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510(k) Data Aggregation

    K Number
    K190485
    Date Cleared
    2019-07-08

    (131 days)

    Product Code
    Regulation Number
    862.1675
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Kawasumi Multiple Sample Adapter with Pr-Attached Holder (MBCH) is a sterile, non-invasive device used for connection with a female luer system and non-needle devices in order to collect blood specimen to blood collection tube.

    Device Description

    The Kawasumi Multiple Sample Adapter with Pre-Attached Holder (MBCH) is a sterile, singleuse device consisting of a plastic holder with a non-patient contacting stainless steel cannula covered with a rubber sheath and a male luer adapter which is attached into the holder. This device is used to collect blood specimen by connecting to female luer connectors of vascular access devices such as peripheral, central catheter, Huber needle, etc. As this device can be connected to various devices with female luer adapter, it is called "multiple sample adapter".

    When blood is collected, the blood collection tube is placed over the cannula, pushing the rubber sheath back, allowing blood flow. After obtaining the correct amount of blood, the blood collection tube is removed from the holder. When the blood collection tube is removed, the rubber sheath extends back over the cannula and stopping blood flow. Blood collection may be continued by connecting additional blood collection tubes, if required.

    The device is sterilized using Ethylene Oxide. The device is a prescription-use device intended to be used in hospitals or healthcare facilities.

    AI/ML Overview

    Here's an analysis of the provided text, focusing on the acceptance criteria and the study proving the device meets them, based on the requested information.

    It's important to note that this document is a 510(k) summary for a medical device (blood specimen collection adapter), not an AI/ML software device. Therefore, many of the typical questions for an AI/ML device, such as those related to AI model training, ground truth establishment, expert adjudication, MRMC studies, or standalone algorithm performance, are not applicable to this type of submission. The 'device' here refers to a physical, non-digital product.


    Acceptance Criteria and Study Proving Device Performance

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

    The document doesn't provide a direct "acceptance criteria" table with specific quantitative limits for each test. Instead, it describes various performance tests conducted to demonstrate substantial equivalence (SE) to a predicate device. The general acceptance criterion for all tests is "meets design requirements and specifications" and "confirm performance," ultimately aiming to show comparable function and performance to the predicate device, thereby demonstrating substantial equivalence in terms of safety and effectiveness.

    Here's an interpretation based on the "Non-Clinical Testing" section and "Technological Characteristics" comparison, outlining the tests performed to demonstrate that the device meets its design requirements and is substantially equivalent:

    Acceptance Criteria (Implied)Reported Device Performance
    Comparative Testing (Functional/Performance Equivalence)Conducted to verify equivalent function and performance as the predicate device across:
    - Appearance and Measurement (Dimensions: Subject: 20G, L: 64.1mm, WA: 31.1mm, WB: 23.6mm; Predicate: 20G, L: 64.3mm, WA: 30.5mm, WB: 24.9mm - "Comparable," despite minor differences, supported by non-clinical testing).
    - Attachment and Detachment
    - Pressure Resistance
    - Connection Strength
    - Vacuum Tube Insertion and Removal
    - Chemical Resistance
    Shelf Life/Accelerated AgingConducted to ensure functionality, performance, quality, and safety over time (up to 36 months equivalent) for both physical and chemical properties.
    Physical Testing (Accelerated Aging)Assessed: Packaging Study/Stability Test (Transportation, Appearance, Seal Strength, Dye Test), Physical Study/Stability Test (Leakage, Tensile Strength, Blood Taking Needle functionality).
    Chemical Testing (Accelerated Aging)Assessed: Reducing matter, Metal ions, Titration acidity and alkalinity, Nonvolatile residue, Absorbance (per ISO 1135-3:2016).
    Sterilization EffectivenessDemonstrated compliance with ISO 11135:2014 (Ethylene Oxide sterilization) and United States Pharmacopeia <71> for sterility testing.
    EO ResidualsComplies with ISO 10993-7 for residual gas and chemicals.
    Particulate ContaminationComplies with ISO 1135-3:2016 for particulate contamination via accelerated aging.
    Packaging IntegrityVerified through Transportation Test (ISTA 2A), Appearance Test (ISO 11607-1), Seal Strength Test (ISO 11607-2), and Dye Test (ISO 11607-2).
    Luer Fitting ConformanceConformed to ISO 80369-7:2016 (small-bore connectors) at 0 and 36 months, with measured dimensions within tolerance.
    BiocompatibilityComplies with ISO 10993-1, including Cytotoxicity (ISO 10993-5), Sensitization and Irritation (ISO 10993-10), Acute Systemic Toxicity and Material-Mediated Pyrogenicity (ISO 10993-11), and Hemocompatibility (ASTM F756-17, ISO 10993-4).
    Materials EquivalenceMaterials (Hub: Polycarbonate (PC); Cannula: Stainless Steel; Glue: Epoxy; Silicon: Silicon Oil; Sheath: Isoprene Rubber; Holder: Polypropylene (PP)) were compared. While the Predicate uses Polystyrene for the Hub, the Subject device's use of Polycarbonate was supported by "Biocompatibility Testing and Performance Testing was conducted to demonstrate SE." All other materials are the same.

    2. Sample sized used for the test set and the data provenance:

    • Sample Size: The document does not explicitly state the numerical sample size (e.g., number of devices) used for each individual test. It lists the types of tests performed. For physical device testing, sample sizes are typically determined by relevant ISO standards or internal quality protocols.
    • Data Provenance: The document does not specify the country of origin of the data. Given the "Kawasumi Laboratories, Inc." address in Tokyo, Japan, it is highly likely that testing was performed by or for the manufacturer, potentially in Japan or at contract labs globally.
    • Retrospective or Prospective: These are non-clinical, controlled laboratory tests on manufactured devices, so the terms "retrospective" or "prospective" as they apply to clinical studies or real-world data collection are not applicable.

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

    • This is a review of a physical medical device. The "ground truth" is established through engineering and laboratory testing against established physical, chemical, and biological standards (e.g., ISO, USP, ASTM). It does not involve human expert interpretation of data in the way an AI/ML device would. Therefore, the concept of "experts establishing ground truth" in this context is not applicable.

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

    • Not applicable for a physical device undergoing laboratory testing. This concept is relevant for human interpretation tasks, often in AI/ML performance evaluations.

    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 is a physical blood collection device, not an AI/ML radiology or diagnostic aid. MRMC studies are for evaluating diagnostic accuracy with and without AI assistance.

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

    • Not applicable. This is not an algorithm or software device.

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

    • The "ground truth" for this device's performance is defined by adherence to established international standards (ISO, ASTM, USP) for physical properties, chemical properties, sterility, biocompatibility, and functional performance of medical devices. The predicate device's performance also serves as a benchmark for comparative testing to demonstrate equivalence.

    8. The sample size for the training set:

    • Not applicable. This is not an AI/ML device, so there is no "training set."

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

    • Not applicable. As above, there is no "training set" for a physical medical device.
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