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510(k) Data Aggregation

    K Number
    K171626
    Device Name
    truFreeze System
    Manufacturer
    Date Cleared
    2017-08-30

    (89 days)

    Product Code
    Regulation Number
    878.4350
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    truFreeze System

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

    The truFreeze System is intended for cryogenic destruction of tissue using Liquid Nitrogen spray that has a boiling point of -196℃ requiring either active or passive venting during surgical procedures.

    The truFreeze System is indicated for use as a cryosurgical tool in the fields of dermatology, gynecology, and general surgery, to ablate benign (eg. Barrett's Esophagus with high grade and/or low grade dysplasia) and malignant lesions.

    Device Description

    The truFreeze system is a cryosurgical tool that applies medical-grade liquid nitrogen to the ablation area via a small, low pressure, open tipped catheter. The truFreeze System consists of a console and a disposable spray kit.

    AI/ML Overview

    I am sorry, but the provided text does not contain information about acceptance criteria or a study proving a device meets them in the context of an Artificial Intelligence (AI) or machine learning (ML) device. The document describes a 510(k) premarket notification for the "truFreeze® System," which is a cryosurgical tool.

    The document discusses:

    • The indications for use for the truFreeze system, including the addition of Barrett's Esophagus with low-grade dysplasia.
    • A clinical study conducted to support the effectiveness and safety of the truFreeze system for ablating Barrett's Esophagus with low-grade dysplasia. This is a study of a physical medical device, not an AI/ML algorithm.
    • Data on the safety and effectiveness of the device, focusing on patient response (complete eradication of dysplasia - CE-D) and adverse events.
    • Comparison to predicate and reference devices to establish substantial equivalence.

    Therefore, I cannot extract the information required for the requested table and study details related to an AI/ML device's acceptance criteria and performance as the provided document does not pertain to such a device.

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    K Number
    K172041
    Device Name
    truFreeze System
    Manufacturer
    Date Cleared
    2017-07-27

    (21 days)

    Product Code
    Regulation Number
    878.4350
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    truFreeze System

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

    The truFreeze System is indicated for use as a cryosurgical tool in the fields of dermatology, gynecology, and general surgery, to ablate benign (eg. Barrett's Esophagus with high grade dysplasia) and malignant lesions.

    Device Description

    The truFreeze System is a cryosurgical tool that applies medical-grade liquid nitrogen to the ablation area via a small, low pressure, open tipped catheter. The truFreeze System consists of a console and a disposable spray kit.

    Console:
    The console is the central interface of the system and is comprised of a touch panel computer (TPC) and cryogen, suction, and electronics modules packaged in a mobile cart. Users interact with the console through a dual foot pedal and a touch panel. An off-the-shelf controller and associated software manage the cryogen level sensing, filling, pressure, cooling, defrost, suction, timing and data management functions. A fill kit, stored on the rear of the console, allows for liquid nitrogen transfer from the source tank to the console. Safety features include indicators, tank pressure relief valves, an isolated low voltage power system, and an emergency button to be used in the event of user or technical malfunction.

    Disposable Spray Kits:
    Currently, there are 2 types of spray kits available. One kit is available for active venting procedures and one kit is available for passive venting procedures. Both active and passive venting kits are provided in a carton of five (5) sterile, single-use catheters with introducers in individual pouches. Additionally, the active venting kit includes a carton of five (5) sterile, single-use, dual-lumen Active Venting Cryo Decompression Tubes (CDTs) with associated tubing in individual pouches. Each carton within a spray kit contains Instructions for Use.

    CryoDecrompression Tube (CDT):
    Proposed changes involve the CryoDecrompression Tube (CDT) only. The CDT is a necessary part of the truFreeze Active Venting Kit to suction gas out of the patient when liquid nitrogen is sprayed.

    AI/ML Overview

    The document provided describes modifications to the truFreeze System, specifically to the CryoDecompression Tube (CDT). The purpose of these modifications is to address user annoyance related to tube kinking and an orange indicator display during use, without changing the intended use or indications for use of the device.

    Here's an analysis of the acceptance criteria and study information based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    Specification Test associated with proposed modificationsAcceptance Criteria (Implicit)Reported Device Performance (Result)
    Measure the maximum OD of the CDTOD
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    K Number
    K163244
    Device Name
    truFreeze System
    Manufacturer
    Date Cleared
    2017-05-24

    (187 days)

    Product Code
    Regulation Number
    878.4350
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    truFreeze System

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

    The truFreeze System is indicated for use as a cryosurgical tool in the fields of dermatology, gynecology, and general surgery, to ablate benign (e.g. Barrett's Esophagus with high grade dysplasia) and malignant lesions.

    Device Description

    The truFreeze system is a cryosurgical tool that applies medical-grade liquid nitrogen to the ablation area via a small, low pressure, open tipped catheter. The truFreeze System consists of a console and a disposable spray kit.

    Console:
    The console is the central interface of the system and is comprised of a touch panel computer (TPC) and cryogen, suction, and electronics modules packaged in a mobile cart. Users interact with the console through a dual foot pedal and a touch panel. An off-the-shelf controller and associated software manage the cryogen level sensing, filling, pressure, cooling, defrost, suction, timing and data management functions. A fill kit, stored on the rear of the console, allows for liquid nitrogen transfer from the source tank to the console. Safety features include indicators, tank pressure relief valves, an isolated low voltage power system, and an emergency button to be used in the event of user or technical malfunction. The console is the same as previously cleared for the predicate truFreeze System (K162695). Therefore, there are no new issues of safety or effectiveness raised.

    Disposable spray kit:
    There are 2 types of spray kits available. One kit is available for active venting procedures and one is available for passive venting procedures. Both active and passive venting kits are provided in a carton of five (5) individually packaged sterile, single-use catheters with introducers in individual pouches. Additionally, the active venting kit is provided with includes a carton of five (5) individually packaged sterile, single-use CDTs with associated tubing in individual pouches. Each carton within a spray kit contains the instructions for use. The disposable kit is the same as previously cleared for the predicate truFreeze System (K162695). Therefore, there are no new issues of safety or effectiveness raised.

    AI/ML Overview

    Although the provided text heavily details the device and its testing, it does not contain acceptance criteria in the format of a table with specific metrics and thresholds. Instead, it presents a clinical study's results with the claim of "substantial equivalence" to predicate devices. Therefore, I cannot construct the requested table of acceptance criteria and reported device performance directly from the text.

    However, I can extract and structure all other requested information about the study that proves the device meets its expanded indications.

    Here's an analysis of the provided text, addressing your points:


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

    The document does not provide a table of pre-defined acceptance criteria with specific numerical thresholds. It relies on a "substantial equivalence" argument, comparing the device's performance (safety and efficacy) to existing predicate devices and literature.

    Implicit "Performance Metrics" and Reported Performance (derived from results):

    Performance Metric (Derived)Reported Device Performance (truFreeze System, BE-HGD Efficacy Population)
    Efficacy: Complete Eradication of Dysplasia (CE-D)87.0% (40 out of 46 CE-D patients)
    Safety: Stricture Rate (per patient)2.7% (3 out of 111 safe population patients)
    Safety: Pancreatitis Rate (per patient)0.9% (1 out of 111 safe population patients)
    Safety: Procedure-Related Stricture Rate (per procedure session)1.2% (3 out of 258 safe population procedures)
    Safety: Procedure-Related Pancreatitis Rate (per procedure session)0.4% (1 out of 258 safe population procedures)

    Note on "Acceptance Criteria": The concluding statement in the "Discussion" section mentions: "This success rate is comparable to the success rate for the Barrx System and the Coldplay CryoBalloon™ Focal Ablation System among all phenotypes of BE patients, ranging from no dysplasia to early adenocarcinoma and across 3 different ablation doses." This suggests that the "acceptance criterion" was achieving a comparative efficacy and safety profile to these established devices, rather than a fixed numerical threshold.


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

    • Test Set (Clinical Study Population):
      • Safety Population: 111 patients
      • Efficacy Population: 46 patients (a subset of the safety population, meeting specific inclusion/exclusion criteria for BE-HGD)
    • Data Provenance:
      • Country of Origin: Not explicitly stated, but the FDA submission suggests it's likely a US-based study given the regulatory context.
      • Retrospective or Prospective: "This post-marketing registry prospectively collected data on patients treated with the FDA-cleared cryotherapy device (truFreeze® System)." So, it was prospective.

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

    The document does not specify the number or qualifications of experts used to establish the ground truth (e.g., histology results for Barrett's Esophagus with high-grade dysplasia). It merely states that there were "pre-therapy and post-therapy histology."


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

    The document does not specify any adjudication method for the test set's ground truth assessment.


    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

    This section is not applicable. The device is a cryosurgical tool, not an AI-powered diagnostic or assistive tool for human readers. Therefore, an MRMC study related to human reader improvement with AI assistance was not conducted.


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

    This section is not applicable. The device is a physical surgical intervention tool, not an algorithm. Its performance is measured by clinical outcomes (ability to ablate lesions, safety profile), not by an algorithm's standalone performance.


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

    The primary ground truth for efficacy was established through histology (pathology): "Patients without a pre-therapy and post-therapy histology" was an exclusion criterion for the efficacy population. The outcome measured was "Complete Eradication of Dysplasia (CE-D)," which relies on pathological confirmation.


    8. The sample size for the training set

    This section is not applicable. The truFreeze System is a cryosurgical device, not a machine learning algorithm that requires a "training set." The clinical data presented is for validation of its expanded indications.


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

    This section is not applicable as there was no "training set" for an algorithm.

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    K Number
    K162695
    Device Name
    truFreeze System
    Manufacturer
    Date Cleared
    2016-10-25

    (28 days)

    Product Code
    Regulation Number
    878.4350
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    truFreeze System

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

    Intended Use: The truFreeze System is intended for cryogenic destruction of tissue using Liquid Nitrogen spray that has a boiling point of -196ºC requiring either active or passive venting during surgical procedures.

    Indications for Use: The truFreeze System is indicated for use as a cryosurgical tool in the fields of dermatology, gynecology, and general surgery, to ablate benign and malignant lesions.

    Device Description

    The truFreeze system is a cryosurgical tool that applies medical-grade liquid nitrogen to the ablation area via a small, low pressure, open tipped catheter. The truFreeze System consists of a console and a disposable spray kit.

    Console: The console is the central interface of the system and is comprised of a touch panel computer (TPC) and cryogen, suction, and electronics modules packaged in a mobile cart. Users interact with the console through a dual foot pedal and a touch panel. An off-the-shelf controller and associated software manage the cryogen level sensing, filling, pressure, cooling, defrost, suction, timing and data management functions. A fill kit, stored on the rear of the console, allows for liquid nitrogen transfer from the source tank to the console. Safety features include indicators, tank pressure relief valves, an isolated low voltage power system, and an emergency stop button to be used in the event of user or technical malfunction.

    Disposable spray kit: There are 2 types of spray kits available. One kit is available for active venting procedures and one is available for passive venting procedures. Both active and passive venting kits are provided in a carton of five (5) individually packaged sterile, single-use catheters with introducers in individual pouches. Additionally, the active venting kit is provided with a carton of five (5) individually packaged sterile. single-use CDTs with associated tubing in individual pouches. Each carton within a spray kit contains the instructions for use. There is a proposed change to the active venting disposable spray kit. The proposed change reduces the Outside Diameter (OD) of the CDT from 20 French to 16 French without changing performance specifications, adds additional Marker Bands to the 16 French version of the CDT and makes the 16 Fr CDT and 20 Fr CDT available as a 5-pack box in addition to as a part of the active venting kit.

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for the truFreeze System, focusing on minor modifications to an already cleared device. Therefore, a full-scale clinical study with extensive acceptance criteria, ground truth establishment, and multi-reader comparative effectiveness studies as typically seen for novel diagnostic AI devices, is not applicable here.

    Instead, the submission details a verification and validation process for specific physical changes to a component of the device (the Cryoablation Drug Delivery Tube, CDT). The "acceptance criteria" are essentially the performance specifications for these modified components.

    Here's an analysis based on the provided text, structured to address your points where applicable, and noting when information is not present due to the nature of this submission:

    Acceptance Criteria and Device Performance

    The acceptance criteria are the "Test Specifications" and the "Reported Device Performance" is the "Result" column.

    Proposed ChangeAcceptance Criteria (Test Specification)Reported Device Performance (Result)
    Reduce CDT ODThe CDT shall be less than or equal to 16.5 FrPass
    The CDT shall not crack, break or experience lumen separation after exposure to temperatures with the boundary range of - 196°C and 40°C.Pass
    Shall have sufficient column strength to allow it to be advanced over a 0.072” Savary WirePass
    Shall maintain structural integrity and not kink while looped in a minimum internal bend radius.Pass
    A complete flex of the CDT shall meet current kinking specification.Pass
    The bonded CDT connector will withstand a minimum of 10lbf pull force without failing.Pass
    Flow Rate shall meet current specification.Pass
    The CDT OD shall not deform per specification.Pass
    The bonded CDT connector will shall meet current. pull force specification without failing.Pass
    Enhance VisualizationCircumferential banding must be sufficient to identify the banding through an endoscope.Pass
    Shall be labeled with four side-by-side 0.100"±0.030" wide identifying bands 7.7" ±0.1" from the distal end.Pass
    All 0.100" wide bands shall be 360 degrees.Pass
    Reduce CDT OD (DV)CDT diameter will be as small as possible while enabling gas egress and allowing it to pass through the majority of anatomies with and without dilation.Pass
    Enhance Visualization (DV)CDT will have Mark Bands to assist user for performing the initial, approximate placement of the CDT.Pass

    Note: (DV) indicates Design Validation Testing.


    Study Details Addressing Your Points:

    2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    • The document does not specify the sample sizes (e.g., number of CDTs tested) for the individual mechanical and material tests. These are typically internal verification tests.
    • For the Design Validation tests:
      • User Survey / Simulated Use (PRO-R-17-00193): The sample size for the user survey/simulated use is not explicitly stated. It would likely involve a small number of users.
      • Animal Study (PRO-R-17-00198): The sample size (number of animals) for the animal study is not explicitly stated.
    • Data provenance (country of origin, retrospective/prospective) is not mentioned, as these are internal design control activities for a physical device modification.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

    • For the physical and functional tests, "ground truth" is established through engineering and material science standards and measurements. There are no "experts" in the sense of medical professionals establishing ground truth for diagnostic accuracy here.
    • For the "User Survey / Simulated Use" and "Animal Study," the "experts" would be the participants in the survey/study and the veterinarians/surgeons conducting the animal procedures. Their number and specific qualifications are not detailed in this summary.

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

    • Adjudication methods like 2+1 or 3+1 are typically used for establishing ground truth in diagnostic accuracy studies where there's subjectivity (e.g., interpreting medical images). This is not applicable here as the tests are for physical and functional properties of a medical device component. The "pass" results imply that the device met the predefined specifications, which is a form of objective assessment.

    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 relevant for evaluating the impact of an AI algorithm on human reader performance, typically in diagnostic imaging. The truFreeze System is a cryosurgical tool, and this submission concerns a minor physical modification to an existing component, not an AI diagnostic algorithm.

    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 is a physical cryosurgical system and does not involve a standalone algorithm for diagnostic or prognostic purposes.

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

    • The ground truth for the physical and functional tests is based on engineering specifications, material science properties, and direct objective measurements.
    • For the "User Survey / Simulated Use," the ground truth would be the subjective feedback and observed performance from the users.
    • For the "Animal Study," the ground truth would be the physiological outcomes and observations documented during and after the animal procedures.
    • None of these involve pathology or long-term outcomes data related to disease diagnosis, as the device is a therapeutic (surgical) tool.

    8. The sample size for the training set

    • There is no training set in the context of this 510(k) submission. Training sets are used for machine learning algorithms. This submission is for a physical medical device.

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

    • Not applicable, as there is no training set.
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    K Number
    K161557
    Device Name
    truFreeze System
    Manufacturer
    Date Cleared
    2016-07-26

    (50 days)

    Product Code
    Regulation Number
    878.4350
    Reference & Predicate Devices
    N/A
    Why did this record match?
    Device Name :

    truFreeze System

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

    Intended Use: The truFreeze System is intended for cryogenic destruction of tissue using Liquid Nitrogen spray that has a boiling point of -196ºC requiring either active or passive venting during surgical procedures.

    Indications for Use: The truFreeze System is indicated for use as a cryosurgical tool in the fields of dermatology, and general surgery, to ablate benign and malignant lesions.

    Device Description

    The truFreeze system is a cryosurgical tool that applies medical-grade liquid nitrogen to the ablation area via a small, low pressure, open tipped catheter. The truFreeze System consists of a console and a disposable spray kit.

    Console: The console is the central interface of the system and is comprised of a touch panel computer (TPC) and cryogen, suction, and electronics modules packaged in a mobile cart. Users interact with the console through a dual foot pedal and a touch panel. An off-the-shelf controller and associated software manage the cryogen level sensing, filling, pressure, cooling, defrost, suction, timing and data management functions. A fill kit, stored on the rear of the console, allows for liquid nitrogen transfer from the source tank to the console. Safety features include indicators, tank pressure relief valves, an isolated low voltage power system, and an emergency button to be used in the event of user or technical malfunction.

    Disposable spray kit: There are 2 types of spray kits available. One kit is available for active venting procedures and one is available for passive venting procedures. Both active and passive venting kits include are provided in a carton of five (5) individually packaged sterile, single-use catheters with introducers in individual pouches. Additionally, the active venting kit is provided with includes a carton of five (5) individually packaged sterile, single-use CDTs with associated tubing in individual pouches. Each carton within a spray kit contains the instructions for use.

    AI/ML Overview

    This document describes a 510(k) premarket notification for the truFreeze® System (K161557), which is a cryosurgical unit. The submission focuses on modifications to the predicate device (K160273) and assesses if these changes introduce new questions of safety or effectiveness. The core of the evaluation is demonstrating that the modified device remains substantially equivalent to its predicate.

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

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

    The document doesn't explicitly state "acceptance criteria" in a quantitative manner for specific performance metrics like accuracy, sensitivity, or specificity. Instead, the acceptance criteria are implicitly defined as successful completion of various verification and validation tests, ensuring that the software and hardware modifications do not negatively impact the code, system performance, or functionality, and do not raise new questions of safety or effectiveness.

    The "Verification Testing Summary Table" provides a good overview of the tests performed and their outcomes:

    Test TypeProposed truFreeze System PerformancePredicate truFreeze System (K150920) PerformanceComments
    Software Regression Tests
    - BIT CodePassPassEquivalent
    - Fill CodePassPassEquivalent
    - Procedure CodePassPassEquivalent
    - Data CodePassPassEquivalent
    - Service CodePassPassEquivalent
    - Admin CodePassPassEquivalent
    - Home CodePassPassEquivalent
    Software Integration Tests
    - Fill CodePassNAThe integration tests were specific to the proposed modifications and therefore it was not part of K150920
    - Procedure CodePassNAThe integration tests were specific to the proposed modifications and therefore it was not part of K150920
    System Functional Tests
    - truFreeze Field VerificationPassPassEquivalent
    Hardware Stress Tests
    - Simulated Shock and RotationPassNAThe simulated shock and rotation methods were not part of K150920 testing.

    Reported Device Performance Summary: All tests, including software regression, software integration, system functional, and hardware stress tests, were successfully completed with a "Pass" result for the proposed truFreeze System, demonstrating that the modifications did not negatively affect the device's safety or functionality.

    2. Sample size used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective):

    • Software Testing:
      • Regression Tests: The document states that "Regression testing was successfully completed and all tests passed," implying 100% pass rate for the tested code components (BIT, Fill, Procedure, Data, Service, Admin, Home Codes). The exact number of individual test cases within these categories is not specified.
      • Integration Tests: "All integration tests were completed and were considered acceptable." Again, the specific number of test cases or scenarios is not provided.
      • Unit Tests: "Unittests were used to verify the BIT and code revision updates... only one run on one console is required for this testing." This indicates a single run for these specific unit tests.
    • Hardware and System Functional Testing:
      • Hardware Stress Testing: "Three production equivalent systems underwent stress testing."
      • System Functional Tests: "System functional testing was performed on three production consoles."
    • Data Provenance: The testing appears to be internal to CSA Medical, Inc. or its contractors. No information is provided about the country of origin of data, or whether it was retrospective or prospective in the sense of patient data. This is a simulated/laboratory testing environment, not clinical data provenance.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g., radiologist with 10 years of experience):

    This type of information is not applicable to the testing described in this document. The truFreeze® System is a cryosurgical tool, and the testing outlined is focused on verifying software and hardware functionality and safety of modifications, not diagnostic accuracy requiring expert panel review. The "ground truth" for these tests would be the expected behavior of the system as defined by its design specifications.

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

    This is not applicable as the testing primarily involves automated software verification, hardware stress tests, and functional checks against predetermined specifications, not subjective interpretation of results by multiple human adjudicators. The evaluation outcome (Pass/Fail) is based on objective criteria related to system performance and behavior.

    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:

    This is not applicable. The truFreeze® System is a physical medical device (cryosurgical unit) and its modifications are for internal system functionality, not an AI-powered diagnostic or assistive tool for human readers (e.g., radiologists interpreting images). Therefore, an MRMC study or assessment of AI assistance effect size is irrelevant here.

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

    This is not applicable in the context of an "algorithm only" performance as it relates to AI/diagnostic algorithms. The device itself is a standalone system with specific functionalities, and the testing implicitly evaluates its standalone performance relative to its design specifications. However, this is not a device whose performance would be measured in terms of classification, detection, etc., like an AI algorithm.

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

    The "ground truth" for the tests described is the expected behavior and performance of the device's software and hardware as defined by its design specifications and requirements. For example:

    • For software regression, the ground truth is that the updated code should produce the same correct output as the previous version for existing functionalities.
    • For integration tests, the ground truth is that the software should correctly detect errors and display messages as designed.
    • For hardware stress tests, the ground truth is that the hardware modifications should withstand simulated stress without failure.

    8. The sample size for the training set:

    This is not applicable. The document describes verification and validation of modifications to a physical medical device and its embedded software, not the development or training of a machine learning or AI model. Therefore, there is no "training set" in this context.

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

    This is not applicable as there is no training set for an AI model. The ground truth for the testing was established through design specifications and requirements for the device's intended functionality and safety.

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    K Number
    K160273
    Device Name
    truFreeze System
    Manufacturer
    Date Cleared
    2016-03-25

    (52 days)

    Product Code
    Regulation Number
    878.4350
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    truFreeze System

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

    Intended Use: The truFreeze System is intended for cryogenic destruction of tissue using Liquid Nitrogen spray that has a boiling point of -196 C requiring either active or passive venting during surgical procedures.

    Indications for Use: The truFreeze System is indicated for use as a cryosurgical tool in the fields of dermatology, gynecology, and general surgery, to ablate benign and malignant lesions.

    Device Description

    The truFreeze system is a cryosurgical tool that applies medical-grade liquid nitrogen to the ablation area via a small, low pressure, open tipped catheter. The truFreeze System consists of a console and a disposable spray kit.

    Console: The console is the central interface of the system and is comprised of a touch panel computer (TPC) and cryogen, suction, and electronics modules packaged in a mobile cart. Users interact with the console through a dual foot pedal and a touch panel. An off-the-shelf controller and associated software manage the cryogen level sensing, filling, pressure, cooling, defrost, suction, timing and data management functions. A fill kit, stored on the rear of the console, allows for liquid nitrogen transfer from the source tank to the console. Safety features include indicators, tank pressure relief valves, an isolated low voltage power system, and an emergency button to be used in the event of user or technical malfunction.

    Disposable spray kit: There are 2 types of spray kits available. One kit is available for active venting procedures and one is available for passive venting procedures. Both active and passive venting kits include are provided in a carton of five (5) individually packaged sterile, single-use catheters with introducers in individual pouches. Additionally, the active venting kit is provided with includes a carton of five (5) individually packaged sterile, single-use CDTs with associated tubing in individual pouches. Each carton within a spray kit contains the instructions for use.

    AI/ML Overview

    The provided text is a 510(k) summary for the truFreeze System, a cryosurgical tool. It describes the device, its intended use and indications for use, and a comparison to a predicate device (K152668).

    However, the document explicitly states: "Since the change in the truFreeze System is limited to the Indications for Use and adds to it information currently present in truFreeze System labeling, no additional testing was performed."

    This indicates that no new study was conducted specifically for this 510(k) submission (K160273) to establish new acceptance criteria or prove device performance for new claims. The submission relies on the substantial equivalence to a previously cleared device (K152668) and its existing testing.

    Therefore, I cannot provide the requested information regarding acceptance criteria and a study proving the device meets them from this document, because this document states no new studies were performed.

    If information from the previous 510(k) submission (K152668) were available, it might contain the details of studies that established performance for the original truFreeze System. Without that context, I can only report what is stated in this document.

    Based on the provided text, the following points can be made:

    • 1. A table of acceptance criteria and the reported device performance: Not available in this document as no new testing was performed. The device is deemed substantially equivalent based on label and technology comparison to a predicate device.
    • 2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective): Not available as no new testing was performed.
    • 3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience): Not available as no new testing was performed.
    • 4. Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not available as no new testing was performed.
    • 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. The truFreeze System is a cryosurgical tool, not an AI-assisted diagnostic or imaging device used by human readers. No MRMC study was mentioned.
    • 6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable. The truFreeze System is a physical surgical device, not an algorithm.
    • 7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.): Not available as no new testing was performed.
    • 8. The sample size for the training set: Not applicable as a training set for an algorithm is not relevant to this type of device and no new testing was performed.
    • 9. How the ground truth for the training set was established: Not applicable.
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    K Number
    K152668
    Device Name
    truFreeze System
    Manufacturer
    Date Cleared
    2015-10-14

    (27 days)

    Product Code
    Regulation Number
    878.4350
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    truFreeze System

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

    The truFreeze® System is intended for cryogenic destruction of tissue requiring either active or passive venting during surgical procedures.

    The truFreeze® System is Indicated for use as a cryosurgical tool in the fields of dermatology, gynecology, and general surgery, to ablate benign and malignant lesions.

    Device Description

    The truFreeze system is a cryosurgical tool that applies medical-grade liquid nitrogen to the treatment area via a small, low pressure, open tipped catheter. The truFreeze System consists of a console and a disposable spray kit.

    Console:
    The console is the central interface of the system and is comprised of a touch panel computer (TPC) and cryogen, suction, and electronics modules packaged in a mobile cart. Users interact with the console through a dual foot pedal and a touch panel. An off-the-shelf controller and associated software manage the cryogen level sensing, filling, pressure, cooling, defrost, suction, timing and data management functions. A wireless remote control provides alternative timer control from a distance in the treatment room. A fill kit, stored on the rear of the console, allows for liquid nitrogen transfer from the source tank to the console. Safety features include indicators, tank pressure relief valves, an isolated low voltage power system, and an emergency button to be used in the event of user or technical malfunction.

    Disposable spray kit:
    There are no proposed changes to the disposable spray kit. There are 2 types of spray kits available. One kit is available for active venting procedures and one is available for passive venting procedures. Both active and passive venting kits include are provided in a carton of five (5) individually packaged sterile, single-use catheters with introducers in individual pouches. Additionally, the active venting kit is provided with includes a carton of five (5) individually packaged sterile, single-use CDTs with associated tubing in individual pouches. Each carton within a spray kit contains the instructions for use.

    AI/ML Overview

    This document describes the 510(k) premarket notification for the truFreeze® System. The information provided heavily focuses on the mechanical modifications and testing rather than clinical performance for diagnostic or prognostic purposes, which the requested questions seem to imply.

    Based on the provided text, the device is a cryosurgical unit, not an AI-based diagnostic tool. Therefore, many of the requested elements (like MRMC studies, training sets, ground truth establishment by experts, etc.) are not applicable or described in this type of submission.

    Here's an attempt to answer the questions based only on the provided text, highlighting where information is not present or not relevant to this type of device and submission.


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

    Acceptance CriteriaReported Device Performance
    No leaking observedNo leaking observed for all tested samples

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

    • Test Set Sample Size: 4 samples of the Transfer Interface Assembly (2 at the low end of the depth specification, 2 at the high end of the depth specification). Each sample was subjected to 6 fill cycles for a total of 24 trials.
    • Data Provenance: Not specified, but implied to be internal verification testing conducted by CSA Medical. No country of origin or retrospective/prospective nature is mentioned, but it's part of device verification.

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

    • Not applicable/Not provided. The ground truth here is a physical characteristic (absence of leaking) observable during mechanical testing, not a clinical diagnosis or interpretation requiring expert consensus.

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

    • Not applicable/Not provided. Adjudication methods are typically for subjective assessments (e.g., image interpretation), whereas this test is for a directly observable physical failure (leaking).

    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 is a cryosurgical unit, not an AI-assisted diagnostic device for human readers.

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

    • Not applicable. This device is a cryosurgical unit, not an algorithm.

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

    • The "ground truth" for this engineering test was the direct observation of "no leaking" during multiple fill cycles, which is a physical performance characteristic of the device's redesigned components.

    8. The sample size for the training set

    • Not applicable. This is a mechanical device, not an AI model that requires a training set. The descriptions are for modifications to existing hardware components.

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

    • Not applicable. No training set for an AI model is described.
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    K Number
    K150920
    Device Name
    truFreeze System
    Manufacturer
    Date Cleared
    2015-06-17

    (72 days)

    Product Code
    Regulation Number
    878.4350
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    truFreeze System

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

    The truFreeze® System is intended for cryogenic destruction of tissue requiring either active or passive venting during surgical procedures.

    The truFreeze® System is Indicated for use as a cryosurgical tool in the fields of dermatology, gynecology, and general surgery, to ablate benign and malignant

    Device Description

    The truFreeze system is a cryosurgical tool that applies medical-grade liquid nitrogen to the treatment area via a small, low pressure, open tipped catheter. The truFreeze System consists of a console and a disposable spray kit.

    Console:
    The console is the central interface of the system and is comprised of a touch panel computer (TPC) and cryogen, suction, and electronics modules packaged in a mobile cart, Users interact with the console through a dual foot pedal and a touch panel. An off-the-shelf controller and associated software manage the cryogen level sensing, filling, pressure, cooling, defrost, suction, timing and data management functions. A wireless remote control provides alternative timer control from a distance in the treatment room. A fill kit, stored on the rear of the console, allows for liquid nitrogen transfer from the source tank to the console. Safety features include indicators, tank pressure relief valves, an isolated low voltage power system, and an emergency button to be used in the event of user or technical malfunction.

    Disposable spray kit:
    There are no proposed changes to the disposable spray kit. The truFreeze disposable spray kit continues to consist of five (5) individually packaged sterile single-use catheters (7 Fr Straight Tip Catheter and one Catheter Introducer) and 5 individually packaged cryogen decompression tubes (CDTs) (each containing one Dual Lumen 20 Fr CryoDecompression Tube (CDT), Connector, and Suction Tubing). The catheter is flexible and capable of retroflex in a scope. The CDT and accessory tubes are included for use with the onboard suction system.

    AI/ML Overview

    The provided document describes a 510(k) premarket notification for a medical device called the truFreeze® System (K150920). This submission is for a software modification to an existing device (K143625). The document focuses on demonstrating that the updated device is substantially equivalent to its predicate.

    Here's an analysis based on your request, extracting the available information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly state "acceptance criteria" in a quantitative manner (e.g., minimum sensitivity or specificity). Instead, it describes various tests performed to ensure the software modification did not negatively impact the device and added new safety features. The "acceptance criteria" can be inferred as successful completion of these tests without introducing new safety or performance concerns.

    Test TypeAcceptance Criteria (Inferred from study description)Reported Device Performance
    Software Regression TestsNo negative impact on existing code functionality. All previous functionalities maintained.All tests passed, verifying that updates did not negatively impact the code. No additional safety or functionality concerns were observed.
    Software Integration TestsAbility of the software to correctly detect and respond to cDAQ related hardware and communication errors.All integration tests completed and considered acceptable. Demonstrated ability to correctly detect (or not) cDAQ related hardware and communication errors and respond accordingly.
    System Functional TestsNo negative impact on system performance and functionality. System functions as intended per software specifications.All tests successfully performed and passed. Confirmed software updates did not negatively impact system performance and functionality.
    Specific Software FunctionsSoftware functions as intended per software performance specifications. All input and output software values are as specified. System functions as intended. Software functions as intended when a cDAQ hardware error is present or not present.All items successfully verified and validated.

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

    The document states:

    • "Two sets of testing were performed for each of the load packages available to customers."
    • "Three consoles were successfully loaded with the respective load packages."

    This implies a very small sample size for the "test set" (e.g., 3 consoles). The data provenance is prospective in the sense that the testing was conducted specifically for this 510(k) submission on the modified device. The country of origin of the data is not explicitly stated, but the company is based in Lexington, Massachusetts, USA.

    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 testing described is primarily focused on software and system functionality, not on diagnostic accuracy requiring expert interpretation of clinical data.

    4. Adjudication Method for the Test Set

    This information is not provided and is not relevant for the type of software/system functional testing described. The "ground truth" for these tests would be the expected software behavior and system response to various inputs and error conditions.

    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. The device is a cryosurgical tool, and the submission concerns a software update to improve safety by detecting communication errors, not an AI-assisted diagnostic or interpretive tool that would involve human readers.

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

    This is a standalone assessment of the software's functionality and its impact on the system. The "algorithm" (software control) was tested for its ability to detect and respond to communication interruptions. The performance is assessed without a human-in-the-loop in the context of the software's detection capability. However, the overall device (truFreeze® System) is a tool used by a clinician, so there is always a human-in-the-loop for its clinical application.

    7. The Type of Ground Truth Used

    The ground truth used for the software and system testing was based on:

    • Software performance specifications: The expected design and functionality of the software.
    • Intended system behavior: How the system is designed to operate, especially its response to error conditions (e.g., closing valves upon error detection).
    • Predicate device's established performance: Ensuring the modified device maintained equivalence to the predicate for unchanged aspects.

    It is not expert consensus, pathology, or outcomes data, as these are not relevant to the described software modification.

    8. The Sample Size for the Training Set

    The document describes software updates and validation, not a machine learning model that requires a "training set." Therefore, a training set sample size is not applicable.

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

    As there is no training set for a machine learning model, this question is not applicable. The "ground truth" for the software development and testing was established through engineering specifications and design requirements.

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    K Number
    K143625
    Device Name
    truFreeze System
    Manufacturer
    Date Cleared
    2015-01-15

    (24 days)

    Product Code
    Regulation Number
    878.4350
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    truFreeze System

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

    The truFreeze® System is intended for cryogenic destruction of tissue requiring either active or passive venting during surgical procedures.

    The truFreeze® System is Indicated for use as a cryosurgical tool in the fields of dermatology, gynecology, and general surgery, to ablate benign and malignant lesions.

    Device Description

    The truFreeze system is a cryosurgical tool that applies medical-grade liquid nitrogen to the treatment area via a small, low pressure, open tipped catheter. The truFreeze System consists of (1) a console and (2) a disposable spray kit.

    Console:
    The console is the central interface of the system and is comprised of a touch panel computer (TPC) and cryogen, suction and electronics modules packaged in a mobile cart. Users interact with the console through a dual foot pedal and a touch panel. An off-the-shelf controller and associated software manage the cryogen level sensing. filling, pressure. cooling, defrost, suction, timing and data management functions. A wireless remote control provides alternative timer control from a distance in the treatment room. A fill kit, stored on the rear of the console, allows for liquid nitrogen transfer from the source tank to the console. Safety features include indicators, tank pressure relief valves, an isolated low voltage power system, and an emergency button to be used in the event of user or technical malfunction.

    Disposable spray kit:
    The truFreeze disposable spray kit consists of 5 individually packaged sterile single-use catheters (7 Fr Straight Tip Catheter and one Catheter Introducer.) and 5 individually packaged cryogen decompression tubes (CDTs) (each containing one Dual Lumen 20 Fr CryoDecompression Tube (CDT), Connector, and Suction Tubing.). The catheter is flexible and capable of retroflex in a scope. The CDT and accessory tubes are included for use with the on-board suction system.

    AI/ML Overview

    I am sorry, but the provided text does not contain information about acceptance criteria or a study proving the device meets acceptance criteria as typically understood for AI/ML medical devices. The document is a 510(k) premarket notification for a cryosurgical unit, which is a hardware device, not an AI/ML diagnostic or prognostic tool.

    The text does mention "Testing" but states: "The truFreeze System was previously subjected to a comprehensive test program that included electrical safety and electromagnetic compatibility testing, software testing, animal testing, biocompatibility and sterilization testing. Since the change does not involve any changes to the hardware or software of the truFreeze system, no additional testing was conducted to support demonstration of substantial equivalence in performance of the truFreeze system to its predicate device."

    This indicates that the document is focused on demonstrating substantial equivalence to a predicate device based on minor labeling changes, not on establishing performance criteria for a new AI/ML algorithm or device.

    Therefore, I cannot provide the requested information in the specified format from this text.

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    K Number
    K133258
    Device Name
    TRUFREEZE SYSTEM
    Manufacturer
    Date Cleared
    2014-06-19

    (239 days)

    Product Code
    Regulation Number
    878.4350
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    TRUFREEZE SYSTEM

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

    The truFreeze is intended for cryogenic destruction of tissue requiring either active or passive venting during surgical procedures.

    The truFreeze is indicated for use as a cryosurgical tool in the fields of dermatology, gynecology, and general surgery, to ablate benign and malignant lesions.

    Device Description

    The truFreeze system is a cryosurgical tool that applies medical-grade liquid nitrogen to the treatment area via a small, low pressure, open tipped catheter. The truFreeze System consists of (1) a console and (2) a disposable spray kit.

    Console:
    The console is the central interface of the system and is comprised of a touch panel computer (TPC) and cryogen, suction and electronics modules packaged in a mobile cart. Users interact with the console through a dual foot pedal and a touch panel. An off-the- shelf controller and associated software manage the cryogen level sensing, filling, pressure, cooling, defrost, suction, timing and data management functions. A wireless remote control provides alternative timer control from a distance in the treatment room. A fill kit, stored on the rear of the console, allows for liquid nitrogen transfer from the source tank to the console. Safety features include indicators, tank pressure relief valves, an isolated low voltage power system, and an emergency button to be used in the event of user or technical malfunction.

    Disposable spray kit:
    The truFreeze disposable spray kit consists of 5 individually packaged sterile single-use catheters ( 7 Fr Straight Tip Catheter and one Catheter Introducer.) and 5 individually packaged cryogen decompression tubes (CDTs) (each containing one Dual Lumen 20 Fr CryoDecompression Tube (CDT), Connector, and Suction Tubing.). The catheter is flexible and capable of retroflex in a scope. The CDT and accessory tubes are included for use with the on-board suction system.

    AI/ML Overview

    Here's an analysis of the acceptance criteria and study information for the truFreeze® System based on the provided document:

    1. Table of Acceptance Criteria and Reported Device Performance

    Bench Test CharacteristicAcceptance Criteria (Predicate IceSense3 K102360)Reported Device Performance (Proposed truFreeze® System K133258)Comments from Study
    Ability to reach equivalent dose (using same freeze/thaw/freeze cycle)2min/2min/2min = 2.1-2.5cm depth2min/2min/2min = 1.8-2.4cm depthBoth capable of producing equivalent depth of ice
    3min/2min/3min = 2.6-3.0cm depth3min/2min/3min = 2.4-3.0cm depth
    4min/4min/4min = 3.1-4.0cm depth4min/4min/4min = 3.0-3.6cm depth
    Output Temperature at tip-170 degree C-196 degree CBoth achieve temperatures low enough to destroy malignant tissue
    Equivalent temperature distribution using the radial distance from the 0°C isotherm (border of ice ball) to the -20°C, -40°C and -50°C isotherms@ freeze depth of 22mm at 0°C:
    -20°C isotherm at 16.9mm depth
    -40°C isotherm at 13.4mm depth@ freeze depth of 21.87mm at 0°C:
    -20°C isotherm at 15.5mm depth
    -40°C isotherm at 11.8mm depthBoth can produce lethal ice at comparable depths

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

    The document explicitly states that "limited bench testing was conducted to support demonstration of substantial equivalence." It does not specify the sample sizes (e.g., number of tests, number of trials) for each bench test performed. Given the nature of bench testing, the data provenance would be laboratory-controlled (not patient data). The document refers to the data as "bench testing," implying a prospective experimental setup in a lab environment. The country of origin of the data is not mentioned but can be inferred as the USA, as the applicant is CSA Medical in Lexington, MA.

    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. Bench testing typically does not involve human experts establishing ground truth in the same way clinical studies do. The "ground truth" for these tests would be the physical measurements taken (e.g., ice ball dimensions, temperature readings) by the testing equipment and personnel.

    4. Adjudication Method for the Test Set

    This information is not applicable and therefore not provided. Bench testing focuses on objective physical measurements, not subjective evaluations that would require adjudication among experts.

    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

    An MRMC comparative effectiveness study was not conducted. The document describes bench testing to demonstrate substantial equivalence to a predicate device, not a study involving human readers or AI assistance.

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

    A standalone performance study of an algorithm was not done. The "device" in this context is a cryosurgical tool (hardware with integrated software), not an AI algorithm. The performance evaluation was of the physical device's capabilities (ice ball formation, temperature output) in a lab setting.

    7. The Type of Ground Truth Used

    For the bench testing, the ground truth was based on physical measurements of:

    • Ice ball depth (in cm) under different freeze/thaw/freeze cycles.
    • Output temperature at the catheter tip (in degrees C).
    • Radial distance of specific isotherms (-20°C, -40°C) from the 0°C isotherm at a given freeze depth.

    These are objective, quantitative measurements taken directly from the device's operation.

    8. The Sample Size for the Training Set

    This information is not applicable and therefore not provided. The truFreeze® System is a physical cryosurgical device, not a machine learning model that requires a training set of data.

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

    This information is not applicable for the same reason as above (no training set for a physical device).

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