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510(k) Data Aggregation

    K Number
    K210541
    Date Cleared
    2021-08-06

    (163 days)

    Product Code
    Regulation Number
    870.1650
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    ulrichINJECT CT motion

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

    ulrichINJECT CT motion is a contrast media management system that is indicated for the controlled, automatic administration, on the venous side, of contrast media and saline (NaCl), to human subjects undergoing diagnostic examinations in computed tomography (CT) applications.

    ulrichINJECT CT motion is specifically indicated for use in CT procedures for the delivery of Omnipaque™ (lohexol) Injection, solution - GE Healthcare Inc. contrast media as supplied in Imaging Bulk Packages (IBP), Omipaque™ (lohexol) Injection, solution - GE Healthcare Inc., and Visipaque™ (lodixanol) Injection, solution - GE Healthcare Inc. contrast media as supplied in single dose bottles.

    Pump Tubing-Flex is used for a maximum time of twenty four (24) hours. When used with Omnipaque™ IBP, Omnipaque™ single dose bottles, or Visipaque™ single dose bottles, a maximum of 19 bottles of contrast media can be used or maximum time of twenty four (24) hours of Pump Tubing-Flex, or whichever comes first. Time per contrast media or saline container depends on each contrast media's or saline's use time expiration with a maximum of eight (8) hours per contrast media or saline container.

    Spike for CT disposable is for single-bottle use only and must be discarded with the media container. The Patient tubing must be discarded after each patient procedure.

    SYNCopen is indicated for the specific purpose of allowing an injector to interface with a CT scanner.

    RIS/PACS is indicated for the specific purpose of allowing an injector to interface with a Radiological Information System (RIS) and a Picture Archiving and Communications System (PACS).

    ulrichINJECT CT motion is to be used only by and under quasi-continuous supervision of trained healthcare professionals in an appropriate licensed healthcare facility, in a room designated for radiological procedures that involve intravasular administration of contrast agent.

    Device Description

    ulrichINJECT CT motion is a syringeless contrast media management system that is designed for the controlled, automatic administration, on the venous side, of contrast media and saline, to human subjects undergoing diagnostic examinations in computed tomography (CT) applications.

    The ulrichINJECT CT motion system consists of the CT motion terminal, CT motion injector, and the CT motion tubing system. The CT motion tubing system is the only component that comes in contact with the patient and has indirect contact with the blood path of a patient for a limited duration (few minutes). The CT motion tubing system consists of three components:

    • Spike for CT
    • Pump tubing-flex .
    • . Patient Tubing

    ulrichINJECT CT motion uses a peristaltic pump as part of the injector which is designed to transport the media fluid through the CT motion tubing system (spikes for CT, CT motion pump tubing-flex, and patient tubing for pump tubing-flex). The ulrichINJECT CT motion system is intended to be used with the following components that are not supplied with the system:

    • Multiple patient use saline containers, ●
    • . Omnipaque IBP contrast media containers,
    • Omnipaque single-dose contrast media bottles. ●
    • Visipaque single-dose contrast media bottles, and
    • Cannula. .

    The ulrichINJECT CT motion system is specifically indicated for use in CT procedures for the delivery of Omnipaque™ (lohexol) Injection, solution - GE Healthcare Inc. contrast media as supplied in Imaging Bulk Packages (IBP), Omnipaque™ (Iohexol) Injection, solution – GE Healthcare Inc., and Visipaque™ (iodixanol) Injection - GE Healthcare Inc. contrast media as supplied in single dose bottles.

    ulrichINJECT CT motion is equipped with multiple hardware and software controls that work together for the safe operation of the intended use of the device. Controls include air detectors, which are designed to detect air without direct contact with the medium, pressure controls to manage and regulate pressure inside the tubing system, and check valves to prevent backflow of media and avoid retrograde contamination.

    The ulrichINJECT CT motion is provided in three versions:

    • Mobile pedestal version ●
    • Ceiling version ●
    • Wall mounted version .

    The mobile pedestal version consists of the injector head and the injector base with rechargeable battery. The ceiling version and the wall-mounted version consist of the injector head, a fixed-height arm, and a movable arm.

    The software option SYNCopen is a new software and hardware option which allows a connection between the injector system and a validated CT scanner. Both systems can communicate with each other and thus synchronize time sequences. The software option is only available if the manufacturer of the CT scanner has enabled the connection to the injector system.

    The ulrich medical RIS/PACS Interface is a new software option supports transferring documentation-related parameters for a contrast media injection to healthcare IT systems. A worklist can be retrieved from a RIS server by means of the DICOM modality worklist information model. After selecting a patient from the worklist and performing the iniection, a comprehensive contrast media dose report is automatically transmitted to the configured PACS and/or Dose Reporting system.

    AI/ML Overview

    The FDA 510(k) Summary for the ulrichINJECT CT motion outlines a series of non-clinical tests to demonstrate that the device meets its performance criteria. While the acceptance criteria are implicitly stated through adherence to various international standards and specific thresholds (e.g., air detection limit, volume accuracy), they are not presented in a single, consolidated table with reported device performance. No clinical studies (MRMC or standalone based on expert consensus/pathology) were performed or referenced for this 510(k) submission, as the submission relies on demonstrating substantial equivalence to a predicate device through non-clinical testing.

    Here's a summary based on the provided text, addressing your specific points where information is available:

    1. Table of Acceptance Criteria and Reported Device Performance

    A consolidated table of acceptance criteria and reported device performance is not explicitly provided in the document. Instead, acceptance criteria are described as conformance to specific international standards and pre-defined thresholds for certain parameters. The reported performance is generally stated as "complies with the standard," "satisfactorily met," or "met the requirements of the pre-defined acceptance criteria."

    Acceptance Criteria CategorySpecific Acceptance Criteria (implicit or stated)Reported Device Performance
    SoftwareConformance with FDA's "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices" (2005); All acceptance criteria for installation qualification and operational and performance qualification.All acceptance criteria for installation qualification and operational and performance qualification are satisfactorily met.
    Electromagnetic Compatibility / Electrical SafetyConformance with IEC 60601-1:2012 (Edition 3.1) and IEC 60601-1-2:2014 (Edition 4.0).The ulrichINJECT CT motion complies with the listed standards.
    SterilizationSterility Assurance Level (SAL) of $10^{-6}$ in accordance with ISO 11135-1:2007.Verification results indicate that the ulrichINJECT CT motion tubing system complies with the standard.
    Shelf-LifeConformance with ISO 11607-1:2006 for packaging; maintenance of integrity for a specified duration.Verification results indicate compliance for a shelf life of 5 years.
    Chemical CompatibilityNo interaction with Omnipaque™ or Visipaque™; chemical integrity of contrast media not compromised.The ulrichINJECT CT motion tubing system does not interact with Omnipaque™ or Visipaque™; chemical integrity of contrast media is not compromised.
    Contamination ControlMaintain sterility of injection media; resist ingress of microorganisms; residuals between compounds within defined limits after rinsing.Maintains sterility, resists ingress of microorganisms, and residuals are within defined limits.
    BiocompatibilityConformance with ISO 10993-1:2009 for indirect patient contact materials.Materials comply with the standard (based on cytotoxicity, intracutaneous reactivity, allergic sensitization, systemic acute toxicity, pyrogen shelf-life, hemocompatibility, LAL test).
    Extractables and LeachablesMet requirements of pre-defined acceptance criteria for intended uses.Testing and toxicological assessment demonstrated that the device is safe and effective and met the requirements.
    Human FactorsNo new unacceptable usability risks introduced by modifications; intended user population able to perform tasks.No new unacceptable usability risks were introduced; intended user population is able to perform use tasks.
    Performance - BenchConformance with applicable requirements of ISO 8536-4:2010; confirmation that mixing of contrast media will not occur.The ulrichINJECT CT motion tubing system conforms to its predetermined specifications and applicable standards.
    Technical Detection Limit of Air in Tubing0.05 mL0.05 mL
    Air Detector Alarm Limit1 mL1 mL
    Occlusion Detection Alarm Limit246 PSI246 PSI
    Volume Accuracy$\pm 5%$ for 10-200 mL of contrast media$\pm 5%$
    Flow Rate Accuracy$\pm 5%$$\pm 5%$

    2. Sample Size for the Test Set and Data Provenance

    The document explicitly states that non-clinical testing (bench testing, software verification and validation, EMC testing, sterilization validation, shelf-life studies, chemical compatibility, contamination control, biocompatibility, extractables/leachables, and human factors) was performed.

    • No "test set" in the context of clinical images or patient data is mentioned because this is a medical device for contrast media administration, not an imaging AI diagnostic device.
    • The tests mentioned are primarily laboratory or simulated use tests. Therefore, there is no direct information on a "sample size for the test set" as would be applicable to an AI diagnostic device evaluating patient data.
    • Data Provenance: Not applicable in the context of clinical data. The studies are primarily engineering validation and verification tests.

    3. Number of Experts and Qualifications for Ground Truth

    • Not applicable. Since this is a submission for a contrast media injector device and not an AI diagnostic tool requiring image interpretation or disease detection, there is no mention of experts establishing a "ground truth" for a test set of patient data. The "ground truth" for the tests performed relates to engineering specifications, safety standards, and functional performance.

    4. Adjudication Method for the Test Set

    • Not applicable. As there is no "test set" requiring expert interpretation or consensus for clinical ground truth, no adjudication method is mentioned.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    • No. The document does not describe any MRMC comparative effectiveness study. The device is a contrast media injector, and the submission focuses on its technical and functional equivalence and safety, not on improving human reader performance in interpreting medical images.

    6. Standalone (Algorithm Only Without Human-in-the-Loop) Performance

    • Yes, implicitly. All the non-clinical tests described (software validation, EMC, sterilization, shelf-life, chemical compatibility, contamination control, biocompatibility, extractables/leachables, and performance bench tests) are evaluations of the device's inherent functional performance without human intervention in the loop of the test itself. The "Human Factors" study assessed the user interaction with the device, but the core performance criteria were evaluated without human interaction during the test.

    7. Type of Ground Truth Used

    The "ground truth" for the various non-clinical tests described is based on:

    • Technical Specifications: Pre-defined design requirements for flow rate accuracy, volume accuracy, alarm limits (air, occlusion).
    • International Standards: Adherence to standards like IEC 60601-1, IEC 60601-1-2, ISO 11135-1, ISO 11607-1, ISO 10993-1, ISO 8536-4.
    • Safety and Efficacy Assessments: Demonstrating no adverse interactions with contrast media, maintaining sterility, preventing contamination, and ensuring biocompatibility.
    • Usability Objectives: Confirmation that intended users can safely and effectively operate the device.

    8. Sample Size for the Training Set

    • Not applicable. This submission is for a medical device (contrast media injector), not an AI algorithm that would require a "training set" of data for machine learning. The software mentioned is control software, verified and validated against functional requirements.

    9. How the Ground Truth for the Training Set was Established

    • Not applicable. As there is no AI algorithm training set, there is no ground truth established for such a set. The "ground truth" for the device's control software functionality would be its design specifications, regulatory requirements, and established safety and performance parameters.
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    K Number
    K192872
    Date Cleared
    2020-07-02

    (268 days)

    Product Code
    Regulation Number
    870.1650
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    ulrichINJECT CT Motion

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

    ulrichINJECT CT motion is a contrast media management system that is indicated for the controlled, automatic administration, on the venous side, of contrast media and saline (NaCI), to human subjects undergoing diagnostic examinations in computed tomography (CT) applications.

    ulrichINJECT CT motion is specifically indicated for use in CT procedures for the delivery of Omnipaque™ (lohexol) Injection, solution - GE Healthcare Inc. contrast media as supplied in Imaging Bulk Packages (IBP), Omnipaque™ (Iohexol) Injection, solution - GE Healthcare Inc., and Visipaque™ (iodixanol) Injection - GE Healthcare Inc. contrast media as supplied in single dose bottles.

    Pump tubing-flexis used for a maximum time of twenty four (24) hours. When used with Omnipaque™ IBP, Omnipaque™ single dose bottles, or Visipaque™ single dose bottles, a maximum of 19 bottles of contrast media can be used or maximum time of twenty four (24) hours of Pump tubing-flex, or whichever comes first. Time per contrast media or saline container depends on each contrast media's or saline's use time expiration with a maximum of eight (8) hours per contrast media or saline container.

    Spike for CT disposable is for single-bottle use only and must be discarded with the media container. The Patient tubing must be discarded after each patient procedure.

    ulrichINJECT CT motion is to be used only by and under quasi-continuous supervision of trained healthcare professionals in an appropriate licensed healthcare facility, in a room designated for radiological procedures that involve intravascular administration of contrast agent.

    Device Description

    ulrichINJECT CT motion is a syringeless contrast media management system that is designed for the controlled, automatic administration, on the venous side, of contrast media and saline, to human subjects underqoing diagnostic examinations in computed tomography (CT) applications.

    The ulrichINJECT CT motion system consists of the CT motion terminal, CT motion injector and the CT motion tubing system. The CT motion tubing system is the only component that comes in contact with the patient and has indirect contact with the blood path of a patient for a limited duration (few minutes). The CT motion tubing system consists of three components:

    • . Spike for CT
    • . Pump tubing-flex
    • . Patient Tubing

    ulrichINJECT CT motion uses a peristaltic pump as part of the injector which is designed to transport the media fluid through the CT motion tubing system (spikes for CT, CT motion pump tubing-flex, and patient tubing for pump tubing-flex).

    The updated ulrichINJECT CT motion system is intended to be used with the following components that are not supplied with the system:

    • Multiple patient use saline containers, .
    • Omnipaque IBP contrast media containers, .
    • . Omnipaque single-dose contrast media bottles,
    • . Visipaque single-dose contrast media bottles, and
    • . Cannula.

    The updated ulrichINJECT CT motion system is specifically indicated for use in CT procedures for the delivery of Omnipaque™ (lohexol) Injection, solution - GE Healthcare Inc. contrast media as supplied in Imaging Bulk Packages (IBP), Omnipaque™ (Iohexol) Injection, solution - GE Healthcare Inc., and Visipaque™ (iodixanol) Injection - GE Healthcare Inc. contrast media as supplied in single dose bottles.

    ulrichINJECT CT motion is equipped with multiple hardware and software controls that work together for the safe operation of the intended use of the device. Controls include air detectors, which are designed to detect air without direct contact with the medium, pressure controls to manage and regulate pressure inside the tubing system, and check valves to prevent backflow of media and avoid retrograde contamination.

    The ulrichINJECT CT motion is provided in three versions:

    • . Mobile pedestal version
    • Ceiling version ●
    • Wall mounted version ●
    AI/ML Overview

    This document describes the ulrichINJECT CT motion, a syringeless contrast media management system for CT applications. The submission to the FDA (K192872) is seeking to market the device as substantially equivalent to a previously cleared version (K171392). The main changes mentioned are the support for additional contrast media (Omnipaque single dose and Visipaque single dose) and a new Li-ion battery option.

    Here's an analysis of the acceptance criteria and study information provided:

    Acceptance Criteria and Reported Device Performance

    The document does not explicitly present a table of acceptance criteria with corresponding performance metrics in a clear, concise format. Instead, it details various non-clinical tests performed and states that the device "complies with the standards listed" or "met the requirements of the pre-defined acceptance criteria."

    Therefore, I will extrapolate the acceptance criteria and performance based on the described tests and the "Comparison" column in the detailed comparison table, where the subject device is deemed "identical" or "equivalent" to the predicate.

    Extrapolated Acceptance Criteria and Reported Device Performance (Based on "Comparison" and "Non-Clinical Testing" sections):

    Acceptance Criteria CategoryPerformance Criterion (Extrapolated)Reported Device Performance (Summary from document)
    Indications for UseBe indicated for controlled, automatic administration of contrast media and saline on the venous side for CT applications. Support Omnipaque™ IBP, Omnipaque™ single dose, and Visipaque™ single dose. Maintain specified tubing use times (Pump tubing-flex 24 hours, Patient tubing per patient, Spike for CT single bottle).Met. Intended use and indications are identical to predicate, with the addition of Omnipaque single dose and Visipaque single dose, which are stated not to affect intended use or safety/effectiveness. Tubing use times are identical to predicate.
    System ComponentsInjector Head, Touch Terminal, Injector Base, Wall Mount, Ceiling Mount, Contrast Media Housing with Heater, and specified disposables (Pump Tubing-flex, Patient Tubing, Spike for CT) must be present and function as per predicate.Met. System components and disposables are identical to the predicate (K171392).
    Physical DesignWeight, dimensions, and power requirements must be identical to predicate.Met. Weight, dimensions, and power requirements are identical to predicate.
    BatteryNew Li-Ion battery must not affect intended use, safety, or effectiveness.Met. The new Li-Ion battery option is a difference from the predicate but is stated not to affect the intended use, safety, or effectiveness of the device. (Implies testing was done to confirm this, though specific results aren't detailed in the table).
    Display TypeColor LCD Terminal with touch screen.Met. Identical to predicate.
    Operational CharacteristicsSyringeless system, remote operation via Touch Terminal, single-patient use disposable (Patient Tubing), prevention of reusable disposables via software, rotary peristaltic pump, administration of contrast media and saline, use of spikes for media containers.Met. All operational characteristics are identical to the predicate.
    Safety MechanismsMulti-layered software stops, used Patient Tubing/Pump Tubing-flex detectors, volume remaining readout (if programmed > remaining), programmable pressure limit (195 PSI), safety feature against reuse of patient tubing and spikes.Met. All safety mechanisms are identical to the predicate.
    Injection Capabilities40 phases per protocol. Injection rates for contrast media and saline (0.1 mL/s to 10.0 mL/s). Injection volume (1-200 mL contrast, 400 mL total media per patient). Injection pause (0-999 sec). Injection protocol storage. Priming/Venting Rate (2 mL/s manual).Met. All injection capabilities are identical to the predicate.
    Flow Rate and Volume AccuracyVolume accuracy of ± 5% for 10-200 mL contrast media. Flow rate accuracy of ± 5%.Met. Identical to predicate.
    Compatible Contrast MediaMust be compatible with Omnipaque™ IBP, Omnipaque™ single dose, and Visipaque™ single dose, without compromise to chemical integrity.Met. Chemical compatibility testing concluded the system does not interact with Omnipaque™ or Visipaque™, and their chemical integrity is not compromised. This difference from the predicate was addressed with contamination control, extractables/leachables studies, and bench testing.
    Contrast Media Container VolumeSystem supports 500 mL (OMNIPAQUE™ IBP), 100 mL and 150 mL (VISIPAQUE™ single dose), 150 mL (OMNIPAQUE™ single dose).Met. Equivalent to predicate; additional volumes for Omnipaque and Visipaque addressed with a process simulation study.
    Air DetectionUltrasound principle. Technical detection limit of air in tubing 0.05 mL. Air detector alarm limit 1 mL.Met. Identical to predicate.
    Occlusion DetectionFail-safe piezo-resistive pressure sensor principle. Occlusion detection alarm limit 246 PSI.Met. Identical to predicate.
    SterilizationEtO sterilization to a sterility assurance level of 10-6 in accordance with ISO 11135-1. Packaging validated per ISO 11607-1.Met. Verification results indicate compliance with ISO 11135-1 and ISO 11607-1.
    Shelf-LifeReal-time and accelerated aging studies confirm specified shelf-life.Met. Additional real-time aging shelf-life data provided for this submission. The ulrichINJECT CT motion tubing system's packaging was validated per ISO 11607-1.
    Contamination ControlAbility to maintain sterility and resist microorganism ingress with Omnipaque IBP, Omnipaque single dose, and Visipaque single dose. Residuals between active compounds within defined limits after rinsing.Met. Studies (Process Simulation, Microbial Ingress, Cross Contamination, Rinsing) concluded the device maintains sterility and resists ingress with the listed contrast media, and residuals are within defined limits.
    BiocompatibilityIndirect patient contact materials verified per ISO 10993-1, including tests for cytotoxicity, intracutaneous reactivity, allergic sensitization, systemic acute toxicity, pyrogens, hemocompatibility (hemolysis), and LAL test.Met. Verification results indicated compliance with ISO 10993-1 for the listed tests.
    Extractables and LeachablesTesting and toxicological assessment demonstrate safety and effectiveness for intended uses, meeting pre-defined acceptance criteria for Omnipaque and Visipaque.Met. Testing for extractables and leachables for VISIPAQUE, along with a toxicological assessment, met pre-defined acceptance criteria, demonstrating safety and effectiveness. (OMNIPAQUE testing was previously done for K171392).
    Performance - BenchConformance to predetermined specifications and applicable standards (e.g., applicable requirements from ISO 8536-4). Confirmation that mixing of contrast media will not occur.Met. Testing confirmed conformance to specifications and applicable standards. Additional verification testing confirmed no mixing of contrast media. Transport validation and cleaning instructions validation were also performed.
    Software ValidationConformance with established performance criteria through Installation Qualification and Operational/Performance Qualification, following FDA guidance "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices; Guidance for Industry and FDA Staff" (2005).Met. Software V&V was repeated for updates, following FDA guidance. IQ and O/PQ criteria were met, and the software was released for intended use.
    Electromagnetic Compatibility / Electrical SafetyConformance with IEC 60601-1 and related collateral standards (e.g., IEC 60601-1-2 4th edition).Met. Testing results indicate compliance with IEC 60601-1, IEC 60601-1-2 (4th edition).

    Study Information:

    The provided document describes a 510(k) submission (K192872) for the ulrichINJECT CT motion system. This is a premarket notification for a medical device seeking to demonstrate substantial equivalence to a predicate device (K171392), rather than prove de novo safety and effectiveness through extensive clinical trials. Therefore, the "studies" described are primarily non-clinical verification and validation activities.

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

    • Test Set Sample Size:

      • For physical components and engineering performance (Flow Rate, Volume Accuracy, Pressure Limits, Air Detection, etc.): The document does not specify a numerical sample size for bench tests. It refers to "verification testing" and "additional verification testing," implying that a sufficient number of tests were conducted to confirm performance parameters against established specifications and standards.
      • For chemical compatibility, contamination control, biocompatibility, and extractables/leachables: These tests typically involve a sample of the device materials and exposure to the specified substances or conditions, but a specific number is not provided.
      • For software validation: No specific number of test cases or iterations is provided, but it states "Validation included an installation qualification and an operational / performance qualification."
    • Data Provenance: The studies are non-clinical (bench testing, lab studies). The country of origin of the data is not explicitly stated, but the submitter (ulrich GmbH & Co. KG) is located in Germany. These studies are prospective in the sense that they were conducted specifically for this submission to address the changes and confirm substantial equivalence.

    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. For this type of non-clinical, engineering, and laboratory-based verification and validation, "ground truth" as established by human experts (like radiologists) is not the primary method. Instead, "ground truth" is typically defined by:
      • Established engineering specifications and performance targets.
      • International and national consensus standards (e.g., ISO, IEC).
      • Regulatory guidance documents (e.g., FDA software guidance).
      • Pre-defined acceptance criteria derived from these specifications and standards.
      • Laboratory analysis results (e.g., chemical assays, microbiological cultures, physical measurements).

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

    • Not applicable. Adjudication methods like 2+1 (two readers plus one adjudicator) are used in clinical studies involving human interpretation or subjective assessments. The studies presented here are non-clinical verification and validation tests, where results are typically objectively measured against predefined criteria.

    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

    • No, an MRMC comparative effectiveness study was not done. This device is an angiographic injector, a hardware-based system for delivering contrast media, not an AI software intended for image interpretation or diagnosis. Therefore, MRMC studies and AI assistance metrics are not relevant to this submission.

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

    • Not applicable. This device is a physical injector system with embedded software, not a standalone algorithm or AI software. Its performance is inherent to its mechanical and electronic function, although the software controls are crucial for its operation. The performance described is "algorithm only" in the sense that it's the device's intrinsic mechanical/software behavior being tested, but not an AI algorithm performing a diagnostic task.

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

    • The "ground truth" for the non-clinical studies relies on:
      • Engineering specifications and design requirements: For physical dimensions, weights, power, injection rates, volumes, accuracies, and programmable limits.
      • Consensus standards: Such as ISO 11135-1 (sterilization), ISO 11607-1 (packaging), ISO 10993-1 (biocompatibility), IEC 60601-1/60601-1-2 (electrical safety, EMC), and applicable parts of ISO 8536-4 (infusion equipment).
      • Laboratory test results: For chemical compatibility, extractables and leachables (chemical analysis), and contamination control (microbiological assays).
      • Software validation protocols: Defining expected behavior and outputs.

    8. The sample size for the training set

    • Not applicable. This device does not use machine learning or AI that requires a "training set" of data in the conventional sense. The software validation refers to qualification, not machine learning model training.

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

    • Not applicable. As there is no machine learning "training set," there is no "ground truth" established for it.
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    K Number
    K171392
    Date Cleared
    2017-11-09

    (182 days)

    Product Code
    Regulation Number
    870.1650
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    ulrichINJECT CT motion

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

    ulrichINJECT CT motion is a contrast media management system that is indicated for the controlled, automatic administration, on the venous side, of contrast media and saline (NaCl), to human subjects undergoing diagnostic examinations in computed tomography (CT) applications.

    ulrichINJECT CT motion is specifically indicated for use in CT procedures for the delivery of Omnipaque™ (lohexol) Injection, solution - GE Healthcare Inc. contrast media as supplied in Imaging Bulk Packages (IBP).

    Pump tubing-flex is used for a maximum time of twenty four (24) hours. When used with Omnipaque™ IBP, a maximum of 19 bottles of contrast media can be used or maximum time of twenty four (24) hours of Pump tubing-flex, or whichever comes first, with a maximum of eight (8) hours per contrast media or saline container.

    Spike for CT disposable is for single-bottle use only and must be discarded with the media container. The Patient tubing must be discarded after each patient procedure.

    ulrichINJECT CT motion is to be used only by and under quasi-continuous supervision of trained healthcare professionals in an appropriate licensed healthcare facility, in a room designated for radiological procedures that involve intravascular administration of contrast agent.

    Device Description

    ulrichINJECT CT motion is a syringeless contrast media management system that is designed for the controlled, automatic administration, on the venous side, of contrast media and saline, to human subjects undergoing diagnostic examinations in computed tomography (CT) applications.

    The ulrichINJECT CT motion system consists of the CT motion terminal, CT motion injector and the CT motion tubing system.

    ulrichINJECT CT motion uses a peristaltic pump as part of the injector which is designed to transport the media fluid through the CT motion tubing system (spikes for CT, CT motion pump tubing-flex and patient tubing for pump tubing-flex).

    The only component of the ulrichINJECT CT motion that comes in contact with the patient is the ulrichINJECT CT motion tubing system. The tubing system consists of three components:

    • . Spike for CT
    • Pump tubing-flex .
    • . Patient Tubing

    The ulrichINJECT CT motion tubing system has indirect contact with the blood path of a patient for a limited duration (few minutes).

    The ulrichINJECT CT motion system is also intended to be used with the following components, which are not supplied with the system:

    • . Multiple patient use saline containers,
    • . Omnipaque™ IBP contrast media containers, and
    • . Cannula.

    ulrichINJECT CT motion is specifically indicated for use in CT procedures for the delivery of Omnipaque™ (lohexol) Injection, solution - GE Healthcare Inc. contrast media as supplied in Imaging Bulk Packages (IBP).

    ulrichINJECT CT motion is equipped with multiple hardware and software controls that work together for the intended use of the device. Controls include air detectors, which are designed to detect air without direct contact with the medium, pressure controls to manage and regulate pressure inside the tubing system, and check valves to prevent backflow of media and avoid retrograde contamination.

    The ulrichINJECT CT motion is provided in three versions:

    • Mobile pedestal version
    • . Ceiling version
    • Wall mounted version
    AI/ML Overview

    The document provided is a 510(k) Summary for the ulrichINJECT CT motion device, seeking substantial equivalence to a predicate device. It primarily focuses on comparing the new device to the predicate and listing non-clinical tests conducted to support its safety and performance.

    However, the document does not contain the specific information requested regarding acceptance criteria and a structured study demonstrating the device meets those criteria, as typically found in clinical evaluation reports or detailed performance studies for AI/software devices. The ulrichINJECT CT motion is a contrast media management system, a hardware device, not an AI or software device that would typically have the requested metrics (e.g., sensitivity, specificity, F1 score).

    Therefore, I cannot fulfill the request for information like:

    • A table of acceptance criteria and reported device performance (in the context of AI metrics).
    • Sample size used for the test set and data provenance.
    • Number of experts used to establish ground truth.
    • Adjudication method for the test set.
    • MRMC comparative effectiveness study.
    • Standalone performance.
    • Type of ground truth used.
    • Sample size for the training set.
    • How ground truth for the training set was established.

    The document explicitly states: "No clinical studies were performed using ulrichINJECT CT motion." (Page 18).

    Instead, the document details non-clinical testing performed to establish substantial equivalence to a predicate device, as summarized below:


    Acceptance Criteria and Study to Prove Device Meets Acceptance Criteria (Based on Non-Clinical Testing for Substantial Equivalence)

    The ulrichINJECT CT motion is a contrast media management system (a hardware device) that was evaluated for substantial equivalence primarily through non-clinical testing. The "acceptance criteria" here refer to compliance with various engineering standards and performance requirements demonstrated through bench testing and material compatibility studies, rather than AI-specific performance metrics. No clinical studies were performed.

    1. Table of Acceptance Criteria and Reported Device Performance

    Given the nature of the device (hardware medical device rather than an AI diagnostic tool), the "acceptance criteria" are compliance with established standards and demonstrated functional equivalence to a predicate device. The table below summarizes these and the reported performance.

    Category / StandardAcceptance Criteria (Implied by Compliance)Reported Device Performance (as stated in document)
    General PerformanceConformance with established performance criteria; controlled, automatic administration of contrast media and saline on the venous side. Safe and effective during diagnostic CT examinations."ulrichINJECT CT motion system and software were validated in accordance with a Verification & Validation plan to ensure conformance with established performance criteria." It is "indicated for the controlled, automatic administration, on the venous side, of contrast media and saline (NaCl), to human subjects undergoing diagnostic examinations in computed tomography (CT) applications."
    Electromagnetic Compatibility / Electrical SafetyCompliance with IEC 60601-1 and IEC 60601-2."Electromagnetic Compatibility / Electrical Safety testing was performed in accordance with... IEC 60601-1... IEC 60601-2..."
    SterilizationSterility Assurance Level of 10⁻⁶ (SAL 10⁻⁶) in accordance with ISO 11135-1."The ulrichINJECT CT motion tubing system is ethylene oxide (EtO) sterilized and was validated to a sterility assurance level of 10⁻⁶ in accordance with... ISO 11135-1... Verification results indicate that the ulrichINJECT CT motion tubing system complies with the standard."
    Shelf-Life & PackagingPackaging integrity and shelf-life validated in accordance with ISO 11607-1."ulrich performed real time aging and accelerating aging studies. The ulrichINJECT CT motion tubing system is sterilized and its packaging was validated in accordance with ISO 11607-1... Verification results indicate that the ulrichINJECT CT motion tubing system complies with the standard."
    Chemical CompatibilityNo interaction with Omnipaque™ (Iohexol) and chemical integrity of Omnipaque™ not compromised."material compatibility testing was performed using Omnipaque™ 350 mg//ml as the solvent. The results concluded that the ulrichINJECT CT motion tubing system does not interact with Omnipaque™ and the chemical integrity of Omnipaque™ is not compromised throughout use."
    Contamination ControlMaintain sterility of injection media and resist microorganism ingress when used with Omnipaque™ IBP."Based on these results, it has been concluded that ulrichINJECT CT motion has the ability to maintain the sterility of the injection media and resist the ingress of microorganisms when used with Omnipaque™ Imaging Bulk Package (IBP) during its intended use." (Studies included process simulation, microbial ingress, cross contamination).
    BiocompatibilityCompliance of indirect patient contact materials with ISO 10993-1."The ulrichINJECT CT motion tubing system indirect patient contact materials were verified in accordance with... ISO 10993-1... Verification results indicated that the materials comply with the standard."
    Performance - BenchApplicability to ISO 8536-4 (where relevant), capability to deliver contrast media and saline at prescribed rates and volumes for expected cannula ranges, acceptable pressure during operation with various cannulas and flow rates, acceptable levels of extractables and leachables, and successful transport validation."ulrichINJECT CT motion tubing system... evaluated the device pressure when using the device with multiple size cannulas at multiple flow rates and to demonstrate that the device is capable of delivering contrast media and saline at the prescribed rate and total volume for the expected range of cannulas." "Additional testing included extractables and simulation testing for leachable compounds and particulates. Transport validation and cleaning instructions validation was performed." "Test and verification results indicate that the ulrichINJECT CT motion tubing system conforms to its predetermined specifications and the applicable standards."
    Use within defined disposable time limitsThe differing time limits for disposables (Pump tubing-flex, Patient tubing, Spike for CT) compared to the predicate device must be supported by contamination control studies. (Pump tubing-flex: 24hrs; Patient Tubing: 12hrs; Spike for CT: 8hrs)"The differences in the time limits of the disposables components are addressed through the results of contamination control studies." "The differences in time limits between the ulrichINJECT CT motion and the predicate device are addressed with the completion of contamination control studies."
    Human Factors / UsabilityUsers can operate ulrichINJECT CT motion as the predicate device."Human Factors / Usability assessments were performed in a simulated use environment. The results demonstrated that users can operate ulrichINJECT CT motion as the predicate device."
    Functional Equivalence to Predicate Device (CT Expres 3D Contrast Media Delivery System)The ulrichINJECT CT motion should be equivalent in indications for use, overall design, and operating principles to the predicate device, with any differences not raising new questions of safety or effectiveness. Specific parameters like flow rates, volumes, pressure limits, air detection, etc., should be comparable or improved.The document provides a detailed comparison table (pages 6-7) indicating equivalence or similar performance for numerous parameters (e.g., syringeless system, remote operation, rotary peristaltic pump, administration of contrast/saline, disposable uses spikes, safety stop, volume readout, programmable pressure limit, injection capabilities, injection rates, injection volume, flow rate/volume accuracy, contrast media container volume, saline flush, needle size, injection pause, protocol storage, priming/venting rate, air detection, occlusion detection).

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

    This information is not applicable or not specified within the provided text. The testing conducted was primarily bench testing and simulated use, not clinical trials with human subjects or retrospective/prospective data analysis in the manner typically associated with AI/software performance studies. The provenance of the manufacturing entity is Germany (ulrich GmbH & Co. KG).

    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)

    This information is not applicable or not specified as the evaluation did not involve expert-labeled ground truth for a diagnostic task. The "ground truth" for the non-clinical tests was established by compliance with engineering standards and predefined performance specifications.

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

    This information is not applicable or not specified because the testing described does not involve human adjudication of results in the context of diagnostic performance.

    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 ulrichINJECT CT motion is a hardware device for administering contrast media, not a diagnostic AI system intended to assist human readers.

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

    This information is not applicable as the device is a hardware system, not a standalone algorithm. Its performance is inherent in its electromechanical operation and tubing system.

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

    For the non-clinical testing, the "ground truth" was based on:

    • Compliance with recognized standards: e.g., ISO, IEC standards for sterility, biocompatibility, electrical safety, etc.
    • Engineering specifications: predefined operational ranges for flow rate, volume accuracy, pressure limits, air detection, etc.
    • Chemical and microbiological tests: laboratory measurements to confirm material compatibility, absence of contamination, and sterility.

    8. The sample size for the training set

    This information is not applicable. The ulrichINJECT CT motion is a hardware device and does not involve AI/machine learning training sets.

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

    This information is not applicable as there is no training set for an AI/machine learning model.

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