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510(k) Data Aggregation

    K Number
    K121832
    Date Cleared
    2012-07-17

    (25 days)

    Product Code
    Regulation Number
    876.5010
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The ReSolve® Biliary Locking Drainage Catheter with locking pigtail and hydrophilic coating is used for drainage of bile within the biliary system.

    Device Description

    The ReSolve® Biliary Locking Drainage Catheter consists of single lumen tubing with two suture holes and 17 to 18 drainage holes in the distal curve region. It is made from a biocompatible thermoplastic. A hydrophilic coating reduces entry site/catheter friction during placement. The components of the catheter allow initial placement using an over-the-wire technique. These include a metal stiffening cannula, flexible stiffening cannula, straightener, and repositioning tool. The pigtail straightener is provided to assist in feeding the guide wire through the catheter. Once the catheter position is established in the area to be drained, the pigtail is formed by retracting a suture which is looped from the hub, to the catheter tip and back to the hub. The hub incorporates a suture locking mechanism to retain the distal pigtail shape. It may be unlocked using the repositioning tool to allow repositioning or replacement of the catheter. A single radiopaque marker band is located proximal to the most proximal drainage hole to assist in accurate placement of the drainage holes in the biliary duct.

    AI/ML Overview

    Here's a summary of the acceptance criteria and the study that proves the device meets them, based on the provided text:

    Device: ReSolve® Biliary Locking Drainage Catheter


    1. Table of Acceptance Criteria and Reported Device Performance

    The provided document describes a "Special Premarket Notification 510(k)" for the ReSolve® Biliary Locking Drainage Catheter. This type of submission relies on demonstrating substantial equivalence to a predicate device rather than presenting new clinical efficacy data. As such, the "acceptance criteria" are primarily related to safety and performance testing to ensure the device performs as intended and is safe for its stated use, and that these characteristics are substantially equivalent to the predicate device.

    The document lists various tests performed, indicating that the device "met the pre-determined acceptance criteria applicable to the safety and efficacy of the device." However, it does not explicitly quantify the specific acceptance thresholds for each test. For example, it lists "Hub Leak" as a test but doesn't state "leakage must be less than X mL/hr."

    Below is a table summarizing the tests performed and the general reported performance.

    Acceptance Criteria CategorySpecific Test PerformedReported Device Performance
    Design VerificationConditioningMet pre-determined acceptance criteria
    DimensionalMet pre-determined acceptance criteria
    Drainage Hole OrientationMet pre-determined acceptance criteria
    Marker Band/Hole LocationMet pre-determined acceptance criteria
    Tip PenetrationMet pre-determined acceptance criteria
    Hub LeakMet pre-determined acceptance criteria
    Vacuum TestMet pre-determined acceptance criteria
    Tubing Kink TestMet pre-determined acceptance criteria
    Safety & PerformanceMarker Band AdhesionMet pre-determined acceptance criteria
    Hub Tensile TestingMet pre-determined acceptance criteria
    Tubing Tensile TestingMet pre-determined acceptance criteria
    Material Durability TestingMet pre-determined acceptance criteria
    Bile Exposure TestingMet pre-determined acceptance criteria
    Stiffening Cannula Friction TestMet pre-determined acceptance criteria
    BiocompatibilityCytotoxicityMet pre-determined acceptance criteria (per ISO 10993)
    IrritationMet pre-determined acceptance criteria (per ISO 10993)
    Acute Systemic ToxicityMet pre-determined acceptance criteria (per ISO 10993)
    PyrogenicityMet pre-determined acceptance criteria (per USP 34 )
    Chemical CharacterizationMet pre-determined acceptance criteria (per ISO 10993)
    Ethylene Oxide Sterilization (Validation)Met requirements of ISO 11135-1:2007
    Ethylene Oxide ResidualsMet requirements of ISO 10993-7:2008
    Sterile Barrier SystemsAccelerated AgingMet requirements of ASTM F 1980-07:2007
    Shipping/PackagingPerformance Testing of Shipping Containers and SystemsMet requirements of ASTM D4169-09:2009
    Conditioning for TestingMet requirements of ISO 2233:2000

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

    The document does not specify the sample sizes used for each of the performance and safety tests listed. The data provenance is implied to be from internal testing conducted by Merit Medical Systems, Inc. There is no information regarding the country of origin of the data or whether the tests were retrospective or prospective, though device performance testing is typically prospective (i.e., conducted specifically for the submission).


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

    This section is not applicable to this submission. The "ground truth" concept, especially involving expert consensus or adjudication, is typically relevant for studies validating diagnostic algorithms (e.g., AI in radiology) where a human expert's judgment or a definitive diagnostic method is used as the reference standard. This document describes a 510(k) submission for a physical medical device (a catheter) based on performance testing and substantial equivalence, not a diagnostic algorithm. Therefore, no experts were used to establish "ground truth" in this context.


    4. Adjudication Method for the Test Set

    This section is not applicable for the same reasons as point 3. Adjudication methods like "2+1" or "3+1" are used in studies involving subjective assessments or disagreements among experts, which is not the case for the physical and biocompatibility tests described for this catheter.


    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 section is not applicable. An MRMC study is relevant for evaluating the performance of diagnostic imaging devices or AI algorithms that assist human readers. The ReSolve® Biliary Locking Drainage Catheter is a physical therapeutic device, not an imaging device or an AI assistant. Therefore, no MRMC study was conducted.


    6. If a Standalone (i.e. algorithm only without human-in-the loop performance) Was Done

    This section is not applicable. This refers to the standalone performance of an AI algorithm, which is not relevant for a physical medical device like a catheter.


    7. The Type of Ground Truth Used

    The "ground truth" in this context is established by objective engineering specifications, material standards, and biological safety standards. For example:

    • Engineering Specifications: Dimensional tolerances, tensile strength requirements, leak rates, kink resistance, marker band adhesion force.
    • Material Standards: Biocompatibility (cytotoxicity, irritation, systemic toxicity, pyrogenicity, chemical characterization) as defined by ISO 10993 series and USP 34.
    • Sterilization and Packaging Standards: Requirements for ethylene oxide sterilization (ISO 11135-1), residuals (ISO 10993-7), accelerated aging of sterile barriers (ASTM F 1980-07), and shipping performance (ASTM D4169-09).

    8. The Sample Size for the Training Set

    This section is not applicable. There is no "training set" in the context of a physical medical device like this catheter. Training sets are used for machine learning or AI algorithms.


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

    This section is not applicable for the same reasons as point 8.

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