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510(k) Data Aggregation

    K Number
    K043204
    Date Cleared
    2005-03-30

    (132 days)

    Product Code
    Regulation Number
    880.5725
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Sgarlato PainFree Pump is a single use, general purpose infusion device intended to provide continuous infusion of medication (such as local anesthetics or corticosteroids) directly into a target site for the purpose of pain relief. Infusion may be carried out via percutaneous, subcutaneous, and epidural routes. The PainFree Pump may be used to provide continuous infusion of a local anesthetic directly into an intraoperative site for postoperative management of pain following surgery. It is suitable for use as an ambulatory device. It is not intended for vascular drug delivery, hyperalimentation, or the delivery of blood or blood products.

    Device Description

    The Sgarlato PainFree pump is mechanically the same device currently legally marketed by Sgarlato Labs for continuous infusion of liquid medication into an intraoperative site for postoperative pain management. This infusion pump is one of a multiplicity of similar general purpose devices marketed to provide continuous infusion of moderate amounts of liquid medication (100-200 ml) over an extended period of time without use of electrical power. These mechanically-driven, single-use or reusable infusion pumps are therefore suitable for ambulatory use and can provide medication infusion via catheters for extended periods ranging from a few hours to several days. The PainFree pump uses a syringe-like reservoir that compresses the plunger against a self-contained spring to apply pressure to the liquid volume in the syringe. The Sgarlato device is distributed as a single-use sterile device.

    AI/ML Overview

    This looks like a 510(k) summary for a medical device, which typically focuses on demonstrating substantial equivalence to a predicate device rather than providing extensive details about a clinical study with detailed acceptance criteria and performance data in the way a PMA or clinical trial summary would.

    Therefore, many of the requested items (sample sizes, expert qualifications, adjudication methods, MRMC studies, standalone performance, training set details) are not applicable or not provided in this type of submission.

    The document describes the acceptance criteria by comparing the new device (Sgarlato PainFree pump) to two predicate devices (Paragon Infusion Kit K984146 and Sgarlato Pain Control Infusion Pump K990101) to establish substantial equivalence. The "performance" is demonstrated through this comparison, showing that its specifications are similar to or within the expected range of already cleared devices for its expanded indications.

    Here's a breakdown based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    The device demonstrates "performance" by being substantially equivalent to the predicate devices. The acceptance criteria are essentially met if the characteristics of the Sgarlato PainFree Pump are comparable to the Paragon Infusion Kit and the Sgarlato PCIP (Sgarlato Pain Control Infusion Pump), especially regarding the new indications.

    ItemAcceptance Criteria (from Predicate Devices)Sgarlato PainFree Pump Performance (from device description)
    Intended UseVariety of continuous infusion for pain management (Intraoperative for PCIP; General Infusion for Paragon)Continuous infusion of medication into a target site for pain management
    Routes of AdministrationPercutaneous (PCIP); Percutaneous, subcutaneous, intramuscular, and epidural (Paragon)Percutaneous, subcutaneous, and epidural
    ContraindicationsNot for IV, blood products, lipids (Paragon); Not for epidural, subcutaneous, vascular, blood products, TPN (PCIP)Not for IV, blood products, lipids, or fat emulsions
    ReuseReusable pump, single-use administration sets (Paragon); Single Use (PCIP)Single Use
    Fill Volumes100 ml (Paragon); 100 or 200 ml (PCIP)100 or 200 ml
    Flow Rates0.5, 1, 2, 4, or 10 ml/hr (Paragon); 0.5, 1, or 2 ml/hr (PCIP)1, 2, or 4 ml/hr
    Flow controlMicro-bore tubing with medication filter (both predicates)Micro-bore tubing with 5 micron medication filter
    Pump MechanismSpring-scissors plate compressing PVC bag (Paragon); Spring-powered syringe plunger (PCIP)Spring-powered syringe plunger
    PowerCompressed spring (both predicates)Compressed spring
    Components and MaterialsConform with ISO 10993 part 1 for fluid path (both predicates)Conform with ISO 10993 part 1 for fluid path
    Safety/AlarmsNone except fluid level indicator/plunger movement monitors flow (both predicates)None except plunger movement monitors flow
    PackagingTyvek-sealed tray with pump, administration sets, accessories (both predicates)Tyvek-sealed tray with pump, administration sets, accessories, and catheter sets

    2. Sample size used for the test set and the data provenance

    Not applicable/Not provided within this 510(k) summary. This document relies on comparison to predicate devices, not a separate "test set" with patient data. The "test" is the comparison of device specifications and intended use against existing cleared devices.

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

    Not applicable/Not provided. This is not a study requiring expert ground truth in the traditional sense. The "ground truth" for substantial equivalence is the FDA's existing clearances for the predicate devices.

    4. Adjudication method for the test set

    Not applicable/Not provided. No "test set" or adjudication process described as part of this substantial equivalence determination.

    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 an infusion pump, not an AI or imaging diagnostic device.

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

    Not applicable. This device is an infusion pump, not an algorithm. Its operation is purely mechanical.

    7. The type of ground truth used

    The "ground truth" for this 510(k) submission is the FDA's prior clearance of the predicate devices based on their established safety and effectiveness. The Sgarlato PainFree pump is deemed substantially equivalent if it shares similar technological characteristics and has the same or similar intended use, without raising new questions of safety and effectiveness, as demonstrated by the comparison table and descriptive text.

    8. The sample size for the training set

    Not applicable/Not provided. This is a mechanical medical device, not a machine learning algorithm requiring a training set.

    9. How the ground truth for the training set was established

    Not applicable/Not provided. As above, no training set is relevant for this type of device submission.

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