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510(k) Data Aggregation

    K Number
    K170305
    Date Cleared
    2017-07-25

    (175 days)

    Product Code
    Regulation Number
    880.2500
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Spinal Manometer NRFit; Spinal Manometer LUER

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

    The Spinal Manometer NRFit/ Spinal Manometer LUER is intended to measure the pressure of the Cerebrospinal Fluid (CSF) during a lumbar puncture procedure.

    Device Description

    The Spinal Lumbar Puncture Manometer with either NRFit Connector according to ISO80369-6 or LUER-Connector according to ISO80369-7. The manometer is considered a Class II medical device as defined in 21 CFR §880.2500, product code FMJ. The device is a sterile finished disposable device, supplied sterile to the end user and non-sterile intended to be sterilized prior to use to repackagers/ medical device manufacturers. Materials: PVC, Polycarbonate, HDPE. No patient contact.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and the study information for the Spinal Manometer NRFit and Spinal Manometer LUER, based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria are primarily defined by adherence to recognized standards and internal protocols, with the reported performance being "Pass" for all tests.

    Acceptance Criteria / Test DetailStandard / ProtocolReported Device Performance
    SterilizationISO 11135Pass
    ResidualsISO 10993-7Pass
    BiocompatibilityISO 10993-1Pass (based on no patient contact & sterilization/residuals validation)
    Liquid Leakage (Luer)ISO 80369-7, 6.1Pass
    Air Leakage (Luer)ISO 80369-7, 6.2Pass
    Stress Cracking (Luer)ISO 80369-7, 6.3Pass
    Axial Load (Luer)ISO 80369-7, 6.4Pass
    Unscrewing torque (Luer)ISO 80369-7, 6.5Pass
    Overriding (Luer)ISO 80369-7, 6.6Pass
    Liquid Leakage (NRFit)ISO 80369-6, 6.1Pass
    Air Leakage (NRFit)ISO 80369-6, 6.2Pass
    Stress Cracking (NRFit)ISO 80369-6, 6.3Pass
    Axial Load (NRFit)ISO 80369-6, 6.4Pass
    Unscrewing torque (NRFit)ISO 80369-6, 6.5Pass
    Overriding (NRFit)ISO 80369-6, 6.6Pass
    Accuracy of MarkingsInternal protocolPass
    Durability of MarkingsInternal ProtocolPass
    Stability of Glue ConnectionInternal ProtocolPass
    Compatibility LUERInternal ProtocolPass
    Compatibility NRFitInternal ProtocolPass
    Batch Inspection reportInternal ProtocolPass
    Sterility Assurance Level (SAL)10^-6Met
    Ethylene Oxide (EtO) Residuals25 ppmMet
    Ethylene Chlorhydrine (ECH) Residuals25 ppmMet
    Pyroburden/Endotoxin0.06 EU/ml and 2.15 EU/deviceMet
    Shelf Life Performance5 yearsNo decrease in performance after real-time and accelerated aging

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

    The document does not explicitly state the specific number of devices or test samples used for each individual performance test (e.g., liquid leakage, axial load). It mentions:

    • Sterility tests: "performed using worst case devices already cleared for market and being packed in identical packaging (material and dimensions)."
    • Shelf-life performance: "tested with real time aged devices (1 year) and devices subject to accelerated aging (1 year, 3 years, 5 years)."

    The provenance of the data is internal testing conducted by PAJUNK® GmbH Medizintechnologie, located in Geisingen, Germany, and its contract sterilizer, Sterigenics Germany GmbH, located in Wiesbaden, Germany. All testing appears to be retrospective in the sense that it's performed on manufactured devices to demonstrate compliance, rather than a prospective clinical trial.

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

    This information is not provided in the document. The tests described are primarily engineering and laboratory-based performance tests against established international standards (ISO) and internal protocols. There is no mention of human expert evaluation to establish a "ground truth" in the clinical sense, as the device is for mechanical measurement and connectivity rather than diagnostic interpretation.

    4. Adjudication Method for the Test Set

    This is not applicable as the tests are objective, quantifiable physical and chemical performance metrics against defined standards, not subjective assessments requiring expert adjudication. The result for each test is a simple "Pass" or "Fail."

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

    No, an MRMC comparative effectiveness study was not done. This type of study is relevant for devices involving human interpretation of clinical data (e.g., AI in radiology). The Spinal Manometer is a physical device for measuring pressure, not an AI or diagnostic imaging tool.

    6. Standalone Performance (Algorithm Only Without Human-in-the-Loop Performance)

    Not applicable. This device is a physical medical instrument, not an algorithm or AI system. Therefore, the concept of "standalone performance" in the context of AI is not relevant. The device operates independently of human interpretation of its internal function; humans use it to observe a reading. All performance tests evaluated the device in its intended operational context without human interpretation being part of its core "performance" beyond reading the scale.

    7. The Type of Ground Truth Used

    The "ground truth" for the performance tests relies on:

    • International Standards: Adherence to ISO standards (e.g., ISO 11135, ISO 10993-7, ISO 80369-6, ISO 80369-7) defines acceptable physical and chemical properties.
    • Internal Protocols: For aspects not covered by specific ISO standards (e.g., Accuracy/Durability of Markings, Glue Connection Stability), internal, presumably validated, protocols establish the acceptance criteria.
    • Measurement against predefined limits: For sterilization residuals and endotoxin, specific quantitative limits (e.g., 25 ppm, 0.06 EU/ml) serve as the ground truth.

    8. The Sample Size for the Training Set

    There is no training set as this device is not an AI/machine learning product. The term "training set" doesn't apply.

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

    Since there is no training set, this question is not applicable.

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