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510(k) Data Aggregation
(60 days)
ulricheasyINJECT Max 2M (XD 10140); ulricheasyINJECT Max 3 (XD 10150); ulricheasyINJECT Max 3 (XD 10180
ulricheasyINJECT Max 2M (XD 10140) / 3 (XD 10150) 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 magnetic resonance (MR) applications.
ulricheasyINJECT Max 2M / 3 (XD 10140 / XD 10150) is specifically indicated for use in MRI procedures for the delivery of Clariscan (Gadoterate Meglumine) Injection - GE Healthcare Inc., Gadavist (gadobutrol) Injection - Bayer HealthCare Pharmaceuticals Inc., VUEWAY™ (gadopiclenol) – Bracco Diagnostics, Inc., MultiHance (gadobenate dimeglumine) - Bracco Diagnostics, Inc., and Gadobutrol Injection - Fresenius Kabi AG, contrast media as supplied in approved single dose bottles and Gadavist (gadobutrol) Injection - Bayer HealthCare Pharmaceuticals Inc. and Gadobutrol Injection - Fresenius Kabi AG, contrast media as supplied in approved Imaging Bulk Packages (IBPs).
ulricheasyINJECT Max 3 (XD 10180) 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 magnetic resonance (MR) applications.
ulricheasyINJECT Max 3 (XD 10180) is specifically indicated for use in MRI procedures for the delivery of VUEWAY™ (gadopiclenol) Injection - Bracco Diagnostics, Inc., MultiHance (gadobenate dimeglumine) - Bracco Diagnostics, Inc., Clariscan™ (Gadoterate Meglumine) Injection - GE Healthcare Inc., Dotarem® (gadoterate meglumine) Injection -Guerbet, LLC, Gadavist™ (gadobutrol) Injection - Bayer HealthCare Pharmaceuticals Inc., and Gadobutrol Injection -Fresenius Kabi AG, contrast media as supplied in approved single dose vials and Gadavist™ (gadobutrol) Injection -Bayer HealthCare Pharmaceuticals Inc. and Gadobutrol Iniection - Fresenius Kabi AG. contrast media as supplied in approved Imaging Bulk Packages (IBPs).
ulricheasyINJECT Max is a syringeless contrast media management system that is designed for the controlled, automatic venous administration of contrast media in conjunction with physiological saline solution to human subjects undergoing diagnostic examinations in Magnetic Resonance Imaging (MRI or PET MRI).
The ulricheasyINJECT Max device consists of a terminal, injector, and tubing system. The injector is a mobile pedestal device that consists of an injector base with rechargeable battery. The 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 tubing system consists of the following three components:
- Spikes,
- Easy-Click-Cassette flex
- Patient Tubing
The ulricheasyINJECT Max uses a peristaltic pump as part of the injector which is designed to transport the media fluid through the tubing system (spikes, cassette, and patient tubing). ulricheasyINJECT Max is intended to be used with the following components that are not supplied with the system:
- Saline containers.
- Single-dose contrast media bottles,
- IBP contrast media containers, and
- Cannula.
ulricheasyINJECT Max is equipped with multiple hardware and software controls that work together for the safe operation of the intended use of the system. Controls include air detectors to detect the presence of air in the tubing system 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 ulricheasyINJECT Max is provided in three models:
- ulricheasyINJECT Max 2M (XD 10140),
- ulricheasylNJECT Max 3 (XD 10150), and
- ulricheasylNJECT Max 3 (XD 10180).
The Max 3 models have 3 media connection points: 1 NaCl and 2 Contrast Media connections. The Max 2M has 2 media connection points: 1 NaCl and 1 Contrast Media connections. Max 2M and Max 3 are technically identical except the different available media connection points.
The provided text describes a 510(k) premarket notification for the ulricheasyINJECT Max contrast media management system, which primarily references a previously cleared predicate device (K233737) for most of its acceptance criteria and supporting studies. The information available focuses on the differences between the current device and its predicate.
Here's a breakdown of the requested information based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly present a table of "acceptance criteria" with quantitative targets alongside "reported device performance" in a separate column. Instead, it describes various non-clinical tests conducted for the predicate device (K233737) and states that the subject device (ulricheasyINJECT Max) supports a broader range of contrast media, with additional testing performed to address this difference.
The following table summarizes the performance characteristics and states of verification for the device and its predicate:
Characteristic | Acceptance Criteria (Implied) | Reported Device Performance (as stated in the document) |
---|---|---|
Software | Conformance with established performance criteria. | Software verification and validation performed as part of K233737, and repeated for software updates for the current submission. |
EMC / Electrical Safety | Adherence to IEC 60601-1:2005, AMD 1:2012, AMD 2:2020 and ANSI AAMI ES60601-1:2005/(R)2012 & A1:2012, C1:2009/(R)2012 & A2:2010/(R)2012. | Testing performed in accordance with the specified standards as part of K233737. |
Sterilization Validation | Sterility assurance level of 10-6. | Validated to a sterility assurance level of 10-6 as part of K233737 (Ethylene Oxide). |
Shelf Life & Transport | Packaging integrity and functional stability over time and through transport. | Real-time and accelerated aging studies performed as part of K233737. Transport validation performed on tubing system, injector, and terminal as part of K233737. |
Chemical Compatibility | Material compatibility with specified contrast media. | Additional Chemical Compatibility testing performed for the current submission to support new contrast media (Gadobutrol single dose bottle, Gadavist™ (gadobutrol) IBP, Gadobutrol IBP). Previous testing done for K233737. "The safety and effectiveness of the ulricheasyINJECT Max has been confirmed through contamination control testing, chemical compatibility testing, and extractables and leachables testing." |
Contamination Control | Ability to prevent microbial ingress and cross-contamination; residuals within defined limits after rinsing. | Microbial ingress study demonstrated ability to prevent ingress during use. Cross-contamination study demonstrated effectiveness in preventing contamination. Rinsing study demonstrated residuals within defined limits. (All performed as part of K233737). |
Biocompatibility | Compliance with ISO 10993-1. | Verification results indicated compliance with ISO 10993-1 as part of K233737 for indirect patient contact materials. |
Performance – Bench | Conformance to predetermined specifications and applicable standards (ISO 8536-4 for applicable requirements). | Test and verification results indicated that the ulricheasyINJECT Max tubing system conforms to its predetermined specifications and the applicable standards (performed as part of K233737). |
Extractables & Simulation | Leachable compounds within acceptable limits. | Testing included extractables and simulation testing for leachable compounds as part of K233737. |
Human Factors / Usability | Safe and effective for use by intended users. | Usability study performed as part of K233737 to confirm that the ulricheasyINJECT Max is safe and effective for use by its intended users. |
Flow Rate Accuracy | ± 5% | ± 5% (Same as predicate, implied validation via K233737 non-clinical testing). |
Volume Accuracy | ± 5% (for 10-400 mL) | ± 5% (for 10-400 mL of contrast media; Same as predicate, implied validation via K233737 non-clinical testing). |
Technical Detection Limit of Air in Tubing | 0.05 mL | 0.05 mL (Same as predicate, implied validation via K233737 non-clinical testing). |
Air Detector Alarm Limit | 1 mL | 1 mL (Same as predicate, implied validation via K233737 non-clinical testing). |
Occlusion Detection Alarm Limit | 203 PSI | 203 PSI (Same as predicate, implied validation via K233737 non-clinical testing). |
2. Sample size used for the test set and the data provenance
- Sample Size: The document does not specify exact sample sizes for each test set. It mentions "studies" and "testing" without providing numerical details for the number of units or data points tested in non-clinical assessments.
- Data Provenance: All non-clinical testing (Software, EMC/Electrical Safety, Sterilization Validation, Shelf Life and Transport Validation, Contamination Control and Rinsing, Biocompatibility, Performance – Bench, Extractables and Simulation, Human Factors / Usability) was performed as part of K233737, indicating it was conducted for the predicate device. Additional chemical compatibility testing was conducted for the current submission (K241850) to support new contrast media. The origin of the data (e.g., country) is not specified beyond being part of ulrich GmbH & Co. KG's submission, implying internal company testing. Studies are described as "non-clinical" and "bench," which means they are not human clinical trials.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable. The document discusses non-clinical bench testing, not image-based diagnostic performance involving expert readers establishing ground truth. The "Human Factors / Usability" study confirms the device's safety and effectiveness for its intended users (trained healthcare professionals), but it's not about expert clinical interpretation for a diagnostic algorithm.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. This type of adjudication method is used for establishing ground truth in diagnostic studies involving multiple human readers, which is not described in this document.
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 a contrast media management system, not an AI-powered diagnostic imaging tool. Therefore, MRMC studies are not relevant.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
Not applicable. This device is a physical medical device (an injector) with software controls, not an algorithm meant for standalone diagnostic performance.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
For non-clinical testing, "ground truth" generally refers to established scientific principles, engineering specifications, recognized industry standards (e.g., ISO, IEC), and predetermined specifications for the device's performance. For biocompatibility, it's compliance with ISO 10993-1. For sterilization, it's achieving a specified Sterility Assurance Level. For performance metrics like flow rate and volume accuracy, it's meeting the ±5% specification.
8. The sample size for the training set
Not applicable. The document refers to a physical medical device and its controls, not a machine learning model that requires a training set.
9. How the ground truth for the training set was established
Not applicable, as no training set for a machine learning model is mentioned.
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(149 days)
ulricheasyINJECT Max 2M (XD 10140); ulricheasyINJECT Max 3 (XD 10150); ulricheasyINJECT Max 3 (XD 10180
ulricheasyINJECT Max System Max 2M (XD 10140) and Max 3 (XD 10150) 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 magnetic resonance (MR) applications.
ulricheasyINJECT Max 2M / 3 (XD 10140 / XD 10150) is specifically indicated for use in MRI procedures for the delivery of Clariscan (Gadoterate Meglumine) Injection, - GE Healthcare Inc. contrast media as supplied in approved single dose bottles.
Easy-Click-Cassette – flex Max 2M and Easy-Click-Cassette – flex Max 3 are used for a maximum time of twenty four (24) hours or a maximum of 96 bottles of contrast media, or whichever comes first. Use time expiration per single dose contrast media container is a maximum of four (4) hours per contrast media container, unless otherwise stated by the contrast media labeling.
Spike for MRI 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.
ulricheasyINJECT Max 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.
The ulricheasyINJECT Max 2M / 3 (XD 10140 / XD 10150) is not intended for injection of contrast media (CM) for high-pressure angiography.
ulricheasyINJECT Max 3 (XD 10180) 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 magnetic resonance (MR) applications.
ulricheasyINJECT Max 3 (XD 10180) is specifically indicated for use in MRI procedures for the delivery of VUEWAY™ (gadopiclenol), - Bracco Diagnostics Inc, MultiHance (gadobenate dimeglumine) – Bracco Diagnostics, Inc, Clariscan™ (Gadoterate Meglumine) Injection, - GE Healthcare Inc., Dotarem® (gadoterate meglumine) Injection - Guerbet, LLC, and Gadavist™ (gadobutrol) Injection, - Bayer HealthCare Pharmaceuticals Inc., contrast media as supplied in approved single dose vials.
Easy-Click-Cassette - flex Max 3 is used for a maximum time of twenty four (24) hours or a maximum of 96 bottles of contrast media, or whichever comes first. Use time expiration per single dose contrast is a maximum of four (4) hours per contrast media container, unless otherwise stated by the contrast media labeling.
Spike for MRI 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.
ulricheasyINJECT Max 3 (XD 10180) 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.
The ulricheasyINJECT Max 3 (XD 10180) is not intended for injection of contrast media (CM) for high-pressure angiography.
ulricheasyINJECT Max is a syringeless contrast media management system that is designed for the controlled, automatic venous administration of contrast media in conjunction with physiological saline solution to human subjects underqoing diagnostic examinations in Magnetic Resonance Imaging (MRI or PET MRI).
The ulricheasyINJECT Max device consists of a terminal, injector, and tubing system. The injector is a mobile pedestal device that consists of an injector base with rechargeable battery. The 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 tubing system consists of the following three components:
- . Spikes,
- . Easy-Click-Cassette - flex
- . Patient Tubing
The ulricheasyINJECT Max uses a peristaltic pump as part of the injector which is designed to transport the media fluid through the tubing system (spikes, cassette, and patient tubing), ulricheasylNJECT Max is intended to be used with the following components that are not supplied with the system:
- Saline containers,
- Single-dose contrast media bottles, and .
- . Cannula.
ulricheasylNJECT Max is equipped with multiple hardware and software controls that work together for the safe operation of the intended use of the system. Controls include air detect the presence of air in the tubing system 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 ulricheasyINJECT Max is provided in three models:
- . ulricheasyINJECT Max 2M (XD 10140),
- . ulricheasyINJECT Max 3 (XD 10150), and
- . ulricheasyINJECT Max 3 (XD 10180).
The Max 3 models have 3 media connection points: 1 NaCl and 2 Contrast Media connections. The Max 2M has 2 media connection points: 1 NaCl and 1 Contrast Media connections. Max 2M and Max 3 are technically identical except the different available media connection points.
The ulricheasyINJECT Max system, a contrast media management system, underwent a comprehensive study to demonstrate its substantial equivalence to a predicate device, ulrichINJECT CT motion (K192872). The study focused on non-clinical testing to ensure its safety and effectiveness for its intended use in magnetic resonance (MR) applications.
1. Table of Acceptance Criteria and Reported Device Performance:
The document doesn't explicitly list "acceptance criteria" for each test in a numerical or pass/fail format. Instead, it states that "Verification results indicate that the ulricheasyINJECT Max tubing system complies with the standard" or "conforms to its predetermined specifications." The "Comparison" column in the Comparative Analysis table acts as a high-level summary of performance against the predicate.
Below is a table summarizing the areas tested and the reported performance based on the provided text:
Acceptance Criteria (Inferred) | Reported Device Performance |
---|---|
Conformance with established performance criteria for overall system and software. | Software verification and validation performed. |
Compliance with Electromagnetic Compatibility (EMC) and Electrical Safety standards (IEC 60601-1). | Complies with FDA recognized standard ANSI AAMI ES60601-1:2005/(R)2012 & A1:2012, C1:2009/(R)2012 & A2:2010/(R)2012 (Cons. Text) [Incl. AMD2:2021] Medical electrical equipment - Part 1: General requirements for basic safety and essential performance (IEC 60601-1:2005, MOD) [Including Amendment 2 (2021)]. |
Sterilization to a Sterility Assurance Level (SAL) of $10^{-6}$ and appropriate shelf life. | Validated to a SAL of $10^{-6}$ using Ethylene Oxide (EtO) according to ISO 11135:2014. Real-time and accelerated aging studies performed. |
Material compatibility with specified contrast media. | Chemical compatibility testing performed with Gadavist, Clariscan™, VUEWAY™, MultiHance, and Dotarem. Results support material compatibility. |
Maintenance of sterility of injection media and resistance to microbial ingress. | Microbial ingress study and cross-contamination study performed. Concluded that the system maintains sterility and resists ingress. Residuals between contrast media's active compounds after rinsing are within defined limits. |
Biocompatibility of indirect patient contact materials. | Verified in accordance with ISO 10993-1. Materials comply with the standard. |
Conformance to predetermined specifications and applicable standards for tubing system performance. | Tested for performance and verified in accordance with applicable requirements from ISO 8536-4:2010. Conforms to predetermined specifications and applicable standards. |
Absence of unacceptable leachable compounds. | Extractables and simulation testing for leachable compounds included. |
Safe and effective operation by users. | Human Factors / Usability assessments performed in a simulated use environment. Results demonstrated that users can operate ulricheasyINJECT Max as safely and effectively as the predicate device. |
(Differentiation from predicate that does not raise new safety/effectiveness concerns) | Extensive comparative analysis (Table in the document) highlights differences in indications for use (CT vs. MRI), environment of use (CT vs. MR), accessories, disposables, weight, dimensions, remaining volume readout, pressure limit, injection pause, priming/venting rate, air detection principle, occlusion detection alarm limit, time limit for disposables, patient tubing components, and tubing materials. For each difference, the document states: "This difference does not change the intended use of the device. The safety and effectiveness of the ulricheasyINJECT Max has been confirmed through [specific testing, e.g., MR compatibility testing, chemical compatibility testing, and Safety / EMC testing]". |
2. Sample Size Used for the Test Set and Data Provenance:
The document does not explicitly state the numerical sample sizes for the test sets used in the non-clinical studies (e.g., number of units tested for EMC, number of samples for chemical compatibility). It refers to the tests performed and their general outcomes.
The data provenance is from non-clinical testing performed by ulrich GmbH & Co. KG, for the purpose of a 510(k) premarket notification. This indicates the data is prospective in the context of device validation. The "country of origin of the data" is not explicitly stated but the submitter is based in Ulm, Germany.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications:
This information is not applicable as the described studies are non-clinical (bench testing, software validation, biocompatibility, etc.) and do not involve human readers or refer to "ground truth" in the context of expert review of clinical cases.
4. Adjudication Method for the Test Set:
This information is not applicable for the same reasons as point 3.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done:
No, an MRMC comparative effectiveness study was not done. The document describes non-clinical testing and comparison to a predicate device, not a study evaluating human reader performance with or without AI assistance.
6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done:
Yes, the studies described are analogous to standalone performance evaluation for the device's functional and safety aspects. The software and various physical parameters (e.g., flow rate accuracy, air detection) were tested independently of human intervention during the functional tests, demonstrating the device's inherent performance. Human Factors/Usability assessments considered human interaction but focused on the device design's safety and effectiveness, not the clinical performance of an algorithm.
7. The Type of Ground Truth Used:
For the non-clinical tests, the "ground truth" was established by recognized industry standards and predetermined specifications for device performance, safety, and material properties. Examples include:
- IEC 60601-1 for electrical safety and EMC.
- ISO 11135:2014 for sterilization.
- ISO 10993-1 for biocompatibility.
- ISO 8536-4:2010 (applicable requirements) for infusion equipment performance.
- Internal predetermined specifications for aspects like flow rate accuracy (± 5%), volume accuracy (± 5%), air detection limit (0.05 mL), and alarm limits.
8. The Sample Size for the Training Set:
This information is not applicable. The document describes a contrast media injector system, not an AI/ML algorithm that requires a separate training set. The "software verification and validation" refers to traditional software testing, not machine learning model training.
9. How the Ground Truth for the Training Set Was Established:
This information is not applicable as there is no mention of an AI/ML training set.
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