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510(k) Data Aggregation

    K Number
    K190793
    Date Cleared
    2019-12-12

    (259 days)

    Product Code
    Regulation Number
    876.5860
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    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.

    Device Description

    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.
    AI/ML Overview

    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 PerformedAcceptance CriteriaResult
    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 TestingDocumentation 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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