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510(k) Data Aggregation

    K Number
    K161906
    Device Name
    SCIg60 Infuser
    Date Cleared
    2016-12-01

    (142 days)

    Product Code
    Regulation Number
    880.5725
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The SCIg60 Infusion System is intended for use in the home or hospital environment for the subcutaneous infusion of Hizentra, Immune Globulin Subcutaneous (Human), 20% Liquid (manufactured by CSL Behring), Gammagard Liquid, Immune Globulin Infusion (Human) 10% (manufactured by Baxalta), and Cuvitru Immune Globulin Infusion (Human) 20% (manufactured by Baxalta) with the BD 60 ml syringe (model no. 309653).

    Device Description

    The EMED SCIg60 Infusion System consists of the SCIg60 Infuser, the Infuset™ flow control extension set and SUB-Q patient administration set. The SCIg60 Infuser must be used with the BD 60 ml syringe (model no. 309653). The Infuset™ flow control extension sets and SUB-Q patient administration sets are also manufactured by EMED Technologies.

    The SCIg60 Infuser is a reusable mechanical. non-electronic ambulatory infusion pump that does not require batteries or any electrical source. The EMED SCIg60 Infuser uses a spring as a source of pressure for the subcutaneous infusion of indicated human plasma-derived immunoglobulin solutions.

    The Infuset™ flow control extension sets are assembled from standard luer lock components and specified lengths of PVC microbore tubing. The length and diameter of the tubing results in predetermined flow rates when used with the SCIg60 Infuser, and include slide-clamps for stopping the flow of fluid. The SCIg60 Infuser user manual includes information to guide users in the selection of Infuset™ flow control extension sets and SUB-Q patient administration sets users to achieve the desired infusion rates.

    SCIg60 Infusion System should be used in accordance with its directions for use.

    AI/ML Overview

    The provided text describes a 510(k) submission for the SCIg60 Infusion System, primarily to expand its indications for use to include Gammagard and Cuvitru in addition to Hizentra. The document focuses on demonstrating that the device's performance with these new indications is substantially equivalent to its performance with the predicate indication (Hizentra) and aligns with the drug manufacturers' recommended infusion rates.

    The acceptance criteria for this device are implicitly tied to maintaining the safety and effectiveness of the infusion system, specifically its ability to deliver the indicated human plasma-derived immunoglobulin solutions at appropriate flow rates. The study proving the device meets these criteria is a performance testing study, summarized within the "Summary of Performance Testing" section.

    Here's a breakdown of the requested information based on the provided text:

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

    The acceptance criteria are not explicitly stated as quantitative thresholds (e.g., "flow rate must be within +/- X% of target"). Instead, the acceptance is based on the device's ability to achieve flow rates that are consistent with the FDA approved human plasma-derived immunoglobulin labeling, when used as directed.

    The reported device performance is demonstrated through tables that specify:

    • Needle Gauge
    • Number of needles
    • Total Flow Rate (ml/hr)
    • Approx. Per Site Flow Rate (ml/hr)
    • Infuset™ Reorder Number
    • SUB-Q Set

    These tables are provided for:

    • Hizentra (First Infusion and Standard Infusions)
    • Gammagard (Initial Infusion for patients <40kg and >=40kg; Maintenance Infusions for patients <40kg and >=40kg)
    • Cuvitru (First 2 Infusions and Subsequent Infusions)

    The "reported device performance" is the achievement of these specific flow rates for various configurations, which are then stated to be consistent with the respective drug manufacturers' recommendations.

    Example Excerpt for Hizentra (Standard Infusions) as an illustration of reported performance:

    Needle GaugeNumber of needlesTotal Flow Rate (ml/hr)Approx. Per Site Flow Rate (ml/hr)Infuset™ Reorder NumberSUB-Q Set
    2411212FP-0010008SUB-109-G24
    2445213FP-0010005SUB-409-G24
    2711414FP-0010009SUB-109-G27
    2744712FP-0010004SUB-410

    The general acceptance criterion is that the device, when used with the specified Infuset and SUB-Q sets, delivers flow rates that fall within the ranges published by the drug manufacturers for the given immunoglobulin solutions. The full set of tables across pages 6-10 represents the reported performance data that meets this criterion.

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

    The document does not explicitly state the sample sizes (e.g., number of tests, number of devices tested) for the infusion flow rate testing. It mentions "Infusion flow rate testing with SCIg60 Infusion System and indicated human plasma-derived immunoglobulin solutions" and "Infusion flow rate testing with combinations of SCIg60 Infuser. Infuset 100 extension sets, and . SUB-Q patient administration sets with simulated test fluid."

    Given this is a 510(k) submission, the data provenance is likely from laboratory testing conducted by the manufacturer (EMED Technologies Corporation) in the USA, and it would be prospective for the specific tests performed to support this submission. However, some data (e.g., reliability, biocompatibility, sterility, shelf life) were "incorporated by reference to data from K142319," which means they were likely established during the predicate device's clearance and are thus retrospective in the context of this specific submission.

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

    This type of information (number and qualifications of experts) is typically relevant for studies involving human interpretation (e.g., image reading). For this device, which performs a mechanical function (fluid infusion), the "ground truth" is based on engineering specifications and established fluid dynamics principles (Poiseuille equation) along with the manufacturer-recommended infusion rates for the pharmaceutical products. There is no indication of "experts" in the sense of human adjudicators for the test set results; rather, the "ground truth" is adherence to known physical laws and pharmaceutical labeling.

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

    No human adjudication method is mentioned or relevant for this type of performance testing. The "adjudication" is based on direct measurement of flow rates and comparison against established product specifications.

    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

    An MRMC study is not relevant to this device. This is a medical device (infusion pump), not an AI-assisted diagnostic tool requiring human reader studies.

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

    This refers to the performance of the infusion system itself (the "algorithm" in this context is the mechanical and fluid dynamic operation), without direct human-in-the-loop performance influencing the measurement of its function. The "Infusion flow rate testing" described is indeed a standalone performance test of the device.

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

    The ground truth for this performance study is based on:

    • Engineering principles and physical laws: The flow control properties follow the Poiseuille equation.
    • Manufacturer specifications for the device: The design, materials, and functionality of the SCIg60 Infuser, Infuset, and SUB-Q sets.
    • Pharmaceutical product labeling: The "manufacturer-recommended total flow rates of the additional indicated immunoglobulin biologics" (Hizentra, Gammagard, Cuvitru) serve as the target "ground truth" for the flow rate performance.

    8. The sample size for the training set

    This concept (training set) is typically applicable to machine learning or AI models. The SCIg60 Infusion System is a mechanical device, not an AI. Therefore, there is no "training set" in the context of artificial intelligence. Its design and performance are based on engineering principles and testing.

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

    As there is no training set for an AI model, this question is not applicable. The "ground truth" for the device's design and expected performance (as mentioned in point 7) is derived from established scientific and engineering principles, and the specific requirements of the drug products it is designed to administer.

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