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510(k) Data Aggregation

    K Number
    K954202
    Date Cleared
    1996-06-20

    (287 days)

    Product Code
    Regulation Number
    864.5425
    Reference & Predicate Devices
    N/A
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Not Found

    Device Description

    The tests presented in this application use an instrument platform and assay cartridges that have been used in cardiopulmonary bypass surgery since 1989. The instrument and assay cartridges have proven to be sturdy, reliable, and effective. The instrument and cartridges are designed for the detection of clot formation. The present series of Platelet Function Tests also rely on the detection of clot formation, thus there is not an extension of the basic technology. The basic principles of the instrument and cartridges do not change.

    AI/ML Overview

    Here's an analysis of the provided text regarding acceptance criteria and supporting studies:

    It's important to note that the provided text is a "SUMMARY OF SAFETY AND EFFECTIVENESS" for a K954202 device, which appears to be related to Platelet Function Tests. This type of document is usually submitted to regulatory bodies (like the FDA for a 510(k) clearance) and focuses on demonstrating that a new device is substantially equivalent to a predicate device and is safe and effective for its intended use.

    The document does not explicitly state specific numerical acceptance criteria or detail a formal clinical study with a predefined test set, ground truth experts, or statistical analyses (like an MRMC study or standalone performance metrics). Instead, it describes:

    • The problem with existing platelet function assessment.
    • How the new device addresses the problem by offering STAT conditions.
    • Evidence that the device measures an aspect of platelet function and correlates with existing techniques.
    • The safety of the device by comparing it to predicate devices (other Hepcon HMS cartridges).
    • The effectiveness in that it could lead to more selective use of platelet concentrates.

    Therefore, many of the requested points cannot be directly extracted as they are typically found in a detailed clinical study report or validation protocol, not a summary document like this.

    Let's break down what can be inferred or directly stated from the text:


    1. Table of Acceptance Criteria and Reported Device Performance

    As mentioned, explicit numerical acceptance criteria are not provided in this summary. The "performance" is described qualitatively.

    Acceptance Criteria (Inferred/Stated Concept)Reported Device Performance
    Measures an aspect of platelet function."The data presented in this application demonstrate that an aspect of platelet function is being measured..."
    Correlates with presently available platelet diagnostic techniques."...that it correlates with presently available platelet diagnostic techniques..."
    Measures an activity dependent on the presence of platelets."...and the tests have been demonstrated to measure an activity dependent on the presence of platelets."
    Enable more selective use of platelet concentrates."The clinical data have shown that, although platelet function disorders may not be rampant in post surgical patients, the test would allow more selective use of platelet concentrates, i.e., unless there is a clear defect in the assessed platelet function, another cause should be addressed before swamping the patient with unneeded platelet concentrates."
    Safety equivalent to predicate devices (Hepcon HMS cartridges)."In terms of safety, the present Platelet Function Test assay cartridges are similar to the In tonne of carry the Response assay cartridges. The same degree of technical skill is required... The Platelet Function Tests as presented in this application have been shown to be both effective and maintain the same level of safety as other cartridges which are presently used on the Hepcon HMS."
    Reliable and effective (similar to predicate technology)."The instrument and assay cartridges have proven to be sturdy, reliable, and effective." (This refers to the core Hepcon HMS platform, suggesting the new assays inherit these qualities).
    Built-in error analysis for mishandling/inadequate samples."All the cartridges have some built in error analysis. Since even the activated clotting time is a duplicate channel assay, results must fall within certain limits, or the test is invalidated. The same holds true for the Platelet Function Tests. The existence of a titration curve illustrates that the test has been properly performed."
    Ability to be used for quality control (trending data, normal/abnormal samples)."The trending of test data is relatively straightforward. Drawing a normal donor is also straight forward and has added ability to also provide an "abnormal" control by preactivating the platelets in a portion of the sample. This allows the end user to verify that the test does work."

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

    • Test Set Sample Size: Not explicitly stated as a number. The text refers to "clinical data" and "data presented in this application."
    • Data Provenance: The context of "cardiopulmonary bypass surgery since 1989" suggests the data would likely be from retrospective or prospective clinical observations related to this surgical setting. The document is dated September 5, 1995, so the data would predate this. No country of origin is specified, but given it's a US regulatory submission (K954202), it's highly probable it includes US data.

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

    • Number of Experts: Not mentioned.
    • Qualifications of Experts: Not mentioned. This type of device relies on laboratory measurements rather than subjective expert interpretation of images or other complex data. The "ground truth" would likely be established by comparing the device's measurements to established, perhaps more laborious, laboratory methods for platelet function, or to clinical outcomes.

    4. Adjudication Method for the Test Set

    • Adjudication Method: Not applicable or mentioned. This document describes a diagnostic measurement device, not an AI-driven interpretive system that requires human adjudication of interpretations. The "adjudication" in this context would be the internal error analysis (e.g., duplicate channels, titration curve validity) of the device itself determining if a test is valid.

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

    • MRMC Study: No, this document does not describe an MRMC comparative effectiveness study. This type of study is typically performed for interpretive diagnostic tools (like imaging AI) where human readers (e.g., radiologists) are evaluated with and without AI assistance across multiple cases. The provided text is for a device that performs a laboratory measurement.
    • Effect Size of Human Readers Improve with AI vs. without AI assistance: Not applicable, as no MRMC study or AI assistance for human interpretation is described.

    6. Standalone (Algorithm Only) Performance Study

    • Standalone Performance: The entire description focuses on the standalone performance of the device itself (the "Platelet Function Tests"). The data presented is intended to show the device's ability to measure platelet function, correlate with other techniques, and its safety. It's an algorithm (the device's internal processing) converting signals to a measurement. So, in essence, the "study" described (albeit at a high level) is a standalone performance evaluation of the device.

    7. Type of Ground Truth Used

    • Type of Ground Truth: Inferred from the text:
      • Comparison to "presently available platelet diagnostic techniques": This suggests existing lab tests, which would serve as a reference or a form of ground truth for correlation studies.
      • "Activity dependent on the presence of platelets": This implies experimental setups where platelet presence (or absence/manipulation) defines the true state.
      • "Clinical data... allow more selective use of platelet concentrates": This hints at correlation with clinical outcomes (e.g., bleeding episodes, need for platelet transfusions), acting as a higher-level ground truth.

    8. Sample Size for the Training Set

    • Training Set Sample Size: Not mentioned. As this is a medical device clearance document from 1995, explicit "training set" and "test set" divisions (as understood in modern machine learning validation) were not typically delineated in this manner. The "data presented in this application" would serve as the overall evidence. However, the device has been in use since 1989 for other assays on the same platform, implying a long history of data acquisition and refinement for the underlying technology.

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

    • Ground Truth for Training Set: Not explicitly detailed. Similar to the test set, it would have been established through correlation with existing diagnostic techniques, controlled experiments demonstrating platelet dependency, and clinical observations regarding outcomes, all accumulated over the development and prior use of the Hepcon HMS platform and its cartridges. The mention of "drawing a normal donor" and "preactivating the platelets in a portion of the sample" for quality control suggests a method for generating known "normal" and "abnormal" samples, which would contribute to establishing how the device should respond.

    Summary Limitations:

    The provided text is a high-level summary. For a comprehensive understanding of the validation, one would need to review the full details of the 510(k) submission, including specific study protocols, statistical analyses, and raw data. The language used reflects the regulatory and scientific norms of 1995, predating the widespread use of terms and methodologies common in modern AI/ML device validation (e.g., explicit training/test splits, specific performance metrics like AUC, ROC analysis, or detailed MRMC study designs).

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