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510(k) Data Aggregation

    K Number
    K121248
    Date Cleared
    2013-12-13

    (597 days)

    Product Code
    Regulation Number
    882.5550
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The LiquoGuard CSF system is indicated for the external drainage of cerebrospinal fluid (CSF). It connects to any drainage catheter (not part of the product) which is usually inserted by the doctor into the lateral or third ventricle of the brain or lumbar subarachnoid space in selected patients to reduce intracranial pressure. The LiquoGuard CSF system controls CSF pressure using pressure sensors and a pump, thus taking the role of the conventional CSF dripping chamber and collection bag (predicate devices). The LiquoGuard CSF system also monitors intracranial pressure up to 75 mmHg and cerebrospinal fluid flow during CSF drainage, and provides many alarm functions not offered by the passive dripping chamber systems.

    Device Description

    The LiquoGuard CSF System consists of a pump and a corresponding tube set with pressure sensors. The dynamic range of this system is from -15mmHg to +75 mmHg. The tube set is inserted into the pump, connected to the intrathecal drainage catheter (not part of the product) via Luer-Lock and the LiquoGuard CSF System device via cable connector. The device then continuously measures the pressure inside the tube and operates a tube pump whenever the actual pressure is higher than a preselected target pressure. Thus the LiquoGuard CSF System combines CSF drainage and intracranial pressure (ICP) monitoring with integrated alarm and documentation/data logging functions, improving safety, simplifying the handling and enhancing patient mobility (by its battery back-up).

    AI/ML Overview

    Acceptance Criteria and Device Performance for LiquoGuard CSF System (K121248)

    The provided document describes the Moller Medical LiquoGuard CSF System, which is indicated for external drainage and monitoring of cerebrospinal fluid (CSF). The acceptance criteria for this device are established through a combination of bench tests and a comparative clinical study against predicate devices.

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria are implicitly defined by the successful completion of the bench tests and the demonstration of equivalence in adverse event rates during the clinical study. No specific numerical thresholds for acceptance were explicitly stated beyond "all tests passed according to the predetermined pass/fail criteria."

    Acceptance Criteria CategorySpecific Test/CriterionReported Device Performance
    Pressure MeasurementAbsence of sensor drift during packaging / sterilizationPassed
    Absence of sensor drift during ageingPassed
    Precision of displayed pressure at various pump rates and pressure loadsPassed
    Pressure RegulationEndurance test with in-vitro simulated patientPassed
    Performance comparison with drip chamberPassed
    Reliability of pump shut-off with negative pressuresPassed
    Device functions independent of positioningPassed
    Volume and Flow MeasurementPrecision of total volume and flow (pump rate) measurementPassed
    Alarm Functions (Patient Condition)Pressure alarmsPassed
    Pulsation alarm (e.g., catheter occlusion, collapsed ventricles, disconnected catheter)Passed
    Pressure too constant alarm (e.g., catheter occlusion, collapsed ventricles, disconnected catheter)Passed
    Influence of pressure on catheter wallsPassed
    Detection of clogged catheterPassed
    Alarm Functions (Device Functions)Defective/disconnected sensorsPassed
    Disconnected/leaking tube setPassed
    Battery lowPassed
    Main controller/watchdog cross-checkPassed
    Double safetyPassed
    Tube set too oldPassed
    Battery defectivePassed
    Mechanical Handling and OperationDisposable check for single-usePassed
    Wrong tube set insertionPassed
    Opening of front panelPassed
    Disposable check for agePassed
    EnduranceAutomatic switch to battery upon power failurePassed
    Tube set durabilityPassed
    OtherExternal connectivityPassed
    Clinical Equivalence (Adverse Events)Total rates of incidence of adverse events compared to predicate devices"Very close, with most small variations in favor of the LiquoGuard." Supports equivalence.

    2. Sample Size Used for the Test Set and Data Provenance

    • Sample Size (Clinical Study): 413 patient records.
    • Data Provenance: The records were collected from "several hospitals," indicating a multi-center study. The clinical study combines "similar, independent studies," suggesting a retrospective collection and aggregation of existing patient data rather than a new prospective study exclusively for this submission. The country of origin of the data is not explicitly stated in the provided text.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications

    The document does not specify the number or qualifications of experts used to establish ground truth for the clinical study. The clinical study compares "adverse events" between the LiquoGuard and predicate devices, implying that these events were recorded as part of standard clinical practice.

    4. Adjudication Method for the Test Set

    The document does not specify an adjudication method (e.g., 2+1, 3+1, none) for the clinical study's adverse event data. It mentions identifying and comparing rates of incidence, which suggests a quantitative analysis of pre-recorded data rather than a consensus-based adjudication process for individual cases.

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

    No, a multi-reader multi-case (MRMC) comparative effectiveness study was not conducted. The study focused on comparing adverse event rates between the device and predicate devices in a clinical setting, not on assessing human reader performance with or without AI assistance.

    6. Standalone (Algorithm Only) Performance

    The device is not an AI-driven diagnostic algorithm. It is a medical device that combines hardware (pump, sensors) and software for CSF drainage and monitoring. Therefore, a standalone (algorithm only) performance study as typically understood for AI/CAD devices was not performed. Its performance is assessed through the comprehensive bench tests and clinical comparison.

    7. Type of Ground Truth Used for the Test Set

    The ground truth for the "test set" (clinical study) was based on clinical outcomes data, specifically "adverse events" recorded in patient records resulting from CSF drainage using either the LiquoGuard or predicate drip chambers.

    8. Sample Size for the Training Set

    The document does not explicitly mention a "training set" as would be typical for machine learning models. The device's development and validation relied on engineering principles, bench testing, and a clinical comparison to existing devices. Therefore, a specific sample size for a "training set" in the context of an AI/ML model is not applicable from the provided information.

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

    As there is no explicit mention of a training set in the context of machine learning, the question of how its ground truth was established is not directly applicable. The device's functionality is based on established fluid dynamics, pressure sensing, and pump control mechanisms. Its design and performance would have been refined through iterative engineering development and testing against specifications derived from medical requirements and predicate device functions.

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