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510(k) Data Aggregation
(56 days)
The Vacutore Air/Water Bottle Tubing is to connect an air/CO2 source, a sterile water source (water bottle), and an endoscope to supply air/CO2 and water during gastrointestinal endoscopic procedures. This device is intended to be used for not more than 24 hours. It is a 24-hour multi-patient use device.
The Vacutore CO2 Source Tubing with Luer Connector is intended to be used with a carbon dioxide (CO2) source with the purpose of supplying CO2 to the endoscope during endoscopic procedures. This device is intended to be used for not more than 24 hours. It is a 24-hour multi-patient use device.
The Vacutore® Air/Water Bottle Tubing and CO2 Source Tubing with Luer Connector (Hereafter called CQ2 Source Tubing) are intended for 24-hour multi-patient use. Air/water bottle tubing is supplied in sterile and CO2 Source Tubing is supplied in non-sterile.
The Vacutore® Air/Water Bottle Tubing is manufactured for use in conjunction with sterile water bottle, and together with Fujifilm 500/600 and 700 series endoscopes. The air/water bottle tubing is individually packed in sealed package, sold as a sterile device. The air/water bottle tubing is designed to be attached to the air/water port of the endoscopes to provide irrigation through the air/water channel to the distal end of endoscope.
The Vacutore® CO2 Source Tubing with Luer Connector is manufactured for use in conjunction with air/water bottle tubing and CO2 insufflator. The CO2 Source tubing is individually packed in sealed package, sold as a non-sterile device. The CO2 Source Tubing is designed to be attached to the air/water bottle tubing and the outlet of the CO2 insufflator to provide irrigation and CO2 insufflation through the air/water channel to the distal end of endoscope.
This document is a 510(k) Pre-Market Notification from GA Health Company Limited to the FDA for their Vacutore® Air/Water Bottle Tubing and Vacutore® CO2 Source Tubing with Luer Connector. The purpose of the submission is to demonstrate substantial equivalence to legally marketed predicate devices, not to prove the device's meeting of specific acceptance criteria in the context of an AI/ML study.
Therefore, the requested information for acceptance criteria, study details, sample sizes, ground truth establishment, expert qualifications, adjudication methods, and MRMC effectiveness studies is not applicable to this type of regulatory submission. This document pertains to traditional medical devices, not AI/ML-driven software.
The document primarily focuses on demonstrating that the new devices are as safe and effective as existing (predicate) devices through:
- Comparison of Technological Characteristics: Tables 2, 3, and 4 extensively compare the design, features, principles of operation, materials, and other specifications of the Vacutore® devices to their predicate devices.
- Non-Clinical Performance Data (Bench Testing): Section 9 describes various bench tests performed to ensure the devices meet their intended functional requirements.
Here's a breakdown of the relevant information provided, aligning with the spirit of your request as much as possible for a non-AI/ML device:
1. Table of Acceptance Criteria and Reported Device Performance:
The document does not explicitly state "acceptance criteria" in a quantitative, pass/fail manner for AI/ML performance metrics. Instead, it describes various performance tests conducted to show functional equivalence to predicate devices and ensure safety and efficacy. The reported "performance" is that the devices passed these tests.
Test Category | Specific Test | Acceptance Criteria (Implied) | Reported Device Performance |
---|---|---|---|
Vacutore® Air/Water Bottle Tubing | Assembling Integrity | Components are securely assembled and functional. | Passed (implied by overall conclusion) |
Endoscope Compatibility | Compatible with specified Fujifilm endoscopes. | Passed (implied by overall conclusion) | |
Compatibility with Bottle | Compatible with sterile water bottle. | Passed (implied by overall conclusion) | |
Two-Way Valve Integrity | Valve functions correctly without leakage or backflow. | Passed (implied by overall conclusion) | |
Flow Clamp Test | Clamp maintains proper flow control. | Passed (implied by overall conclusion) | |
Air Flow Test | Delivers adequate air flow. | Passed (implied by overall conclusion) | |
Water Flow Test | Delivers adequate water flow. | Passed (implied by overall conclusion) | |
24-hour use test | Maintains performance and integrity for 24 hours of use. | Passed (demonstrates 24-hour multi-patient use) | |
Vacutore® CO2 Source Tubing with Luer Connector | Assembling Integrity | Components are securely assembled and functional. | Passed (implied by overall conclusion) |
Compatibility with CO2 Insufflator | Compatible with CO2 insufflator. | Passed (implied by overall conclusion) | |
Compatibility with air/water bottle tubing | Compatible with Vacutore® Air/Water Bottle Tubing. | Passed (implied by overall conclusion) | |
CO2 delivery test | Delivers adequate CO2. | Passed (implied by overall conclusion) | |
Water delivery test | Delivers adequate water. | Passed (implied by overall conclusion) | |
Air leak test | No air leakage. | Passed (leakage test conducted for verification) | |
Water backflow test | Prevents water backflow. | Passed (indicates sufficient backflow prevention) | |
Sterilization | EO sterilization cycle | Sterility Assurance Level (SAL) of 10-6. | Achieved (validated EO sterilization cycle with SAL 10-6) |
EO residuals | Below maximum levels defined in ANSI/AAMI/ISO 10993-7:2008. | Achieved | |
Shelf Life (Air/Water Bottle Tubing) | Accelerated aging, seal strength, dye penetration, microbial barrier, vacuum leak, sterility | Maintains sterile barrier and intended performance for 1 year. | Passed (implies performance for at least one year) |
Shelf Life (CO2 Source Tubing) | Accelerated aging, seal strength, dye penetration, microbial barrier, vacuum leak, sterility | Maintains intended performance for 3 years. | Passed (implies performance for at least three years) |
Biocompatibility | Acute Systemic Toxicity, In Vitro Cytotoxicity, Skin Sensitization, Irritation | Device is biocompatible for mucosal membrane contact ≤ 24 hours. | All tests passed, device shown to be biocompatible. |
Simulated Use Testing | 24-hour multi-patient use, backflow prevention | Maintains performance and prevents backflow in simulated use. | Provided sufficient backflow prevention and verified 24-hour multi-patient use. |
2. Sample size used for the test set and the data provenance:
The document states that the bench testing was performed on "GA Health samples from initial production lots." It does not specify the exact number of units tested for each "test set" (i.e., for each individual test like air flow or leak test).
- Sample Size: Not explicitly stated as a number of devices per test.
- Data Provenance: The tests were performed in-house by GA Health Company Limited (the manufacturer). This is direct prospective testing of their own new device.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
Not applicable. This is a physical device, and the "ground truth" for performance is determined by established engineering and medical device standards and functional testing, not by expert interpretation in a clinical or image-based context.
4. Adjudication method for the test set:
Not applicable for a physical device's bench testing. Performance is measured against physical specifications and validated test methods.
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 device is not an AI/ML product for medical image interpretation or diagnosis.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
Not applicable. This is a physical medical device, not an algorithm.
7. The type of ground truth used:
The "ground truth" for these physical devices is based on:
- Engineering Specifications: Design tolerances, material properties, and functional requirements.
- Established Standards: e.g., ANSI/AAMI/ISO 10993-7:2008 for biocompatibility.
- Functional Performance: Direct measurement and observation of device operation (e.g., flow rates, leak prevention, integrity).
- Predicate Device Performance: The predicate devices themselves set a de-facto standard for expected performance and safety, against which the new device is compared to show substantial equivalence.
8. The sample size for the training set:
Not applicable. This is a physical medical device, not an AI/ML product that requires a training set.
9. How the ground truth for the training set was established:
Not applicable. This is a physical medical device.
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