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510(k) Data Aggregation

    K Number
    K202141
    Date Cleared
    2021-01-15

    (168 days)

    Product Code
    Regulation Number
    870.1340
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Scorpion Stylet Portal Vein Access Set, Scorpion Needle Portal Vein Access Set

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

    The Scorpion Portal Vein Access Sets are intended for transjugular liver access in diagnostic and interventional procedures.

    Device Description

    The Scorpion Portal Vein Access Sets have two models. One model has a Stylet as the puncture tool and the other model has a 17ga Needle as the puncture tool. The Scorpion Stylet Portal Vein Access Set contains a 10F Introducer Sheath, a 10F Dilator, a 5F MPA catheter, a 14ga Stiffening Cannula, a 0.040" Nitinol Stylet with a 5Fr PEEK Catheter, and a 7F Cannula Sheath. The 14ga stiffening cannula with cannula sheath has a directional handle that indicates the direction of the curve. The 10F Introducer Sheath hemostatic valve is designed to be compatible with up to 13F (4.3mm/0.171") sleeve. These components are used to create a pathway through the liver parenchyma through which an endoprosthetic can be delivered. The Scorpion Stylet Portal Vein Access Set is used to gain access to the hepatic vein and guide a sharp puncture tool (0.040" Stylet) through the parenchyma. The puncture tool (Stylet) is used to make a pathway from the hepatic vein to the portal vein, and then the pathway is dilated to provide access for a larger sheath. The shunt is inserted through the sheath and deployed through the pathway. Then, all of the Scorpion Stylet Portal Vein Access Set components are removed.

    The Scorpion Needle Portal Vein Access Set contains a 10F Introducer Sheath, a 10F Dilator, a 5F MPA Catheter, a 13ga Scorpion Stiffening Cannula, 17ga Nitinol Needle, a 6.2F PEEK Catheter, and 8F Sheath Introducer. The 13ga stiffening cannula with cannula sheath has a directional handle that indicates the direction of the curve. The 17ga Nitinol Needle has a directional handle that indicates the direction of the 10F Introducer Sheath hemostatic valve is designed to be compatible with up to 13F (4.3mm/0.171″) sleeve. These components are used to create a pathway through the liver parenchyma through which an endoprosthetic can be delivered. The Scorpion Needle Portal Vein Access Set is used to gain access to the hepatic vein and guide a sharp puncture tool (17ga Needle) through the parenchyma. The puncture tool (Needle) is used to make a pathway from the hepatic vein to the portal vein, and then the pathway is dilated to provide access for a larger sheath. The shunt is inserted through the sheath and deployed through the pathway. Then, all of the Scorpion Needle Portal Vein Access Set components are removed.

    A Portal Vein Access Set is typically in use in procedures up to 4 hours.

    AI/ML Overview

    The provided document is a 510(k) summary for the Scorpion Portal Vein Access Set. This document is a premarket notification to the FDA to demonstrate that the new device is substantially equivalent to a legally marketed predicate device.

    For medical devices applying for 510(k) clearance, the primary study conducted is generally non-clinical performance testing and biocompatibility testing, rather than clinical studies involving human patients or complex AI algorithm performance analysis. The goal is to demonstrate that the new device is as safe and effective as a legally marketed predicate device, not necessarily to prove superior or improved efficacy through a comparative effectiveness study involving human readers with and without AI assistance.

    Therefore, the requested information pertaining to AI studies (MRMC studies, standalone AI performance, number of experts for ground truth, sample size for training set, etc.) is not applicable to this type of device clearance.

    Here's the information that can be extracted from the provided text regarding the device's acceptance criteria and the study proving it meets those criteria:


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

    The document lists various performance and biocompatibility tests conducted to demonstrate substantial equivalence to the predicate device. For each test, the implicit acceptance criterion is that the device meets the requirements outlined in the protocols based on guidances and industry standards. The reported device performance is stated as "shown to meet the acceptance criteria" or "meets the requirements for its intended use." Specific quantitative results or detailed pass/fail thresholds for each individual test are generally not included in a 510(k) summary, as it focuses on the conclusion of equivalence rather than the raw data.

    Acceptance Criteria CategorySpecific Tests PerformedReported Device Performance
    Performance TestingDimensional and Functional FitMet acceptance criteria / Requirements for intended use fulfilled
    Surface InspectionMet acceptance criteria / Requirements for intended use fulfilled
    Component CompatibilityMet acceptance criteria / Requirements for intended use fulfilled
    Tensile StrengthMet acceptance criteria / Requirements for intended use fulfilled
    Torque Strength TestMet acceptance criteria / Requirements for intended use fulfilled
    Liquid LeakageMet acceptance criteria / Requirements for intended use fulfilled
    Air LeakageMet acceptance criteria / Requirements for intended use fulfilled
    Corrosion ResistanceMet acceptance criteria / Requirements for intended use fulfilled
    Simulative UseMet acceptance criteria / Requirements for intended use fulfilled
    RadiopacityMet acceptance criteria / Requirements for intended use fulfilled
    EchogenicityMet acceptance criteria / Requirements for intended use fulfilled
    Luer Connector Functional TestingMet acceptance criteria / Requirements for intended use fulfilled
    Burst PressureMet acceptance criteria / Requirements for intended use fulfilled
    Flow RateMet acceptance criteria / Requirements for intended use fulfilled
    Resistance to Fracture TestingMet acceptance criteria / Requirements for intended use fulfilled
    Shipping TestMet acceptance criteria / Requirements for intended use fulfilled
    Biocompatibility TestingCytotoxicity (ISO 10993-5)Met acceptance criteria / Requirements for intended use fulfilled
    Sensitization (ISO 10993-10)Met acceptance criteria / Requirements for intended use fulfilled
    Intracutaneous Irritation (ISO 10993-10)Met acceptance criteria / Requirements for intended use fulfilled
    Acute Systemic Toxicity (ISO 10993-11)Met acceptance criteria / Requirements for intended use fulfilled
    Material Mediated Pyrogen (ISO 10993-11)Met acceptance criteria / Requirements for intended use fulfilled
    Hemocompatibility (ISO 10993-4)Met acceptance criteria / Requirements for intended use fulfilled
    - ASTM Hemolysis Direct/Indirect ContactMet acceptance criteria / Requirements for intended use fulfilled
    - Complement Activation, SC5b-9Met acceptance criteria / Requirements for intended use fulfilled
    - ThrombogenicityMet acceptance criteria / Requirements for intended use fulfilled
    - Platelet and Leucocyte CountsMet acceptance criteria / Requirements for intended use fulfilled
    - Partial Thromboplastin Time (PTT)Met acceptance criteria / Requirements for intended use fulfilled

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

    The document does not specify the precise sample sizes for each of the non-clinical performance or biocompatibility tests. These tests typically involve a defined number of devices or material samples as per the relevant ISO or ASTM standards.

    Regarding data provenance, the testing was conducted non-clinically and is typically performed at the manufacturer's facility or by a contract testing organization. The document refers to "protocols based on requirements outlined in guidances and industry standards," implying controlled laboratory settings. There is no mention of geographical data provenance for test sets (e.g., country of origin), as this is not a clinical study. The studies are prospective in the sense that they were designed and executed to specifically test the device for this submission.

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

    This question is not applicable as this is a 510(k) submission for a physical medical device (catheter introducer) and involves non-clinical performance and biocompatibility testing, not AI/imaging studies that require expert annotation for ground truth.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    This question is not applicable for the reasons stated above. Adjudication methods like 2+1 or 3+1 are used in clinical trials or imaging studies where human interpretation or consensus is required to establish ground truth or assess outcomes. These are not relevant for bench testing of physical device properties.

    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

    No, an MRMC comparative effectiveness study was not done. This type of study is specifically relevant for AI-powered diagnostic devices or imaging interpretation aids, which is not the case for the Scorpion Portal Vein Access Set. The device is a surgical access tool, not an AI or imaging product.

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

    No, a standalone algorithm performance study was not done. This device does not incorporate an AI algorithm.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    For the non-clinical performance and biocompatibility tests, the "ground truth" is established by the defined acceptance criteria within established industry standards (e.g., ISO, ASTM) and internal protocols. For example, a tensile strength test would have a specified minimum breaking strength required by the device's design specifications. Biocompatibility tests have specific endpoints and thresholds defined by ISO 10993 series standards. There is no expert consensus, pathology, or outcomes data used to establish ground truth as these are not clinical or diagnostic studies.

    8. The sample size for the training set

    This question is not applicable. This device is a physical medical device and does not involve AI algorithms that require a "training set."

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

    This question is not applicable for the reasons stated above.

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