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510(k) Data Aggregation

    K Number
    K180668
    Date Cleared
    2018-11-15

    (246 days)

    Product Code
    Regulation Number
    876.1075
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Single Use Aspiration Needle NA-U401SX-4025/NA-U401SX-4025N

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

    This instrument has been designed to be used with ultrasound endoscopes for ultrasound guided fine needle aspiration(FNA) of submucosal and extramural lesions of the gastrointestinal tract.

    Device Description

    The Single Use Aspiration Needle NA-U401SX-4025/NA-U401SX-4025N (aka ViziShot 2) is used in conjunction with Olympus ultrasound endoscopes for ultrasound guided fine needle aspiration (FNA). The subject devices consist of a handle section and insertion. The handle section is connected to the endoscope's instrument channel port via the single use adapter biopsy valve (MAJ-1414). The insertion section is composed of the sheath, needle and stylet. The needle tube is stored in the sheath and extended from the sheath to puncture the target tissue to collect specimen by moving the needle slider on the handle. A syringe is attached to the aspiration port on the handle section to aspirate the specimen. The needle is dimpled for echo enhancement. The subject devices will be sold with or without medallion syringe manufactured by Merit Medical, which consists of VACLOK Syringe and Stopcock.

    AI/ML Overview

    This is a submission for a medical device called the "Single Use Aspiration Needle NA-U401SX-4025/NA-U401SX-4025N". This document is a 510(k) summary, which means it's a premarket notification to the FDA to demonstrate that the device is substantially equivalent to a legally marketed predicate device.

    Here's an analysis of the provided information concerning acceptance criteria and the study that proves the device meets those criteria:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly provide a table of acceptance criteria with corresponding performance results for each criterion in a summarized format. Instead, it lists the types of performance data collected and states that these tests were conducted "to ensure that the subject devices perform as intended and meet design specifications." The overall conclusion is that the device "raise no new issue of safety and effectiveness and are substantially equivalent to the predicate device in terms of safety, efficacy and performance."

    Based on the "Performance testing - Bench" section, we can infer some of the areas where acceptance criteria would have been applied:

    Acceptance Criterion (Inferred from Test Conducted)Reported Device Performance (Implied from Summary)
    Inserting into endoscopePerformed as intended and met design specifications.
    Flexibility of the insertion portionPerformed as intended and met design specifications.
    Piercing capabilityPerformed as intended and met design specifications.
    Ultrasound visibilityPerformed as intended and met design specifications.
    Needle extraction and retractionPerformed as intended and met design specifications.
    Aspiration capabilityPerformed as intended and met design specifications.
    Withdrawal from endoscopePerformed as intended and met design specifications.
    Locking force of handle portionPerformed as intended and met design specifications.
    Limitation of needle depthPerformed as intended and met design specifications.
    Sterility (Sterilization/Shelf life testing)Met requirements in accordance with FDA Guidance and ASTM F1980-16. Real-time aging is ongoing.
    BiocompatibilityMet requirements in accordance with FDA Guidance and ISO 10993-1.
    Risk ManagementRisk analysis conducted, and design verification tests identified and performed according to ISO 14971:2007.

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

    The document does not specify the exact sample sizes for each of the performance tests (e.g., how many needles were tested for piercing or ultrasound visibility). It only states that tests were "conducted."

    The provenance of the data is in-house testing conducted by Olympus Medical Systems Corp. or its contractors. The studies appear to be bench tests and lab-based assessments (e.g., sterilization, biocompatibility, mechanical performance). There is no mention of human clinical data or patient data, so the concepts of "country of origin of the data," "retrospective or prospective," and "test set" in the context of clinical data do not apply here.

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

    Given that the performance data is entirely based on bench testing (mechanical, biocompatibility, sterilization), the concept of "experts establishing ground truth for a test set" in a clinical diagnostic sense (e.g., for image interpretation) is not applicable. The "ground truth" for these engineering tests would be established by validated test methods, reference standards, and established physical/chemical properties, rather than expert human interpretation.

    4. Adjudication Method for the Test Set

    As the performance data is derived from bench testing, an adjudication method like 2+1 or 3+1 (typically used for resolving discrepancies in expert interpretations of clinical data) is not relevant. The results of bench tests would be determined by objective measurements against predefined specifications.

    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 MRMC comparative effectiveness study was done. This device is a physical medical instrument (an aspiration needle) and does not involve AI or human interpretation in a diagnostic workflow where such a study would be applicable.

    6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done

    This device is not an algorithm or AI-based system, so a standalone performance study in that context is not applicable.

    7. The Type of Ground Truth Used

    The ground truth for the performance testing is based on:

    • Design Specifications: The device was tested to perform "as intended and meet design specifications."
    • International Standards: Compliance with standards like ISO 10993-1, ISO 14971, ASTM F1980-16, and various ISO standards for sterilization and packaging.
    • Validated Test Methods: The bench tests themselves would have employed validated methods to objectively measure parameters like flexibility, piercing force, aspiration volume, etc.

    8. The Sample Size for the Training Set

    This device does not utilize a "training set" in the context of machine learning or AI. The design and manufacturing processes are refined through engineering development and quality control, not through iterative training on a dataset.

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

    Since there is no training set in the AI sense, this question is not applicable.

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