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510(k) Data Aggregation

    K Number
    K163597
    Date Cleared
    2017-07-27

    (218 days)

    Product Code
    Regulation Number
    880.5860
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    VacLok AT Vacuum Syringe

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

    VacLok™ AT Vacuum Syringe is used to inject fluids into, or withdraw fluids from the body. It can also be used in cases where a vacuum syringe is preferred (e.g. thrombus, abscess fluid, bile, urine etc.).

    Device Description

    The VacLok™ AT Vacuum Syringe is a general piston syringe constructed using a barrel, plunger, piston seal, and locking mechanism. It is designed to lock in any position along the length of the barrel with the capability of holding a vacuum when the cam locking mechanism is engaged.

    AI/ML Overview

    The provided text is a 510(k) summary for the Merit VacLok™ AT Vacuum Syringe, a medical device. This document focuses on demonstrating the device's substantial equivalence to predicate devices, primarily through performance bench testing against recognized international standards and biocompatibility testing. It does not describe an AI/ML-based device or a study involving human readers or expert consensus for establishing ground truth in an AI/ML context.

    Therefore, many of the requested details about acceptance criteria and study design for an AI/ML device (e.g., sample size for test set with data provenance, number of experts for ground truth, MRMC study, standalone performance, training set details) are not applicable to this document.

    However, I can extract information related to the acceptance criteria and performance testing that was conducted for this physical medical device.

    1. Table of Acceptance Criteria and Reported Device Performance

    The document states that the device complies with FDA-recognized consensus standards ISO 7886-1 and ISO 594-2, and that "Results of the testing demonstrate that the subject device met the acceptance criteria sufficient for its intended use." Specific acceptance criteria values are not explicitly listed in a table, but the areas of testing and the general statement of compliance serve as the "reported device performance."

    CategoryAcceptance Criteria (from recognized standards)Reported Device Performance
    ISO 7886-1:1993(Implicitly, the requirements of the standard for each test)All tests met the established acceptance criteria for intended use.
    Cleanliness
    Limits for acidity or alkalinity
    Limits for extractable metals
    Lubricant
    Tolerance on Graduation
    Capacity
    Graduation Scale
    Barrel
    Piston/Plunger Assembly
    Nozzle
    Performance - Freedom from air and liquid leakage past piston
    ISO 594-2:1998(Implicitly, the requirements of the standard for each test)All tests met the established acceptance criteria for intended use.
    Gauging
    Liquid leakage
    Air leakage
    Separation force
    Unscrewing torque
    Ease of assembly
    Resistance to overriding
    Stress cracking
    Vacuum Performance TestingAll tests met the established acceptance criteria for intended use.
    Air Leakage (Annex B of ISO 7886-1)
    Vacuum Hold (Annex B of ISO 7886-1, 2 minutes)
    Biocompatibility Testing(Implicitly, the requirements of the ISO 10993 series and related FDA guidance)All tests demonstrated biocompatibility for the specified contact type and duration.
    Cytotoxicity
    Sensitization
    Irritation
    Acute Systemic Toxicity
    Pyrogenicity
    Hemolysis
    USP Physicochemical

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

    The document does not specify the exact sample sizes (e.g., number of syringes) used for each bench test. The data provenance is also not detailed beyond the statement that testing was performed by the manufacturer against international standards. It's inherent to this type of device submission that testing is done in a controlled laboratory setting (prospective testing of manufactured devices), rather than using clinical patient data. The country of origin for the data (testing lab location) is not specified.

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

    This question is not applicable as this is a medical device (syringe) performance evaluation, not an AI/ML diagnostic or prognostic system requiring expert-established ground truth from medical images or clinical records. The "ground truth" for the device's performance is established by the specifications and acceptance criteria of the referenced ISO standards.

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

    This question is not applicable as there is no human interpretation or subjective assessment being adjudicated. Device performance is measured objectively against predefined standards.

    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 question is not applicable as the device is a physical syringe, not an AI system.

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

    This question is not applicable as the device is a physical syringe, not an algorithm. Bench testing evaluates the device's performance standalone relative to engineering standards.

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

    The "ground truth" for this device's performance is based on the objective technical specifications and acceptance criteria outlined in recognized international consensus standards (e.g., ISO 7886-1, ISO 594-2) and the FDA's guidance documents for biocompatibility and sterilization.

    8. The sample size for the training set

    This question is not applicable as there is no "training set" in the context of a physical medical device. Manufacturing processes are subject to quality controls and design validation, but not a data-driven "training" as in AI/ML.

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

    This question is not applicable for the reasons stated above.

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