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The CRS Endoluminal Brush is intended to collect a biofilm or fibrin sample, which is suitable for microbiological analysis, from the inner lumen surface of an in-dwelling central venous catheter

The CRS Endoluminal Brush product line is an accessory to central venous catheters. Each single use Endoluminal Brush kit contains 2 pairs of latex free gloves, 1- 70% isopropyl alcohol cleaning agent, 1 fibrin brush in transport bag, 1- 10 cc syringe, 2 patient labels, 1 medical drape, 1 over wrap, and Instructions for Use. The brush consists of nylon bristles wound into a flexible stainless steel wire, which is further wound into a tubular, metal, rigid handle. The Brush is enclosed within a no ratiner would at the distal end and is attached to a standard luer lock at its proximal end. The luer lock fitting complies with catheter manufacturers' requirement that only luer-lock connections be used with catheters. The various CRS Endoluminal Brush products defined by the product codes differ mainly in the length of the flexible wire and the diameter of the Brush bristles.

The provided text describes a 510(k) submission for the "CRS Endoluminal Brush" (K050889), which claims substantial equivalence to the "FAS Endoluminal Brush" (K993614). The core of the submission argues that the new device is "identical" to the predicate device. Therefore, the device's "performance" is implicitly considered to be the same as the predicate, and the "study" is a comparison to the predicate rather than a new clinical trial with specific performance metrics.

Here's an analysis based on the provided documents:

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

The submission does not define explicit "acceptance criteria" in terms of specific performance metrics (e.g., sensitivity, specificity, accuracy) for the device's intended function (collecting biofilm or fibrin samples). Instead, the acceptance criterion appears to be the demonstrate substantial equivalence to a predicate device.

The reported device performance, therefore, is its alleged identicality to the predicate device.

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

The documents do not describe a specific "test set" or a clinical study conducted with human subjects or a defined sample size for the CRS Endoluminal Brush to evaluate its performance characteristics like sample collection efficacy.

The "testing" mentioned is bench and clinical testing to show the new device is "as safe and effective as the predicate devices," but specific details on sample sizes or data provenance (country of origin, retrospective/prospective) are not provided. The emphasis is on the substantial equivalence argument, which suggests that extensive new primary clinical data might not have been generated for this specific device, assuming its identicality to the predicate.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

Not applicable. As no independent test set or clinical study with the CRS Endoluminal Brush is detailed with performance metrics, there is no mention of experts establishing ground truth for such a study. The "ground truth" for this submission would be the regulatory approval of the predicate device.

4. Adjudication method for the test set

Not applicable, as no described test set requiring expert adjudication.

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 physical medical tool (a brush for collecting samples), not an AI or imaging diagnostic device. Therefore, an MRMC study with human readers and AI assistance is entirely irrelevant 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 medical tool and does not involve any algorithms.

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

The "ground truth" for this 510(k) submission is the regulatory clearance of the predicate device (FAS Endoluminal Brush, K993614). The CRS Endoluminal Brush is asserting that it is "identical" to this already cleared device.

8. The sample size for the training set

Not applicable. This is a physical medical device, not a machine learning model, so there is no concept of a "training set."

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

Not applicable, as there is no training set for a physical device.

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