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510(k) Data Aggregation

    K Number
    K190977
    Manufacturer
    Date Cleared
    2019-11-22

    (221 days)

    Product Code
    Regulation Number
    876.5980
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Navina Systems are indicated for use for children (2 -

    Device Description

    The subject Navina Smart System is an electronically controlled, trans-anal irrigation system. The subject Navina Smart System consists of an electronic control unit, a water container and tubing set for water instillation, single-use, disposable rectal balloon catheters in two sizes (regular or small), and a disposable rectal cone catheter. The water container, tubing set and the regular (size) rectal balloon catheter utilized with the Navina Smart System are identical to the same components cleared under the original clearance of the predicate Navina Classic System in premarket notification, K170487.

    With the Navina Smart control unit, the user controls water volume, irrigation speed, and rectal catheter balloon inflation. The Navina Smart system includes a mobile application in which users can save treatment data and rate their irrigation. The Navina Smart mobile application facilitates tracking of TAI treatment data (e.g., treatment duration, water volume used, rectal balloon size, etc.) but does not function in any way to control the function of the Navina Smart System itself.

    The Navina Classic System is a manually operated trans-anal irrigation (TAI) system. The Navina Classic System, as subject of this "bundled" 510(k), consists of a manual control unit, a water container and tubing set for water instillation, single-use, disposable rectal balloon catheters in two sizes (regular or small), and a disposable rectal cone catheter. The water container, tubing set, and regular (size) rectal balloon catheter are identical to the same Navina Classic System components that were cleared under the system's original clearance in the predicate premarket notification, K170487.

    AI/ML Overview

    This document describes the Dentsply Sirona Navina Smart System and Navina Classic System, trans-anal irrigation (TAI) systems. The submission is a 510(k) premarket notification (K190977) for the introduction of the Navina Smart System and modification of the Navina Classic System.

    Here's a breakdown of the acceptance criteria and study information provided:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly present acceptance criteria in a table format with corresponding reported device performance values. Instead, it lists the types of performance tests conducted and states that "The results of the testing conducted in conformity with applicable standards support substantial equivalence." This implies that the devices met the performance requirements defined by these standards.

    Here's an organized view of the performance testing categories:

    Acceptance Criteria Category (Implied by Test Type)Reported Device Performance (Implicitly Met)
    Control Unit Performance
    Control of air leakageMet applicable standards
    Complete deflation of balloon (air release)Met applicable standards
    Ability to instantly stop waterflowMet applicable standards
    Control of water flow rateMet applicable standards
    Control of water back flowMet applicable standards
    Setting of balloon size (Navina Smart System)Met applicable standards
    Small Rectal Catheter Performance
    Balloon burst volumeMet applicable standards
    FlexibilityMet applicable standards
    Even balloon inflationMet applicable standards
    Balloon burst diameterMet applicable standards
    Rectal catheter flow rateMet applicable standards
    Rectal catheter after catheter kinkMet applicable standards
    Hydrophilic coatingMet applicable standards
    Conical Rectal Catheter Performance
    Hydrophilic coating at insertion and withdrawalMet applicable standards
    Bonding strength between the catheter body and conical componentMet applicable standards
    Software Verification & Validation
    Compliance with IEC 60601-1 (Basic safety and essential performance)Met applicable standards
    Compliance with IEC 60601-1-11 (Home healthcare environment)Met applicable standards
    Compliance with IEC 60601-1-2 (Electromagnetic disturbances)Met applicable standards
    Compliance with IEC 60601-1-6 (Usability)Met applicable standards
    Compliance with IEC 62304 (Software Life Cycle Processes)Met applicable standards
    Compliance with IEC 62133 (Secondary Cells and Batteries Saftey)Met applicable standards
    Compliance with IEC 62366-1 (Usability Engineering)Met applicable standards
    Biocompatibility
    Simulated use extraction (ISO 10993-12)Supported substantial equivalence
    Chemical characterizationSupported substantial equivalence
    Toxicological analysis and assessmentSupported substantial equivalence

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

    The document describes non-clinical performance testing and does not provide details on the sample sizes for these tests. It states that the testing was conducted to support substantial equivalence and addressed new components not part of the original clearance (K170487).

    Regarding data provenance, the testing appears to be internal performance testing conducted by the manufacturer, Dentsply Sirona. The tests are for device components and software, not human subject data. Therefore, notions of "country of origin of the data" or "retrospective/prospective" studies are not directly applicable in the sense of clinical trials.

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

    This information is not provided in the document. The performance testing described is non-clinical, focusing on engineering and safety standards for the device itself. Therefore, the concept of "ground truth" as established by medical experts for a diagnostic or clinical outcome is not directly relevant here.

    4. Adjudication Method for the Test Set

    This information is not provided in the document. Given that the performance testing is non-clinical and related to engineering standards, an adjudication method in the context of human interpretation or clinical endpoints would not typically be applicable. The tests likely have objective pass/fail criteria based on measured parameters and compliance with stated standards.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and the Effect Size of How Much Human Readers Improve with AI vs. Without AI Assistance

    No, an MRMC comparative effectiveness study was not done. The Navina Smart System and Navina Classic System are trans-anal irrigation devices, not diagnostic AI systems that assist human readers in interpreting medical images or data. The Navina Smart system includes a mobile application for tracking data, but it does not function to control the device or provide AI assistance to human readers for diagnostic interpretation.

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

    The Navina Smart System includes an "electronically controlled, trans-anal irrigation system" with a control unit that manages water volume, irrigation speed, and balloon inflation. It also has a mobile application for tracking treatment data.

    While the control unit operates with programmed logic (an "algorithm"), the performance testing described (Control of air leakage, Complete deflation of balloon, Ability to instantly stop waterflow, Control of water flow rate, Control of water back flow, Setting of balloon size) represents a form of standalone testing for the functions controlled by the device's embedded software. This is not "algorithm only" in the sense of an AI model making a recommendation, but rather the functional performance of the electromechanical system. The mobile application facilitates tracking but does not function in any way to control the function of the Navina Smart System itself. So, the core function of water instillation and balloon inflation is a standalone device operation.

    7. The Type of Ground Truth Used (Expert Consensus, Pathology, Outcomes Data, etc.)

    For the non-clinical performance testing described, the "ground truth" would be the engineering specifications and applicable international standards (e.g., IEC 60601 series, IEC 62304, IEC 62133, IEC 62366-1, ISO 10993-12). The devices are tested against physical and functional requirements defined by these standards and the manufacturer's design specifications.

    8. The Sample Size for the Training Set

    This information is not provided as there is no mention of a "training set" in the context of machine learning or AI model development. The Navina Smart System and Navina Classic System are medical devices with electromechanical components and software, not AI algorithms that are trained on large datasets.

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

    This information is not applicable as there is no "training set" for an AI model mentioned in the document.

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