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510(k) Data Aggregation

    K Number
    K181669
    Date Cleared
    2019-03-14

    (262 days)

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

    The ConvertX Biliary Stent System with releasable drainage catheter is delivered percutaneously and is intended for internal drainage of the bile ducts, for splinting of the bile ducts during healing, or for providing bile duct patency in a stricture or past a stone while maintaining external access to the stent, as well as providing external drainage. For patients for whom external drainage is not, or no longer desirable, the releasable drainage catheter may be removed, leaving the stent to provide internal drainage from the bile duct to the duodenum.

    Device Description

    The ConvertX Biliary Stent System is a sterile, single-use non-vascular interventional device inserted using percutaneous access techniques to re-establish internal drainage and is intended for internal drainage of the bile ducts, for splinting of the bile ducts during healing, or for providing bile duct patency in a stricture or past a stone. The ConvertX Biliary System allows for external drainage and access as needed.

    The ConvertX Biliary Stent System has two primary components: a double pigtail Biliary Stent and a Releasable Drainage Catheter with Hub.

    The ConvertX Biliary Stent System is a single lumen device that has a detachable Biliary Stent with proximal and distal loops (pigtails). Both proximal and distal loops (pigtails) contain drainage holes. The proximal pigtail forms in the bile duct, while the distal pigtail forms in the duodenum. The distal pigtail has a tapered, atraumatic tip. Drainage can occur internally (from the bile duct to the duodenum) or externally (from the bile duct to the outside of the patient). A suture ("Loop Suture") is threaded through the proximal pigtail enabling the pigtail, straightened for delivery, to be closed in the bile duct.

    The ConvertX Biliary Stent System's Hub has three ports which are used for both ends of the Loop Suture, external drainage of bile and the release wire. Ends of the Loop Suture and the Release Wire are connected to separate pull tabs within the Hub. The Releasable Drainage Catheter and Loop Suture may be detached from the Biliary Stent when external drainage is no longer necessary, leaving the stent in place. While still attached, the Releasable Drainage Catheter may be used to withdraw the Biliary Stent. The ConvertX Biliary Stent System is radiopaque throughout its length and has a marker on the stent between junction and proximal loop

    The ConvertX Biliary Stent System is comprised of the following functional components:

    • . Biliary Stent
    • . Releasable Drainage Catheter with Hub

    The ConvertX Biliary Stent System is supplied with the following accessories:

    • . Metal Stiffening Cannula
    • . Luer Cap
    • . Plastic Stiffening Cannula
    • . Loop Straightener
    AI/ML Overview

    This document is a 510(k) summary for the BrightWater Medical ConvertX Biliary Stent System. It details the device's characteristics, intended use, and a comparison to predicate devices, along with a summary of non-clinical testing.

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

    1. Table of Acceptance Criteria and Reported Device Performance

    Test/CharacteristicAcceptance CriteriaReported Device Performance
    Mechanical/Physical Performance
    Stent / Catheter DimensionsDetermined by applicable standards (e.g., ASTM F1828-97, ISO 10555-1: 2013) and design specifications.Met predetermined acceptance criteria.
    Stiffener DimensionsDetermined by applicable standards and design specifications.Met predetermined acceptance criteria.
    Straightener to Stent CompatibilityDemonstrated compatibility.Met predetermined acceptance criteria.
    Guidewire CompatibilityCompatibility with 0.038" guidewire.Met predetermined acceptance criteria.
    Loop RecoveryDemonstrated adequate loop formation/recovery.Met predetermined acceptance criteria.
    Flow Recovery Post KinkingDemonstrated adequate flow recovery after kinking.Met predetermined acceptance criteria.
    Stent-Catheter Interface StrengthDemonstrated adequate strength.Met predetermined acceptance criteria.
    Kink ResistanceDemonstrated resistance to kinking.Met predetermined acceptance criteria.
    Stent Shaft Tensile StrengthDemonstrated adequate tensile strength.Met predetermined acceptance criteria.
    Hub to Shaft Tensile StrengthDemonstrated adequate tensile strength.Met predetermined acceptance criteria.
    Hub to Stiffener StrengthDemonstrated adequate strength.Met predetermined acceptance criteria.
    Stiffener Tip StrengthDemonstrated adequate strength.Met predetermined acceptance criteria.
    Loop Retention / Removal ForceDemonstrated appropriate forces for retention and removal.Met predetermined acceptance criteria.
    Pull Wire to Pull Tab Tensile StrengthDemonstrated adequate tensile strength.Met predetermined acceptance criteria.
    Loop Suture to Pull Tab Tensile StrengthDemonstrated adequate tensile strength.Met predetermined acceptance criteria.
    Frictional ForceDemonstrated appropriate frictional forces.Met predetermined acceptance criteria.
    Loop Suture Removal ForceDemonstrated appropriate removal force.Met predetermined acceptance criteria.
    Lock Suture to Hub Tensile StrengthDemonstrated adequate tensile strength.Met predetermined acceptance criteria.
    Decoupling ForceDemonstrated appropriate decoupling force.Met predetermined acceptance criteria.
    Resistance to DeformationDemonstrated resistance to deformation.Met predetermined acceptance criteria.
    Resistance to Liquid Leakage Under Pressure and During Aspiration/VacuumDemonstrated resistance to leakage.Met predetermined acceptance criteria.
    Flow RateDemonstrated adequate flow rate.Met predetermined acceptance criteria.
    Pouch Seal StrengthDemonstrated adequate seal strength.Met predetermined acceptance criteria.
    Material/Biocompatibility/Sterilization
    Bile Compatibility (Stent & System)Compatibility with simulated bile (e.g., ASTM F1828-97 using simulated bile, ASTM F2129-17 X2.5 Simulated Bile).Met predetermined acceptance criteria.
    Corrosion TestingDemonstrated resistance to corrosion.Met predetermined acceptance criteria.
    Shelf LifeDemonstrated stability over shelf life.Met predetermined acceptance criteria.
    SterilizationDemonstrated effective sterilization (EtO).Met predetermined acceptance criteria.
    BiocompatibilityMet requirements of ISO 10993.Met predetermined acceptance criteria.
    Imagery/Safety
    MRI Compatibility ConditionalEvaluated according to ASTM F2182-11a, ASTM F2119-07, ASTM F2052-15, ASTM F2503-13.Met predetermined acceptance criteria.
    RadiopacityEvaluated according to ASTM F640-12.Met predetermined acceptance criteria.
    Simulated Use
    Simulated Use TestingPerformed to assess overall device function.Met predetermined acceptance criteria.

    Study Proving Device Meets Acceptance Criteria:

    The document summarizes the "Summary of Non-Clinical Testing" which involved various tests based on applicable ASTM, ISO, and FDA guidance documents. The conclusion states, "The Convert X Biliary Stent System, including its packaging, met the predetermined acceptance criteria. No new safety or performance issues were raised during testing." This collective non-clinical testing served as the study proving the device met the acceptance criteria.

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

    The document does not specify the exact sample sizes (number of units tested) for each non-clinical test. It only lists the types of tests performed. The provenance of the data is not mentioned (e.g., country of origin, retrospective or prospective). This information is typically found in the full test reports, which are not included in this summary.

    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)

    This section is not applicable to the provided document. The listed tests are non-clinical (engineering, material, and simulated use testing), which do not involve expert interpretation or ground truth establishment by medical professionals in the context of diagnostic performance.

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

    This section is not applicable to the provided document, as it describes non-clinical performance testing rather than studies involving expert adjudication of clinical outcomes or images.

    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. The document describes a medical device (a biliary stent system), not an AI-powered diagnostic tool, and therefore no MRMC study or AI-related effectiveness analysis was performed.

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

    This section is not applicable. The device is a physical medical stent system, not an algorithm.

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

    For non-clinical testing, the "ground truth" or reference standard would be the validated testing methods and specifications defined in the relevant ASTM, ISO standards, and FDA guidance documents. For example, for tensile strength, the ground truth would be the specified force limits the device must withstand. For biocompatibility, it would be compliance with ISO 10993 requirements based on biological assays.

    8. The sample size for the training set

    This section is not applicable. There is no mention of a "training set" as this is not an AI/machine learning device. The testing described is for a physical medical device.

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

    This section is not applicable for the reasons stated in point 8.

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