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510(k) Data Aggregation

    K Number
    K181418
    Date Cleared
    2019-07-11

    (406 days)

    Product Code
    Regulation Number
    876.1500
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The ScopeFlow Pure™ is intended to be used in in conjunction with a flexible endoscope to insufflate air/CO2 and supply sterile water during endoscopic procedures. The ScopeFlow Pure™ is compatible with the different sterile water bottles available. It is intended to be used for 24 hours and then disposed of.

    Device Description

    The ScopeFlow Pure™ is used to convey sterile water from an external water source to a flexible endoscope to aid its function. The ScopeFlow Pure™ consists of: 1) PVC tubing is used provide the method of transferring the sterile water from the external source to the flexible endoscope. This sterile water is used to clean the lens of the flexible endoscope during operation or to assist in improving the flexible endoscopes visual field. 2) An endoscope connector at the distal end of the device. For the ScopeFlow Pure™ the three different connectors are designed to fit Olympus, Pentax and Fujinon endoscopes. The connectors are manufactured from medical grade plastic, which is used as an outer housing and medical grade TPE or silicone which are used as seals to prevent water and air from escaping during use. The ScopeFlow Pure™ functions by using a two parallel tubes configuration to supply air to the water bottle and provide water to the flexible endoscope. The HYBRID configuration consists of the ScopeFlow Pure™ and an EndoStream™ units being used together. The HYBRID models function in the same way but instead of using a separate sterile bottle for irrigation of the lens and irrigation of the GI Tract, one bottle of sterile water is used as the feed for both, the Hybrid has only one screwcap.

    AI/ML Overview

    The provided text is a 510(k) premarket notification summary for the ScopeFlow Pure™ device. This document focuses on demonstrating substantial equivalence to a predicate device for FDA clearance, rather than presenting a performance study evaluating acceptance criteria in the way one would for a novel AI/ML device.

    Therefore, much of the requested information regarding acceptance criteria, reported performance, sample sizes, expert ground truth, adjudication methods, MRMC studies, standalone performance, and training set details is not present in this type of FDA submission.

    Here's an breakdown of what can be extracted and what is missing based on the provided document:

    1. Table of Acceptance Criteria and Reported Device Performance

    This document does not present explicit "acceptance criteria" and "reported device performance" in the context of a diagnostic test's sensitivity, specificity, accuracy, or similar metrics for a new AI/ML algorithm. Instead, it describes performance testing related to the device's physical properties and functionality.

    Acceptance Criteria Category (Implied)Reported Device Performance (Summary from text)
    Sterilization ValidationCompleted per ISO 11135. Implied acceptance: sterilization achieved according to standard.
    Package and Shelf-life TestingCompleted. Implied acceptance: device maintains integrity and functionality over its shelf-life and within its packaging.
    BiocompatibilityEvaluated for cytotoxicity, intracutaneous irritation, and sensitization per ISO 10993. Implied acceptance: device materials are biocompatible and safe for intended use.
    Functionality and Performance IntegrityTested to demonstrate functionality and performance integrity. Implied acceptance: device operates as intended (insufflates air/CO2 and supplies sterile water) without failure.

    2. Sample size used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective)

    • Sample Size: Not specified. The document refers to "Performance testing" without detailing sample sizes for each test.
    • Data Provenance: Not applicable in the context of clinical data for an AI/ML algorithm. The tests are laboratory-based for physical and biological properties.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g., radiologist with 10 years of experience)

    Not applicable. The ground truth for these types of engineering and biocompatibility tests is based on established technical standards (e.g., ISO standards, physical measurements). No human experts are described as establishing "ground truth" in the diagnostic sense.

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

    Not applicable. This is not a study requiring adjudication of diagnostic interpretations.

    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 an irrigation/suction system for endoscopes, not an AI/ML diagnostic or assistive device for human readers.

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

    Not applicable. This device is not an algorithm.

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

    The "ground truth" for the performance tests mentioned (sterilization, biocompatibility, functionality) would be determined by the pass/fail criteria of the respective ISO standards and engineering specifications. For biocompatibility, it's about meeting toxicological thresholds; for sterilization, it's demonstrating sterility assurance levels; for functionality, it's about meeting predefined operational parameters.

    8. The sample size for the training set

    Not applicable. This device does not involve a "training set" in the context of AI/ML or statistical modeling.

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

    Not applicable. No training set is involved.


    Summary of Device and Study:

    The ScopeFlow Pure™ is an irrigation/suction system intended for use with flexible endoscopes to insufflate air/CO2 and supply sterile water during endoscopic procedures. It comes in various configurations compatible with Olympus, Pentax, and Fujinon endoscopes.

    The study described (or rather, the testing performed as part of the 510(k) submission) is a series of engineering and biological tests designed to demonstrate the device's safety and effectiveness. These include:

    • Sterilization Validation: Demonstrated compliance with ISO 11135.
    • Package and Shelf-life Testing: Completed, ensuring the device remains effective and sterile over time.
    • Biocompatibility Testing: Evaluated for cytotoxicity, intracutaneous irritation, and sensitization according to ISO 10993, confirming the materials are safe for patient contact.
    • Functionality and Performance Integrity Testing: Demonstrated that the device functions as intended (insufflates air/CO2 and supplies sterile water).

    The conclusion of the 510(k) submission is that the ScopeFlow Pure™ is substantially equivalent to legally marketed predicate devices (Medivators "EndoSmart Bottle, Rinse and Insufflation System" and The Endo SmartCap Company "The Endo SmartCap") based on similarities in indications for use, materials, performance testing, technological characteristics, principle of operation, and design features. The tests conducted support this claim of substantial equivalence by ensuring the new device meets relevant safety and performance standards equivalent to the predicate devices.

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