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510(k) Data Aggregation

    K Number
    K233034
    Manufacturer
    Date Cleared
    2024-04-12

    (200 days)

    Product Code
    Regulation Number
    876.5980
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Mobility+ Enteral Feeding System OTC

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

    Mobility+ is intended to deliver liquid nutrition formula to an enteral access device (feeding tube) in users aged 2 years and over.

    Device Description

    The Mobility+ Enteral Feeding System OTC ("Mobility+ OTC" or the "System") is a portable, lightweight, non-electronic, disposable enteral feeding system intended to deliver liquid nutrition formula to an enteral access device (feeding tube) in users aged 2 years and over in clinical or home care settings. The device is for single patient use, disposable and intended for use over a 24-hour period.

    The System has three primary components; food pouch, filling set and giving set.

    Food Pouch: The Food Pouch serves as the Mobility+ Enteral Feeding System OTC system's combined reservoir and pump. The pouch consists of a foil container with an internal elastomeric pouch. The Food Pouch can hold up to 500 ml of feed.

    Filling Set: The Filling Set is tubing that connects to the Mobility+ food pouch to deliver commercially available nutritional feed from its packaging to the Food Pouch using ENFit connectors. The Filling Set is used to transfer feed from the feed packaging into the Food Pouch, using a syringe.

    Giving Set: The Giving Set is tubing that connects the Food Pouch to the implanted feeding tube's ENFit connector. The Giving Sets will be available in a variety of lengths to give a range of feed flow rates. All connectors in the Mobility+ Enteral Feeding System OTC comply with the FDA-recognized ENFit standard (ISO 80369-3 and ISO 18250-3).

    The Mobility+ Enteral Feeding System OTC may be worn in a bag of choice that can fit the system without kinking the tubing and without squeezing the pouch. The instructions for use guide the user to place the spout of the pouch within 15cm (6 inches) above or below the stoma when feeding.

    AI/ML Overview

    This is a non-AI medical device; therefore, sections 1-9 are not applicable.

    The provided document describes the Mobility+ Enteral Feeding System OTC, a non-electronic, disposable enteral feeding system intended to deliver liquid nutrition formula. As a physical medical device (a pump and tubing system) rather than an AI/software device, the concepts of acceptance criteria related to AI performance, ground truth establishment by experts, training/test sets, or MRMC studies are not applicable in this context.

    The document states:

    • "Non-Clinical Information: The Mobility+ System OTC is the identical device as the predicate. Therefore, all technological characteristics (e.g., design, material, functionality) are identical and non-clinical performance data tests were not repeated."
    • "Clinical Information: Clinical studies were not deemed necessary for The Mobility+ Enteral Feeding System OTC as bench testing was sufficient to demonstrate substantial equivalence by way of comparison to a legally marketed predicate device."

    The acceptance criteria for this device are demonstrated through design verification and validation tests, which focus on the physical and functional aspects of the system.

    Here's the relevant information about the "acceptance criteria" through the lens of device testing:

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

    The document lists "Design Verification Tests" and "Design Validation Tests". These tests represent the acceptance criteria for the device's functionality and safety. The reported device performance is that the device met these requirements.

    Acceptance Criteria (Design Verification Tests)Reported Device Performance
    System FillMet requirements
    Connector dimensional and functionalMet requirements
    Pouch valve seal pressureMet requirements
    On/Off Clamp functionalityMet requirements
    Flowrate under nominal, minimum and overfill conditionsMet requirements
    Residual Feed remaining in systemMet requirements
    Multiple use within 24 hour periodMet requirements
    Temperature performanceMet requirements
    Device height relative to stomaMet requirements
    Shelf-life testingMet requirements
    Biological EvaluationMet requirements
    IFU requirements (maintain integrity, legible)Met requirements
    Tube kink resistanceMet requirements
    Foil seal strengthMet requirements
    Spout neck sealMet requirements
    Bond strengthMet requirements
    Leak testMet requirements
    Drop testMet requirements
    Ancillary device compatibilityMet requirements
    Packaging seal strengthMet requirements
    Removal of product from PackagingMet requirements
    Labelling requirements (maintain integrity, adhesion, legible)Met requirements
    UDI (legible)Met requirements
    Acceptance Criteria (Design Validation Tests)Reported Device Performance
    Removal of Product from PackagingMet requirements
    Ability to fillMet requirements
    Ability to feedMet requirements
    Ability to flushMet requirements
    Ability to use while mobileMet requirements
    Labelling requirements (easy to understand, language, legible)Met requirements
    IFU requirements (easy to understand, language)Met requirements

    The document states: "The test results (K222678 – Volume 0007 Bench Testing) demonstrate that the Mobility+ Enteral Feeding System OTC, being identical to the predicate device, meets the requirements in the applicable standards."

    2. Sample size 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 physical device and the primary evidence is bench testing, not data from a test set. The testing was done on the predicate device (K222678) and deemed identical, meaning the provenance would be tied to the predicate's testing. Specific sample sizes for each bench test are not provided in this summary.

    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 physical device is established by physical measurement, performance specifications, and safety standards, not expert consensus on interpretations as would be the case for an AI diagnostic device.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
    Not applicable. This is not a study involving human interpretation or subjective assessment that would require adjudication.

    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 device is not an AI-assisted diagnostic tool.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
    Not applicable. This device is a physical, non-electronic enteral feeding system, not an algorithm.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
    The "ground truth" for this medical device is established by adherence to design specifications, functional requirements, and recognized standards (e.g., ISO 10993-1 for biocompatibility, ISO 80369-3 and ISO 18250-3 for ENFit connectors), as demonstrated through bench testing.

    8. The sample size for the training set
    Not applicable. This is a physical device, not an AI model.

    9. How the ground truth for the training set was established
    Not applicable. This is a physical device, not an AI model.

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