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510(k) Data Aggregation

    Why did this record match?
    Device Name :

    truFreeze Console, PN CC301; Aire PV Passive Venting Catheter, PN CO840703; 16 Fr CDT 5 Pack, PN 2000181

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

    The truFreeze System is indicated for use as a cryosurgical tool in the fields of dermatology, gynecology, and general surgery, to ablate benign (e.g. Barrett's Esophagus with high grade dysplasia and/or low grade dysplasia) and malignant lesions.

    Device Description

    The truFreeze system is a cryosurgical tool that applies medical-grade liquid nitrogen to the ablation area via a small, low pressure, open tipped catheter. The truFreeze System consists of a console and a disposable spray kit. The console is the central interface of the system and is comprised of a touch panel computer (TPC) and cryogen, suction, and electronics modules packaged in a mobile cart. Users interact with the console through a dual foot pedal and a touch panel. An off-the-shelf controller and associated software manage the cryogen level sensing, filling, pressure, cooling, defrost, suction, timing and data management functions. A fill kit, stored on the rear of the console, allows for liquid nitrogen transfer from the source tank to the console. Safety features include indicators, tank pressure relief valves, an isolated low voltage power system, and an emergency button to be used in the event of user or technical malfunction. There are 2 types of spray kits available. One kit is available for active venting procedures and one is available for passive venting procedures. Both active and passive venting kits are provided in a carton of five (5) individually packaged sterile, single-use catheters with introducers (an introducer is a spring that is introduced into the accessory channel port of the endoscope to provide additional strain relief to the catheter during insertion and retraction from the endoscope) in individual pouches. These catheters are used to introduce the liquid nitrogen to the desired site. Additionally, the active venting kit is provided with a carton of five (5) individually packaged sterile, single-use cryo decompression tubes (CDTs) with associated tubing in individual pouches. The CDTs are used for the removal of the gaseous nitrogen from the patient. Each carton within a spray kit contains the instructions for use.

    AI/ML Overview

    The truFreeze System is a cryosurgical tool validated through a series of non-clinical performance tests. The acceptance criteria and the study results are as follows:

    1. Table of Acceptance Criteria and Reported Device Performance:

    TestAcceptance Criteria (Implicit from "Pass")Reported Device Performance
    Suction flow rateMeets specified flow rate requirementsPass
    Kink ResistanceMaintains patency under specified kinking conditionsPass
    Dimensional measurementsAdheres to design specificationsPass
    Tensile strength of bonded jointsMeets specified tensile strength requirementsPass
    Biocompatibility testingComplies with ISO-10993 requirementsPass
    Product sterility adoptionAchieves a Sterility Assurance Level (SAL) of 10^-6Pass
    Simulated use testingPerforms as intended during simulated use scenariosPass

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

    The document does not explicitly state the sample sizes for each specific test in the "Summary of Non-Clinical Performance Testing." The tests are labeled as "verification testing," which typically involves conducting tests on a representative number of units to ensure consistency and compliance.

    The data provenance is from non-clinical testing conducted by STERIS Corporation for a modification to their existing truFreeze System (K222272). This is presumably prospective testing, as it was specifically done to validate the redesigned 16 French (Fr) cryo-decompression tube. The country of origin of the data is not explicitly stated, but given STERIS Corporation's address in Mentor, Ohio, USA, it can be inferred that the testing was conducted in the USA or by labs commissioned by them.

    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 as the described study is a series of non-clinical performance tests, not a clinical study involving human or image-based ground truth established by experts.

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

    This information is not applicable for the same reason as point 3. The testing involves objective physical and functional measurements against predefined specifications.

    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. The truFreeze System is a cryosurgical tool, not an AI-assisted diagnostic or imaging device used with human readers.

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

    This information is not applicable. The truFreeze System is a physical medical device, not a standalone algorithm.

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

    For the non-clinical performance testing, the "ground truth" is defined by engineering specifications, established standards (e.g., ISO-10993 for biocompatibility), and functional requirements derived from the intended use of the device. For example, for "Suction flow rate," the ground truth would be a predetermined flow rate range that the device must achieve.

    8. The sample size for the training set:

    This information is not applicable. The device is a hardware system, and the reported testing is traditional engineering verification, not machine learning model training.

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

    This information is not applicable for the same reason as point 8.

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    Why did this record match?
    Device Name :

    truFreeze Console, PN CC301; Aire PV Passive Venting Catheter, PN CO840703; 16 Fr CDT 5 Pack, PN 2000181

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

    The truFreeze System is indicated for use as a cryosurgical tool in the fields of dermatology, gynecology, and general surgery, to ablate benign (e.g. Barrett's Esophagus with high grade dysplasia and/or low grade dysplasia) and malignant lesions.

    Device Description

    The truFreeze system is a cryosurgical tool that applies medical-grade liquid nitrogen to the ablation area via a small, low pressure, open tipped catheter. The truFreeze System consists of a console and a disposable spray kit.

    The console is the central interface of the system and is comprised of a touch panel computer (TPC) and cryogen, suction, and electronics modules packaged in a mobile cart. Users interact with the console through a dual foot pedal and a touch panel. An off-the-shelf controller and associated software manage the cryogen level sensing, filling, pressure, cooling, defrost, suction, timing and data management functions. A fill kit, stored on the rear of the console, allows for liquid nitrogen transfer from the source tank to the console. Safety features include indicators, tank pressure relief valves, an isolated low voltage power system, and an emergency button to be used in the event of user or technical malfunction.

    There are 2 types of spray kits available. One kit is available for active venting procedures and one is available for passive venting procedures. Both active and passive venting kits are provided in a carton of five (5) individually packaged sterile, single-use catheters with introducers (an introducer is a spring that is introduced into the accessory channel port of the endoscope to provide additional strain relief to the catheter during insertion and retraction from the endoscope) in individual pouches. These catheters are used to introduce the liquid nitrogen to the desired site.

    Additionally, the active venting kit is provided with a carton of five (5) individually packaged sterile, single-use cryo decompression tubes (CDTs) with associated tubing in individual pouches. The CDTs are used for the removal of the gaseous nitrogen from the patient. Each carton within a spray kit contains the instructions for use.

    AI/ML Overview

    The provided text is a 510(k) Summary for the truFreeze System, which is a cryosurgical tool. This document primarily focuses on demonstrating substantial equivalence to a predicate device and addresses labeling changes, rather than presenting a performance study with acceptance criteria for a new or modified device.

    Therefore, most of the requested information regarding acceptance criteria and performance study details is not available in this document. The document explicitly states:

    • "No performance testing was conducted as the subject of this submission is changes to the labeling only."

    This means there is no study described that "proves the device meets the acceptance criteria" in the traditional sense of a clinical or performance study for a new device. The submission is for administrative and labeling changes.

    However, I can extract information related to the device's characteristics and the basis for its substantial equivalence, which implicitly indicates its expected performance based on the predicate device.

    Here's a breakdown of what can and cannot be answered based on the provided text:

    1. A table of acceptance criteria and the reported device performance

    • Acceptance Criteria: Not explicitly stated as "acceptance criteria" for a new performance study. However, the "Technological Characteristics Comparison Table" (Table 1 on page 5) lists performance specifications that the device is expected to meet because it's identical to the predicate device. These characteristics essentially serve as the "performance" assumed to be met.
    • Reported Device Performance: The document states the device's characteristics are "Identical" to the predicate, K171626. Therefore, the performance values are the same as those established for the predicate device.
    CharacteristicAcceptance Criteria (from predicate)Reported Device Performance
    Intended UseSame as predicateIdentical
    ConstructionSame as predicateIdentical
    Sterile/Non-sterileNon-sterile (console), Sterile (catheters & CDTs)Identical
    Sterilization MethodEthylene OxideIdentical
    Sterilization Assurance Level10-6Identical
    UsageSingle Use (catheters & CDTs), Reusable (console)Identical
    Principle of Operation to Achieve CoolingVia pressurized liquid nitrogen (LN2)Identical
    Method to Destroy TissueUses freeze/thaw/freeze cycleIdentical
    Ability to Reach Equivalent DoseAchieve a 4 cm ice ball within 12 min (total elapsed time)Identical
    Point Source for Destruction of TissueCatheter headIdentical
    Liquid Nitrogen Capability to Freeze Tissue-196°CIdentical
    Output Temperature at Catheter Tip-196°CIdentical
    Equivalent Ice FormationAble to produce an average 23.4 mm (radius) ice ball within 5 minutesIdentical
    Equivalent Temperature Distribution@ freeze depth of 21.87mm at 0°C; -20°C isotherm at 15.5mm depth; -40°C isotherm at 11.8mm depthIdentical
    Delivery of CryogenA spray through a 2.2mm (7 F) sterile conduit; straight catheter, Controlled by userIdentical
    Consistent delivery of cryogen controlled for target siteComputer drivenIdentical
    Guidance required for procedureDirect visualization via an endoscope or bronchoscopeIdentical
    Safety Features/MitigationsStop dose via foot pedal/emergency button; compatible catheter check (RFID); audible beeper/visual timer; computerized system test/monitoring/abortIdentical
    Ensure patient is not exposed to high pressure gasesUses active suction pump and CDT, or natural orifice, as per IFU; venting guidanceIdentical
    Protect healthy tissue from excessive temperaturesUses endoscope/bronchoscope for insulation; insulation outside of scopeIdentical
    Pressure ControlsValves and pressure transducer for LN2 pressure control; redundant pressure switch; mechanical reliefIdentical
    Thermal/DefrostActive defrost using warm Nitrogen gasIdentical
    Safe storage of cryogenic agentSingle Dewar tankIdentical
    BiocompatibilityPatient contact materials comply with ISO -10993Identical

    2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    • Not applicable / Not provided. The document states "No performance testing was conducted." Therefore, there is no test set, sample size, or data provenance from a new study to report.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

    • Not applicable / Not provided. No new performance study was conducted that would require expert-established ground truth.

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

    • Not applicable / Not provided. No new performance study was conducted.

    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 / Not provided. This device is a cryosurgical tool, not an AI/imaging diagnostic device. No MRMC study was mentioned or performed for this submission.

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

    • Not applicable / Not provided. This is a hardware device, not an algorithm. No standalone algorithm performance was assessed for this submission.

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

    • Not applicable / Not provided. No new performance study requiring ground truth establishment was conducted for this submission. The basis for safety and effectiveness is substantial equivalence to the predicate device, which would have had its performance and safety established through prior testing and clinical use.

    8. The sample size for the training set

    • Not applicable / Not provided. No machine learning or AI model development is described, so there is no training set mentioned.

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

    • Not applicable / Not provided. No machine learning or AI model development is described, so there is no training set or ground truth establishment for it.

    In summary, this 510(k) submission is for administrative and labeling changes for a cryosurgical system and explicitly states that no new performance testing was conducted. Therefore, the detailed information about acceptance criteria, study design, and ground truth establishment requested for a performance study is not available within the provided document. The device's performance is assumed to be identical to its predicate, K171626, based on the lack of changes affecting performance.

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