineering and material standards.

    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 is a medical device (intravascular administration set), not an AI/imaging device. Therefore, MRMC studies are not applicable.

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

    • Not applicable. As stated, this is a physical medical device, not an algorithm.

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

    • The "ground truth" (or more accurately, the acceptance criteria) for this type of device performance study is based on recognized consensus standards (like various ISO standards for medical devices, ASTM standards, USP for particulate matter) and the predicate device's established performance and safety profile. The testing verifies that the subject device meets these established engineering, material, and functional benchmarks.

    7. The sample size for the training set:

    • Not applicable. There is no "training set" in the context of this traditional 510(k) submission for a physical medical device. This is not an AI/machine learning product. The design and manufacturing process are subject to Quality System (QS) Regulation (21 CFR Part 820), which involves process validation and quality control, but not a "training set" in the computational sense.

    8. How the ground truth for the training set was established:

    • Not applicable. (See point 7).
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