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510(k) Data Aggregation

    K Number
    K210782
    Device Name
    Tablo Cartridge
    Date Cleared
    2021-11-26

    (255 days)

    Product Code
    Regulation Number
    876.5820
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Tablo Cartridge is a single use, disposable arterial and venous bloodline set intended to provide extra-corporeal access during hemodialysis. The Tablo Cartridge is compatible only with the Tablo Hemodialysis System.

    Device Description

    The Tablo Cartridge is a single use blood tubing set attached to an organizer tray. The E-beam sterilized and disposable cartridge is inserted onto the front panel of the console for each dialysis treatment.

    AI/ML Overview

    The provided document is a 510(k) summary for the Tablo Cartridge, a medical device used in hemodialysis. It outlines the performance data submitted to the FDA to demonstrate substantial equivalence to a predicate device. However, this document does not describe a study involving an AI/machine learning device, nor does it detail acceptance criteria and a study proving an AI device's performance in the way implied by the prompt's structured questions.

    Specifically, the device in question is a physical "blood tubing set" for hemodialysis, and the changes discussed are related to manufacturing processes (sterilization method) and minor design improvements. The "performance data" refers to validation tests for sterilization, shelf-life, biocompatibility, and bench performance of the physical cartridge, not the performance metrics of an AI algorithm.

    Therefore, many of the questions asked in the prompt, such as "Number of experts used to establish the ground truth for the test set," "Adjudication method," "MRMC comparative effectiveness study," "standalone (i.e. algorithm only without human-in-the-loop performance)," and "How the ground truth for the training set was established," are not applicable to the information provided in this 510(k) summary.

    Based on the provided document, here's what can be extracted, acknowledging that it does not fit the typical AI/ML device study format requested:


    Device: Tablo® Cartridge (Hemodialysis blood tubing set)
    Nature of Submission: 510(k) for a modified device (change in sterilization method from Ethylene Oxide (EO) gas to E-beam radiation, and minor design changes).

    Given the nature of the device and the modification, the "acceptance criteria" and "study proving the device meets the acceptance criteria" are related to the safety and performance of the physical medical device and its manufacturing process, not an AI algorithm.


    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not present a single table with explicit "acceptance criteria" alongside "reported device performance" values in a quantitative, pass/fail format in terms of algorithm accuracy (e.g., sensitivity, specificity, AUC). Instead, it lists various types of tests conducted to ensure the device's safety and functionality after the modification. The acceptance criteria for these tests are implied to be compliance with relevant ISO standards, USP standards, and FDA guidance documents.

    Test CategoryImplied Acceptance Criteria (Compliance with)Reported Device Performance (Summary of Study Outcome)
    E-Beam Sterilization ValidationISO 11137-1:2006, ISO 11137-2:2013, ISO 11737-1:2018, ISO 11737-2:2019, USP <71>, ANSI/AAMI ST72:2019. (Ensuring the device is sterile post-treatment and biocompatible with human contact).Conducted comprehensive tests including Bioburden Recovery, Bioburden Determination, Verification Dose Determination, Dose Map Study, Method Suitability Determination, and Test of Sterility. The outcome stated: "The E-beam sterilization process validation testing... was conducted in accordance with FDA guidance documents" and "complies with following standards." This implies successful validation demonstrating effective sterilization.
    Shelf-Life TestingISO 11607-1:2019, ISO 11607-2:2019. (Ensuring the device maintains functionality, sterility, and package integrity over its intended shelf-life under various conditions).Included Accelerated aging testing, Climatic conditioning testing, Gross leak detection (Bubble) testing, Seal strength (Peel) testing, Package performance testing, and Product functional testing. The outcome stated: "The shelf-life verification testing included the following tests to ensure that the Tablo Cartridge complies with the ISO 11607-1:2019 and ISO 11607-2:2019 standards." This implies successful demonstration of shelf-life stability.
    Biocompatibility TestingISO 10993-1:2018. (Ensuring the device does not cause unacceptable adverse biological reactions when in contact with the patient's blood path). Specific tests: Cytotoxicity, Sensitization, Irritation, Acute systemic toxicity, Hemocompatibility, Genotoxicity, Pyrogenicity.Conducted a battery of tests for an external communicating device with prolonged direct and indirect contact (>24 hours to 30 days) with the blood path. The outcome stated: "The battery of testing included the following tests and continues to be supportive for the modified device, per ISO 10993-1:2018." This implies successful demonstration of biocompatibility.
    Bench Performance TestingMeeting system requirements and performing as intended (Implied to be aligned with the predicate device's performance and/or internal specifications for flow rates, pressure handling, etc., relevant to hemodialysis blood tubing sets)."Nonclinical bench performance tests were conducted to demonstrate that the Tablo Cartridge meets the system requirements and performs as intended." The outcome stated: "The performance testing demonstrates that the Tablo Cartridge meets all performance specifications and complies with applicable standards and FDA Guidance Documents." This indicates successful functional performance.

    Overall Conclusion: "The Tablo Cartridge (Modified Device) is substantially equivalent to the Predicate Device, and the minor difference between the Modified and the Predicate Device do not raise any new or different questions of safety or effectiveness."


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

    • Sample Size: Not explicitly stated numerically (e.g., number of cartridges tested). For sterilization validation, often a statistically significant sample size based on standards like ISO 11137 is used, but the exact number isn't provided here. The same applies to shelf-life and bench performance testing.
    • Data Provenance: Not specified regarding country of origin or whether it was retrospective/prospective. This is typical for device performance testing performed by the manufacturer, rather than clinical trial data.

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

    • Not Applicable. This is not an AI/imaging device requiring expert interpretation for ground truth. The "ground truth" for this device would be objective measurements and laboratory test results demonstrating physical, chemical, and biological properties.

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

    • Not Applicable. There's no human interpretation or subjective assessment that would require an adjudication method.

    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. This is a physical medical device, not an AI/ML algorithm that assists human readers.

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

    • Not Applicable. This is a physical medical device.

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

    • For this device, the "ground truth" is established through objective laboratory testing, established chemical/biological assays, and physical performance measurements against predefined specifications and internationally recognized standards (e.g., ISO, USP). It's based on empirical measurements of device properties rather than human diagnostic interpretation.

    8. The sample size for the training set:

    • Not Applicable. There is no "training set" as this is not an AI/ML model.

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

    • Not Applicable. There is no "training set" or corresponding ground truth establishment process in the context of AI/ML.
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    K Number
    K140841
    Device Name
    TABLO CARTRIDGE
    Manufacturer
    Date Cleared
    2014-09-11

    (162 days)

    Product Code
    Regulation Number
    876.5820
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Tablo™ Cartridge is a single use, disposable arterial and venous bloodline set intended to provide extracorporeal access during hemodialysis. The Tablo™ Cartridge is compatible only with the Tablo™ Hemodialysis System.

    Device Description

    The Tablo™ Cartridge comprises a single-use, sterile Blood Tubing Set attached to an Organizer. The Organizer ensures proper placement of the Blood Tubing Set with the Tablo Hemodialysis System. The Blood Tubing Set consists of an arterial line, a venous line, an adaptor to connect the two lines, a saline line, a pressure transducer protector, a venous drip chamber, an arterial pressure pod, and a heparin syringe line. The Tablo Cartridge is developed exclusively for use with the Tablo Hemodialysis System. It is single-use, offered in one configuration, and provided sterile.

    AI/ML Overview

    This document is a 510(k) summary for the Tablo™ Cartridge, a blood tubing set used for hemodialysis. It does not present a study proving the device meets acceptance criteria in the way one might expect for a clinically-oriented AI/software device. Instead, it describes performance testing to demonstrate substantial equivalence to a predicate device for a hardware medical device.

    Therefore, many of the requested fields (like sample size for test sets, number of experts, adjudication methods, MRMC studies, standalone performance for AI, and training set details) are not applicable to this type of submission.

    Here's a breakdown based on the provided document:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly present a table of acceptance criteria with corresponding performance metrics like sensitivity, specificity, or AUC, as would be common for AI/software devices. Instead, it lists types of performance testing and a general conclusion of compliance.

    Acceptance Criteria CategoryReported Device Performance
    Functional TestingMet all performance specifications. The minor differences in technological characteristics (organizer, inner diameter of blood pump segment, access point configuration, pressure measuring component) did not raise new or different questions of safety or effectiveness.
    Biocompatibility TestingDemonstrated to be safe and did not raise new or different questions of safety or effectiveness.
    Packaging and Shelf Life TestingDemonstrated to be safe and did not raise new or different questions of safety or effectiveness.
    Sterilization ValidationDemonstrated to be safe and did not raise new or different questions of safety or effectiveness.
    Pyrogenicity Testing (for blood fluid path)Demonstrated to be safe and did not raise new or different questions of safety or effectiveness.
    Applicable Standards and FDA Guidance DocumentsComplies with applicable standards and FDA Guidance Documents.
    Substantial EquivalenceDetermined to be substantially equivalent to the Fresenius Blood Tubing Set (K120823).

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

    This information is Not Applicable to this document as it describes testing of a physical medical device (blood tubing set) rather than an AI/software device with a distinct "test set" of data. The testing mentioned would involve laboratory and engineering tests on physical devices.

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

    This information is Not Applicable. Ground truth, in the context of expert review for medical images or data, is not relevant for the performance testing described for a blood tubing set.

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

    This information is Not Applicable. Adjudication methods are typically used for expert consensus on ambiguous cases in the context of diagnostic AI/software.

    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 information is Not Applicable. MRMC studies are specific to evaluating the impact of AI on human reader performance, which is not relevant for a physical device like a blood tubing set.

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

    This information is Not Applicable. There is no algorithm discussed for standalone performance.

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

    This information is Not Applicable. The "ground truth" for the performance of a blood tubing set would be established by validated engineering specifications, material standards, and functional requirements rather than medical expert consensus or pathology.

    8. The sample size for the training set

    This information is Not Applicable. Training sets are relevant for machine learning algorithms, which are not described in this submission for a physical medical device.

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

    This information is Not Applicable. As there is no training set for an AI/ML algorithm, this question is not relevant.

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