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510(k) Data Aggregation

    K Number
    K210628
    Manufacturer
    Date Cleared
    2021-11-04

    (247 days)

    Product Code
    Regulation Number
    884.1700
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    X-FLO Fluid Management System

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

    The X-FLO Fluid Management System is intended to:

    · Warm and pump fluid, via intravenous (IV) bags or fluid bottles, to provide fluid distention and flushing of the uterus for gynecology procedures. The device can also measure fluid deficit of the surgical procedure.

    · Warm and pump fluid, via IV bags or fluid bottles, to provide fluid distention and flushing of the bladder and kidneys, or general distention and flushing, for urological procedures. The device can also measure fluid deficit of the surgical procedure.

    · Warm and pump fluid, via IV bags or fluid bottles, to provide fluid distention and flushing of the shoulder, knee, or other small joints for orthopedic procedures. The device can also measure fluid deficit of the surgical procedure.

    Device Description

    The X-FLO Fluid Management System ("X-FLO") (P/N 01910), with an optional deficit module (P/N 01601) is intended for fluid distention, fluid warming, and fluid volume/deficit measurements, as well as external suction regulation pertaining to deficit measurements for diagnostic and/or operative endoscopic procedures within gynecology, urology, and orthopedic disciplines.

    The X-FLO utilizes a touchscreen user interface and performs fluid pressurization, warming, and volume/deficit monitoring functions. More specifically, the device employs a peristaltic pump to pressurize and deliver fluid to the surgical site for distending and continually flushing the surgical site for visualization purposes, utilizes infrared lamps to optionally warm the fluid to body temperature, and uses fluid bag weight to monitor fluid inflow.

    Regarding the optional deficit monitoring function, the device utilizes external suction to return fluid from the surgical site. The X-FLO monitors and adjusts the vacuum level to the operator selected setpoint by opening the suction line to atmosphere if necessary. Once the fluid is returned from the surgical site, the single-use deficit cartridge measures the fluid volume collected, prior to transfer to fluid collection equipment and/or the hospital's waste disposal system.

    The X-FLO is controlled via a Graphical User Interface (GUI), wherein the user is guided to select a surgical discipline and a procedure type. Once selected, the user can input the desired setpoint within the established minimum and maximum parameters for that procedure type. As set forth below, the X-FLO can operate in Pressure Control (the default control, or X-Control. Each control view has defaults and adjustment ranges for fluid pressure, flow, temperature, deficit alarm, and external suction regulation.

    In addition to adjusting the fluid pressure setpoint via the GUI, the user may optionally utilize a foot pedal included with the X-FLO to temporarily increase the fluid pressure. By pressing the foot pedal, the user initiates an increase in fluid pressure. The increase is user configurable but can never exceed the maximum allowable fluid pressure for the procedure. When the user desires to have the fluid pressure return to the setpoint, the foot pedal is released.

    AI/ML Overview

    The provided text details the 510(k) submission for the Thermedx X-FLO Fluid Management System, which is a medical device intended for fluid distention, warming, and volume/deficit measurements during various endoscopic procedures.

    Here's an analysis of the acceptance criteria and study data based on the provided document:

    Acceptance Criteria and Reported Device Performance

    The document presents a comparison table between the subject device (X-FLO Fluid Management System) and its predicate device (FluidSmart), which implicitly defines the performance criteria. The relevant criteria mainly relate to fluid warming, fluid delivery (pressure/flow), and deficit monitoring.

    Table of Acceptance Criteria and Reported Device Performance:

    Feature/CriterionAcceptance Criteria (from comparison with predicate/stated capability)Reported Device Performance (X-FLO Subject Device K210628)
    I. Imaging/AI Specifics(Not Applicable - This is not an AI/imaging device)(Not Applicable - This is not an AI/imaging device)
    II. Device Performance
    Fluid Warming
    Heating TechnologyInfrared lampsInfrared lamps
    Fluid Warming RateIncrease inlet fluid temp to 40°C.Capable of increasing inlet fluid temperature from 18 °C ± 1 °C to 40 °C ± 3 °C for flow rates 800 mL/min.
    Maximum Setpoint40°C40 °C
    Temperature MeasurementMeasured at exit from cartridge component of tubing setIrrigation fluid temperature measured at exit from the cartridge component of the tubing set
    Temperature DisplayedDisplayed at GUIIrrigation fluid temperature displayed at GUI.
    Over-temperature SafetyDisable pumping if fluid temp exceeds set-point + 3°CThe device will disable the lamps if the fluid temperature reaches 41.5 ± 1 °C. The device will disable pumping if the actual fluid temperature reaches 46 ± 1 °C.
    Fluid Delivery
    Pumping MechanismPeristaltic pumpPeristaltic pump with ability to reverse to relieve pressure
    Pressure Measurement(Implied accurate measurement)Dual transducers measuring fluid pressure
    Maximum Flow Rate1200 mL/min (stated for predicate)1200 mL/min
    Fluid Pressure30-300 mmHg (predicate)30-350 mmHg
    Max Fluid Vessel Size(2) 5-Liter (predicate)(4) 5-Liter (Note: The document states this "does not raise different questions of safety and effectiveness")
    Fluid Weight Accuracy± 10% or 250 mL (whichever is greater) (predicate)± 5 mL (Note: This is significantly more precise than the predicate's reported accuracy)
    Temporary Pressure IncreaseUser interface (predicate)Foot pedal or User interface
    Over-pressure SafetyAudible/visual notifications, suspend fluid flow if outside ±10% or 12mmHgAudible and visual notifications and disable pumping if the fluid pressure exceeds the setpoint by the greater of 10% or 12 mmHg. Disable pumping prior to irrigation pressure exceeding the maximum set point by more than the higher of 10% or 12 mmHg.
    Deficit Monitoring
    Fluid Deficit MonitoringYesYes
    Monitoring Accuracy SpecThe greater of 250ml or 10% of the volume pumped (predicate)1 – 1000 mL: ± 75 mL; 1000 – 2500 mL: ± 5 %; 2500 – 5000 mL: ± 3 %; ≥ 5000 mL: ± 2.2 % (Note: This is a different and more precise specification than the predicate's reported accuracy)
    Measurement MeansMeasurement by weight (predicate)Measurement by flow (Note: This is a different method than the predicate, justified by performance testing)
    Fluid Deficit DisplayDisplayed on GUI (predicate implied)Displayed on GUI
    External Suction RegulationNone (predicate)0-400 mmHg Suction Setpoint Range (Note: New feature, justified as not raising new questions of safety/effectiveness as it can be evaluated by performance testing)
    Over-deficit Safety (Isotonic)Audible/visible notification, suspend fluid flow if deficit reachedThe device will disable pumping when the default setpoint or maximum deficit volume (2,500 mL) is reached
    Over-deficit Safety (Hypotonic)(Not applicable for predicate)The device will disable pumping and provide audible notification when the deficit level reaches the deficit alarm setpoint inputted by the user. The device will disable pumping and provide audible notification when the maximum allowable deficit level of 2,500 mL is reached if the fluids used are a combination of isotonic and hypotonic. The device will disable pumping when the maximum deficit of 1,000 mL is reached. (Note: New feature due to the new deficit measurement method)
    III. Other Performance
    BiocompatibilityCompliant with ISO 10993-1, 5, 10, 11Conducted per 2020 FDA guidance. Tests include: Cytotoxicity (ISO 10993-5:2009), Sensitization (ISO 10993-10:2010), Irritation (ISO 10993-10:2010), Acute Systemic Toxicity (ISO 10993-11:2017)
    Electrical Safety & EMCCompliant with IEC 60601-1, 1-2, 1-6Complies with IEC 60601-1:2005 + CORR. 1 (2006) + CORR. 2 (2007) + AM1 (2012), IEC 60601-1-2:2014, and IEC 60601-6:2010 + A1:2013.
    Software V&V TestingCompliant with FDA guidance for "major" level of concernConducted as recommended by 2005 FDA guidance document. Software considered "major" level of concern.
    Sterility & Shelf-LifeSterile, compliant with ISO 11135, ASTM F198/F1929/F88Sterilized via Ethylene Oxide per ISO 11135:2014. Shelf life of 6 months. Shelf-life testing per accelerated aging (ASTM F198-16) with visual inspection (ASTM F1929-15) and seal strength (ASTM F88).
    Bench TestingSpecifications met in simulated use for various parametersEvaluated alarm sound levels, tubing/cartridge leak testing, tubing mechanical strength, fluid sensing, fluid compatibility (sterile water, lactated ringers, mannitol, glycine, saline, sorbitol), irrigation pressure controls (with three hysteroscope models), over-temperature, over-pressure, over-deficit testing, tissue trap capacity, deficit calculation accuracy, empty fluid bag detection, temperature accuracy, and pressure and flowrate accuracy.

    Study Proving Device Meets Acceptance Criteria:

    The document describes non-clinical performance testing conducted to support the substantial equivalence determination.

    1. Sample Size Used for Test Set and Data Provenance:

      • The document implies that testing was performed on representative units of the device and its accessories (tubing sets, deficit cartridge, etc.).
      • Sample Size: Not explicitly stated as a number of devices or data points for each bench test. For example, "Fluid compatibility with sterile water, lactated ringers solution, 5 % mannitol solution, 1.5 % glycine solution, 0.9% saline solution, and sorbitol solution" implies multiple tests, but the quantity of tests, runs, or devices tested for each parameter is not specified. Similarly, "Irrigation pressure controls with three different hysteroscope models" specifies the models but not the number of runs or devices.
      • Data Provenance: The document does not specify the country of origin of the data. It is a 510(k) submission to the US FDA, so the testing was presumably conducted in a manner acceptable for US regulatory submission. The studies are bench/laboratory studies focused on device performance, not patient data studies, so "retrospective or prospective" is not an applicable distinction in the sense of patient data collection.
    2. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications:

      • This is a technical performance study of a medical device, not a study involving human interpretation of clinical data (like AI for imaging). Therefore, the concept of "experts establishing ground truth" in the clinical sense (e.g., radiologists) is not applicable. The "ground truth" for these tests is the physical measurement of device performance against engineering specifications using calibrated equipment and standard test methods.
    3. Adjudication Method for the Test Set:

      • Not Applicable. As this involves objective bench testing, there is no "adjudication" in the sense of reconciling subjective expert opinions. Device performance measurements are compared directly against pre-defined engineering and regulatory specifications.
    4. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done:

      • No. This is not an AI/imaging device or a device whose performance is dependent on human reader interpretation. Therefore, an MRMC study is not relevant.
    5. If a Standalone (algorithm only without human-in-the-loop performance) was done:

      • Not Applicable. While the device has software ("Software controlled"), its performance is measured as an integrated system (hardware and software) in bench testing, not as a standalone algorithm evaluating clinical data. The "stand-alone" performance is implicitly the results of the bench testing.
    6. The Type of Ground Truth Used:

      • The "ground truth" for the performance studies is the pre-defined engineering specifications and internationally recognized standards (e.g., IEC 60601 series for electrical safety, ISO 10993 for biocompatibility) that the device must meet. Performance metrics (e.g., temperature, pressure, flow rate, deficit volume) are objectively measured using calibrated instruments during bench testing.
    7. The Sample Size for the Training Set:

      • Not Applicable. This is a hardware medical device with embedded software; it does not involve machine learning or AI models that require "training sets" in the conventional sense of data-driven model training. The software is developed and verified via traditional software engineering principles.
    8. How the Ground Truth for the Training Set Was Established:

      • Not Applicable. (As explained above, no traditional training set exists for this type of device.) The "ground truth" for software functionality testing (verification and validation) would be the software requirements specifications derived from the device's intended use and design.
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