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510(k) Data Aggregation

    K Number
    K241988
    Date Cleared
    2024-10-23

    (107 days)

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

    ProSeal™ Closed System Bag Access

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

    The ProSeal™ Closed System drug Transfer Device (CSTD) mechanically prohibits environmental contaminants from entering the system and the escape of drug or vapor concentrations from thereby minimizing individual and environmental exposure to drug vapor, aerosols, and spills. The ProSeal™ system also prevents the introduction of microbial contaminations into the drug or fluid path for up to 7 days when used as intended.

    Device Description

    The ProSeal™ CSTD is a sterile, single-use, pyrogen-free CSTD for the preparation, reconstitution, compounding, and administration of antineoplastic and hazardous drugs, intended for use in clinical settings by trained health care professionals and/or pharmacists.

    The ProSeal™ Closed System Bag Access is a component of the ProSeal™ CSTD system which is intended for connection to a standard I.V. bag and appropriate ProSeal™ CSTD component devices for the injection and infusion of I.V. infusion fluids. It is an adaptor between IV bags and ProSeal™ CSTD components for closed system fluid transfer into and out of the I.V. bag. The Subject bag access is compatible with the ProSeal™ Injector or the ProSeal™ Injector Plus (cleared K240171) and other ProSeal™ component devices, e.g. ProSeal™ Closed System Administration Set (for infusion from the I.V. bag). The ProSeal™ Closed System Bag Access and all its corresponding interface membranes exhibit a dry connection with the communicating surfaces in a fluid transfer. The use of this component device and its appropriate ProSeal CSTD connecting component device reduces the risk of microbial ingress for up to 168 hours or 7 days, when used as intended.

    The closed transfer of liquid that takes place with the use of the ProSeal™ CSTD system as follows:

    • A double membrane septum design utilizing self-sealing elastomeric membranes tightly fits . together when the system components engage. A cannula within the ProSeal™ Injector Plus housing perforates the double membranes for the transfer of liquid. When the cannula is retracted, the membranes seal off the transfer of environmental contaminants into the system and/or escape of drug or vapor concentrations outside the system, thereby minimizing the individual and environmental exposure to drug vapor, aerosols, and spills, and also minimizing the risk of microbial contamination, when used as intended.
    AI/ML Overview

    Based on the provided FDA 510(k) summary for the ProSeal™ Closed System Bag Access (K241988), here's a breakdown of the acceptance criteria and the study that proves the device meets them:

    Disclaimer: This document is a 510(k) summary, which provides an overview of the substantial equivalence determination. It does not contain the full details of all the studies performed. Therefore, specific quantitative performance metrics beyond what is explicitly stated for acceptance and observed results are not available in this summary.


    1. Table of Acceptance Criteria and Reported Device Performance

    The provided document describes functional performance, biocompatibility, sterility, shipping, and shelf-life testing. While specific quantitative acceptance criteria are not explicitly listed in a single table with corresponding numerical results, the document states conformance to various ISO and FDA recognized standards. The "Comment/Discussion" column in the comparison table indicates "Same" or "Similar" for many characteristics, implying that the acceptance criteria are met by demonstrating equivalence to the predicate device and adherence to standards.

    For functional performance, the document lists the following tests and their corresponding standards, implying that meeting these standards constitutes the acceptance criteria. The performance data "supporting substantial equivalence" suggests that the device met these criteria.

    Acceptance Criteria (Implied by Standard Conformance)Reported Device Performance (Implied)
    Functional Performance
    Leak integrity (per ISO 8536-4:2019, 7.2 & A.3)Bench performance verifications and validations performed, indicating conformance.
    Tensile strength (per ISO 8536-4:2019, 7.3 & A.4)Bench performance verifications and validations performed, indicating conformance.
    Penetration force (per ISO 22413:2021, 6.6 & A.7)Bench performance verifications and validations performed, indicating conformance.
    Protective caps (per ISO 8536-4:2019, 7.13)Bench performance verifications and validations performed, indicating conformance.
    Vapor containment (per NIOSH CSTD 2016 draft protocol)"from testing data on devices cleared under K222929" (implying met, as K222929 was cleared)
    Microbial ingress (per FDA guidance & ANSI AAMI CN27:2021)"from testing data on devices cleared under K222929" (implying met, as K222929 was cleared and previous devices established "up to 7 days" prevention)
    Biocompatibility (Classified: Externally Communicating Device, Blood Path Indirect, Prolonged Contact)
    Cytotoxicity (per ISO 10993-5)Performed on referred-to cleared devices (K222929), implying met.
    Sensitization (per ISO 10993-10)Performed on referred-to cleared devices (K222929), implying met.
    Intracutaneous Reactivity (per ISO 10993-10)Performed on referred-to cleared devices (K222929), implying met.
    Acute Systemic Toxicity (per ISO 10993-11)Performed on referred-to cleared devices (K222929), implying met.
    14-day Subacute/Subchronic Acute Systemic Toxicity (per ISO 10993-11)Performed on referred-to cleared devices (K222929), implying met.
    In-vitro Hemolysis Assessment (per ISO 10993-4)Performed on referred-to cleared devices (K222929), implying met.
    Material Mediated Pyrogenicity (per ISO 10993-11)Performed on referred-to cleared devices (K222929), implying met.
    Particulate matter (per ISO 8536-4:2019 and USP )Testing conducted on Subject device, implying met.
    Sterility & Shelf-Life
    Sterilization (per ISO 11135:2014, SAL 10-6)Complies with standard, testing/evaluations conducted on K222929, implying met.
    Simulated shipping (per ASTM D 4169-16)Testing conducted, implying met.
    Package integrity (per ASTM F1980-21, F88/F88M-21, F1929-23, EN 868-5:2009)Testing performed, implying met.
    Pyrogen Tests (per ANSI/AAMI ST72/2019, USP , , )Testing conducted "on every lot", implying met.
    Shelf-life (3 years)Validated using ASTM 1980-21, implying met.

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

    The document does not explicitly state the specific sample sizes used for each of the functional performance, biocompatibility, or sterility tests. It refers to various ISO and ASTM standards, which typically prescribe minimum sample sizes for such tests.

    • Data Provenance: The document states "Bench performance verifications and validations referred-to and performed" and "testing data on devices cleared under K222929." This indicates that the testing was primarily benchtop testing (laboratory-based) and retrospective, leveraging data from previously cleared devices within the ProSeal™ CSTD system (specifically K222929). There is no mention of data provenance by country of origin or specific patient data since the studies are physical/chemical rather than clinical.

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

    This section is Not Applicable to this 510(k) submission. The device is a physical medical device (intravascular administration set component), not an AI/ML diagnostic or image analysis device that requires expert human interpretation to establish ground truth from medical images or clinical data. Its performance is evaluated through physical, mechanical, and biological testing against established standards.


    4. Adjudication Method for the Test Set

    This section is Not Applicable. Adjudication methods (like 2+1, 3+1 consensus) are typically used in clinical studies involving human interpretation or subjective assessments, especially for AI/ML devices where ground truth might be derived from multiple expert opinions. For a physical device undergoing performance and safety testing against objective engineering and biological standards, such adjudication is not relevant.


    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done, Effect Size of how much Human Readers Improve with AI vs. without AI Assistance

    This section is Not Applicable. An MRMC study is relevant for diagnostic or AI-assisted diagnostic devices that evaluate human reader performance. The ProSeal™ Closed System Bag Access is a hardware component for drug transfer and does not involve human readers interpreting medical cases.


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

    This section is Not Applicable. This concept applies to AI/ML software. The ProSeal™ Closed System Bag Access is a physical device component.


    7. The Type of Ground Truth Used

    The "ground truth" for this device's performance is established by conformance to internationally recognized performance standards (e.g., ISO, ASTM, USP, ANSI/AAMI) for medical devices, specifically for intravascular administration sets and closed system transfer devices. This includes:

    • Engineering/Physical Standards: Defining acceptable ranges for leak integrity, tensile strength, penetration force, package integrity, etc.
    • Biological Standards: Defining acceptable levels for biocompatibility (cytotoxicity, sensitization, systemic toxicity, hemolysis, pyrogenicity) and sterility.
    • Functional Claim Validation: Demonstration of preventing microbial ingress and vapor containment as defined by specific test protocols (e.g., microbial ingress test, vapor containment test).

    8. The Sample Size for the Training Set

    This section is Not Applicable. The product is a physical medical device, not an AI/ML algorithm. Therefore, there is no "training set" in the machine learning sense. The design and manufacturing processes are validated through engineering principles and compliance with quality systems (e.g., 21 CFR Part 820).


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

    This section is Not Applicable for the same reason as point 8.

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