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510(k) Data Aggregation
(255 days)
Tablo Cartridge
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.
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.
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 Category | Implied Acceptance Criteria (Compliance with) | Reported Device Performance (Summary of Study Outcome) |
---|---|---|
E-Beam Sterilization Validation | ISO 11137-1:2006, ISO 11137-2:2013, ISO 11737-1:2018, ISO 11737-2:2019, USP , 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 Testing | ISO 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 Testing | ISO 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 Testing | Meeting 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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(259 days)
Tablo Hemodialysis System, Tablo Cartridge
The Tablo® Hemodialysis System is indicated for use in patients with acute and/or chronic renal failure, with or without ultrafiltration, in an acute or chronic care facility. Treatments must be administered under physician's prescription, with a trained individual available as needed who is considered competent in the use of the prescribing physician.
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.
The Tablo Hemodialysis System is a self-contained hemodialysis system intended for acute and chronic dialysis therapy, with or without ultrafiltration, in an acute or chronic care facility. The system's innovative design includes the:
- . Tablo Console, a single module consisting of multiple fluidic systems that perform the activities of a water purification system (WPS) and a conventional dialysis delivery system (DDS), and
- Tablo Cartridge, a single use blood tubing set attached to an organizer tray. The ethylene oxide (EO) sterilized and disposable cartridge is inserted onto the front panel of the console for each dialysis treatment (Figure 1).
- . Tablo Script, an accessory software to the Tablo Console, is designed for use by medical professionals to a) prepare, update and verify patient dialysis prescriptions b) view and export dialysis treatment information and billing activities and c) set and modify Tablo Console settings. Note: Tablo Script is optional, patient prescriptions can still be created or changed directly on the Tablo Console.
Here's a breakdown of the acceptance criteria and study findings for the Tablo Hemodialysis System and Tablo Cartridge, based on the provided document:
1. Table of Acceptance Criteria and Reported Device Performance
Test Performed | Acceptance Criteria | Result |
---|---|---|
Biocompatibility testing (Tablo Cartridge) | Tests included Cytotoxicity, Sensitization, Intracutaneous reactivity, Acute systemic toxicity, Hemocompatibility, Genotoxicity, as per FDA guidance "Hemodialysis Blood Tubing Sets - Premarket Notification [510(k)] Submissions." Results must be passing under individual test conditions. | Pass |
Biocompatibility testing (Tablo Console fluid contact materials) | Leachable testing conducted in accordance with FDA Guidance for the Content of Premarket Notifications for Hemodialysis Delivery Systems. Toxicological assessment confirms materials are safe for intended use. | Pass |
Electrical safety and electromagnetic compatibility (EMC) | System complies with ES 60601-1, main and its collateral standards. | Pass |
Software Verification and Validation Testing | Documentation provided as recommended by FDA's Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices." (Major level of concern: failure could result in serious injury or death). | Pass |
Device Performance (Shelf Life and Sterilization) | Device meets performance requirements following 1 year accelerated aging. | Pass |
Packaging integrity (Shelf Life and Sterilization) | Packaging system meets performance requirements following 1 year accelerated aging. | Pass |
Sterilization (Shelf Life and Sterilization) | Device is EO sterilized, meets SAL of 10^-6. | Pass |
EO residuals (Shelf Life and Sterilization) | Meets ISO 10993-7 for prolonged contact device. | Pass |
Bacterial endotoxin (LAL) testing (Shelf Life and Sterilization) | Meets ANSI/AAMI ST72. | Pass |
1. Environmental Operation (Bench Performance Testing) | The device shall meet the system requirements for environmental operation. | Pass |
2. Transit (Bench Performance Testing) | The system shall operate within specification after transit. | Pass |
3. Prime Discard (Bench Performance Testing) | The Tablo Cartridge shall meet the requirements for prime discard. | Pass |
4. Pinch Valve (Bench Performance Testing) | The system shall meet requirements for the blood and saline pinch valves. | Pass |
5. Maximum Power (Bench Performance Testing) | The system shall meet requirements for maximum power and current. | Pass |
6. Dialyzer Compatibility (Bench Performance Testing) | The system shall be compatible with hemodialyzers of sizes with the following ranges: Major Diameter: 2.14 - 2.75", Minor Diameter: 1.45 - 2.05", Total Length: 11.55 - 13.15", Dialysate Port Distance: 8.15 - 9.55". | Pass |
7. External Device Compatibility (Bench Performance Testing) | The system shall be compatible with external devices (i.e., external infusion pump, manual syringe injection of saline bolus and Transonic sensors (Transonic part number H4FX)). | Pass |
8. Cartridge Hemolysis Testing, 12 Hours (Bench Performance Testing) | The increase in hemolysis in a sample of blood circulating through the fluidic path during treatment as compared to a control sample of blood idle for the same amount of time shall not exceed 1%. The system shall meet its hemolysis requirements with a Crit-Line blood chamber (Fresenius part number 191058) connected within the extracorporeal circuit. | Pass |
9. Various hardware (Bench Performance Testing) | The system shall meet the following requirements for various hardware. | Pass |
10. Water Ingress (IP21) (Bench Performance Testing) | The console enclosure shall have an IP21 ingress protection rating per IEC 60529. | Pass |
11. Mechanical (Bench Performance Testing) | The system shall meet requirements for labeled priming volume, be designed with an ultrafilter that removes microbial materials and particles > 5nm, shall be designed with the required ports so that sampling for monitoring can be taken. | Pass |
12. Front Panel Interface with Cartridge Installed (Bench Performance Testing) | The system shall meet the following requirements for front panel interface with the cartridge installed. | Pass |
13. Essential Performance per IEC 60601-2-16 (Bench Performance Testing) | The system shall meet Essential Performance per IEC 60601-2-16. | Pass |
14. Battery Failure (Bench Performance Testing) | The system shall prevent treatment initiation if it detects a low battery voltage. | Pass |
15. AAMI Water and Dialysate Quality (Bench Performance Testing) | The system shall meet ANSI/AAMI 13959:2014 and ANSI/AAMI 11663:2014 requirements for water and dialysate. | Pass |
16. Total Dissolved Solids (Bench Performance Testing) | - Water sample results meet ANSI/AAMI 13959 toxic contaminant standards and ISO 23500 trace element standards. |
- Water from the Post RO sample port meets ISO 23500 electrolyte concentration limits when prepared from water with hardness of 150 mg/L. | Pass |
| 17. Water Treatment System (Bench Performance Testing) | The system shall meet requirements for a water treatment system. | Pass |
| 18. Dialysate flow and Conductivity Monitoring (Bench Performance Testing) | The system shall meet requirements for dialysate flow, temperature, volume, and conductivity monitoring. | Pass |
| 19. Air-In-Line (Bench Performance Testing) | The system shall meet requirements related to the system's purging and detection of air bubbles in the extracorporeal circuit. | Pass |
| 20. Pre-Treatment Mode (Bench Performance Testing) | The system shall meet requirements for pre-treatment mode. | Pass |
| 21. Post-Treatment Mode (Bench Performance Testing) | The system shall meet requirements for post-treatment mode. | Pass |
| 22. Blood Pump and Pinch Valve Control, and Saline Delivery Performance (Bench Performance Testing) | The system shall meet requirements for operation, performance, and control of the peristaltic blood pump. | Pass |
| 23. Heat Disinfection Mode (Bench Performance Testing) | The system shall meet requirements for heat disinfection mode. | Pass |
| 24. Chemical Disinfection Mode (Bench Performance Testing) | The system shall meet requirements for chemical disinfection mode. | Pass |
| 25. Ultrafiltration Accuracy (Bench Performance Testing) | The system shall provide a treatment fluid removal accuracy of +/- 100 mL per hour of the treatment time. | Pass |
| 26. Maintenance and Service User (Bench Performance Testing) | The system shall meet requirements for maintenance and service user. | Pass |
| 27. Maintenance and Service User (Mock Treatments) (Bench Performance Testing) | The system shall allow the user to run mock treatments in Service Interface without the need of a Patient USB. | Pass |
| 28. Heat and Chemical Disinfection Effectiveness (Bench Performance Testing) | Disinfection validation was performed on n=3 consoles per organism, totaling n=6 consoles to demonstrate that chemical and heat disinfection cycles reduce vegetative bacterial species (e.g., Pseudomonas aeruginosa) by six logs and non-tuberculous Mycobacterium species (e.g., Mycobacterium terrae) by three logs. | Pass |
| 29. External Disinfectant Chemical Compatibility Testing (IEC 60601-2-16 Test) (Bench Performance Testing) | The system and its accessories shall be capable of withstanding daily cleaning, using specified chemicals (70% Isopropyl Alcohol, 10% bleach, PDI Super Sani Cloth Germicidal Wipes, CaviWipes, CaviWipes1 Disinfecting Wipe, Oxivir 5, Oxivir TB Wipes) over the service life of the device per the chemical manufacturer instructions. | Pass |
| 30. Bring Your Own Concentrate Conductivity Test (Bench Performance Testing) | The system shall be compatible with dialysis fluid concentrates intended for a 45X-proportioning ratio. When mixed at a 45X ratio, the acid concentrate should comply with the following labeled formulation range: Sodium 100 mEq/L, Potassium 0 - 4 mEq/L, Calcium 0 - 3.5 mEq/L, Acetate 4 mEq/L. | Pass |
| 31. Human Factors Validation (Bench Performance Testing) | The system shall be assessed for usability with representative users (i.e., nurses and patient care technicians in clinical settings and acute-care facilities) in accordance with its intended use/indications for use. | Pass |
The document states that "Non-clinical testing supports the safety and effectiveness of the Tablo Hemodialysis System and Tablo Cartridge. The bench testing demonstrates that the device systems comparably to the predicate device and is substantially equivalent to the legally marketed device." This implies that all listed acceptance criteria were met.
2. Sample Size Used for the Test Set and Data Provenance
- Test Set Sample Size: The document does not explicitly state a general "test set" sample size for all performance tests. Specific sample sizes are mentioned for certain tests:
- Shelf Life and Sterilization Testing: The specifics of how many cartridges were subjected to accelerated aging are not detailed, but it's implied that the testing was sufficient to justify a 12-month shelf life.
- Heat and Chemical Disinfection Effectiveness: n=3 consoles per organism, totaling n=6 consoles for disinfection validation.
- Data Provenance: The data is from non-clinical bench performance testing and biocompatibility testing. It is not patient-derived data. The country of origin is not specified but implicitly refers to testing performed by or for Outset Medical, Inc., a U.S. company. The studies are prospective in the sense that they were designed and executed to evaluate the device.
3. Number of Experts and Qualifications for Ground Truth
- Ground Truth for Biocompatibility: Not applicable in the sense of expert consensus on qualitative data. The ground truth here is derived from standardized laboratory tests and their established pass/fail criteria (e.g., cytotoxicity, sensitization, hemocompatibility). Interpretation of these results would be done by qualified laboratory personnel and toxicologists. The specific number and qualifications are not detailed.
- Ground Truth for Performance Testing: Not applicable. Performance tests (e.g., flow rates, pressures, temperatures, disinfection efficacy, ultrafiltration accuracy) are measured against predefined engineering and regulatory specifications and standards (e.g., IEC standards, AAMI standards). The ground truth is the objective measurement comparing the device's output to these quantitative standards.
- Ground Truth for Human Factors Validation: The "ground truth" here is the assessment of usability in accordance with intended use. While representative users (nurses and patient care technicians) are involved, the document does not specify the number of experts (e.g., human factors engineers) who established the protocol or interpreted the findings, nor their specific qualifications.
4. Adjudication Method for the Test Set
The concept of an "adjudication method" (like 2+1, 3+1) typically applies to studies where human readers are interpreting ambiguous data (e.g., medical images, clinical diagnoses) and discrepancies need to be resolved. This is not applicable to the non-clinical, objective functional and safety performance tests described for the Tablo Hemodialysis System. The results are based on direct measurements and adherence to engineering and biological standards.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No. A Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. This type of study typically evaluates the diagnostic performance or interpretative accuracy of humans (with or without AI assistance) on a set of cases. The studies presented are non-clinical engineering and safety performance tests of a medical device.
6. Standalone Performance Study (Algorithm Only)
The term "standalone" performance usually refers to the algorithm's performance without human intervention, particularly in the context of AI/software. While "Software Verification and Validation Testing" was performed for the Tablo system, the documentation doesn't describe it as an isolated algorithm performance study in the way an AI diagnostic tool would be evaluated. The software is an integrated component controlling the physical device, and its validation is part of the overall system's functional assessment. Therefore, a standalone algorithm performance study, as typically understood for AI, was not explicitly detailed as such.
7. Type of Ground Truth Used
The ground truth used for these studies is primarily:
- Established industry standards and regulatory guidelines: Examples include ISO 10993-7, ANSI/AAMI ST72, ES 60601-1, IEC 60601-2-16, ANSI/AAMI 13959:2014, ANSI/AAMI 11663:2014, and ISO 23500.
- Engineering specifications and design requirements: These define the expected performance of various components and the system as a whole (e.g., maximum power, dialyzer compatibility dimensions, ultrafiltration accuracy of +/- 100 mL/hr, specified concentrate parameters).
- Biological and chemical pass/fail criteria: For biocompatibility, sterilization, and disinfection effectiveness tests, which are based on scientific principles and regulatory limits.
There are no mentions of expert consensus, pathology, or outcomes data being directly used to establish the ground truth for these specific non-clinical tests.
8. Sample Size for the Training Set
Not applicable. This document describes the performance testing of a physical medical device (hemodialysis system and cartridge), not an AI algorithm that requires a "training set" of data. The software within the device underwent verification and validation, but this is distinct from machine learning model training.
9. How the Ground Truth for the Training Set Was Established
Not applicable. As mentioned above, this is not an AI algorithm document where a training set and its ground truth would be relevant.
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(162 days)
TABLO CARTRIDGE
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.
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.
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 Category | Reported Device Performance |
---|---|
Functional Testing | Met 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 Testing | Demonstrated to be safe and did not raise new or different questions of safety or effectiveness. |
Packaging and Shelf Life Testing | Demonstrated to be safe and did not raise new or different questions of safety or effectiveness. |
Sterilization Validation | Demonstrated 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 Documents | Complies with applicable standards and FDA Guidance Documents. |
Substantial Equivalence | Determined 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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