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510(k) Data Aggregation

    K Number
    K193482
    Date Cleared
    2020-03-13

    (87 days)

    Product Code
    Regulation Number
    876.5860
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The PrisMax control unit is intended for:
    · Continuous Renal Replacement Therapy (CRRT) for patients weighing 20 kilograms or more with acute renal failure and/or fluid overload.
    • Therapeutic Plasma Exchange (TPE) therapy for patients weighing 20 kilograms or more with diseases where removal of plasma components is indicated.
    All treatments administered via the PrisMax control unit must be prescribed by a physician.

    Device Description

    The PrisMax System is intended for Continuous Renal Replacement Therapy (CRRT) for patients with acute renal failure and/or fluid overload. The goals of acute renal failure treatments are removal of waste products, restoration of acid-base balance; correction of electrolyte imbalances (e.g., hyperkalemia), patient fluid balance, nutritional support, and other conditions in which fluid removal is needed. PrisMax System offers four Continuous Renal Replacement Therapy (CRRT) options: Slow Continuous Ultrafiltration (SCUF), Continuous Veno-Venous Hemofiltration (CVVH), Continuous VenoVenous Hemodialysis (CVVHD), and Continuous Venovenous Hemodialfiltration (CVVHDF). The proposed device PrisMax System Version 3 uses the current marketed device PrisMax System Version 2 as the predicate.

    AI/ML Overview

    This document is a 510(k) Pre-market Notification for a medical device, the PrisMax System Version 3. The document aims to demonstrate that the new device is substantially equivalent to a legally marketed predicate device (PrisMax System Version 2), and therefore does not require a new premarket approval application (PMA).

    Here's an analysis of the provided information regarding acceptance criteria and the supporting study, organized by your requested points:

    Acceptance Criteria and Device Performance

    The acceptance criteria are implicitly defined by the technical specifications outlined in the "Substantial Equivalence Summary" tables (Table 3), comparing the PrisMax System Version 3 to the predicate PrisMax System Version 2. The reported device performance is stated as meeting these specifications, thereby achieving "substantial equivalence" to the predicate.

    Table 1: Acceptance Criteria and Reported Device Performance

    FeatureAcceptance Criteria (Predicate PrisMax Version 2)Reported Device Performance (PrisMax Version 3)
    Indications for UseContinuous Renal Replacement Therapy (CRRT) for patients ≥ 20 kg with acute renal failure/fluid overload; Therapeutic Plasma Exchange (TPE) for patients ≥ 20 kg where plasma component removal is indicated. All treatments by physician prescription.Identical to predicate.
    Dedicated Disposable Sets AvailableFor CRRT: M60/M100/M150, HF1000 & HF1400; For TPE: TPE 2000 Set.Identical to predicate.
    Syringe Sizes20 & 50 mlIdentical to predicate.
    AnticoagulationUser-controllable (continuous or bolus)Identical to predicate.
    Dialysate Flow Rate (CVVH & CVVHDF)Range: 0 to 8000 ml/hr, Increment: 10 ml/hrIdentical to predicate.
    Dialysate Flow Rate Accuracy± 30 ml/hrIdentical to predicate.
    Replacement solution / Fluid Flow Rate (CVVH & CVVHDF)Range: 0 to 8000 ml/hr, Increment: 10 ml/hrIdentical to predicate.
    Replacement solution / Fluid Flow Rate (TPE)Range: 0 to 5000 ml/hr, Increment: 10 ml/hrIdentical to predicate.
    Replacement Flow Rate Accuracy± 30 ml/hrIdentical to predicate.
    Blood Flow RateRange: 10-450 ml/minIdentical to predicate.
    Blood Flow Rate Accuracy± 10 % of user set rate at nominal blood flow of 450 ml/min or highest achievable disposable blood flow, 37°C, access pressure -200 mmHg, without PBP flow.Identical to predicate.
    Pre-Blood Pump Flow Rate (SCUF)Range: 0 to 2000 ml/hrIdentical to predicate.
    Pre-Blood Pump Flow Rate (CVVH, CVVHD, CVVHDF)Range: 0 to 4000 ml/hrIdentical to predicate.
    Pre-Blood Pump Flow Rate (TPE)Range: 0 to 1000 ml/hr (Note: PBP Volume 2000 ml/treatment for TPE2000)Identical to predicate.
    Pre-Blood Pump Accuracy± 30 ml/hrIdentical to predicate.
    Effluent Pump Flow RateRange: 0 to 10,000 ml/h (depending on therapy)Identical to predicate.
    ECG DischargerYESIdentical to predicate.
    TherapiesSCUF, CVVH, CVVHD, CVVHDF, TPEIdentical to predicate.
    PumpsPBP solution, Replacement solution, Dialysate solution, Effluent, Blood.Identical to predicate.
    ScalesDialysate, Replacement, Effluent, Pre Blood Pump (PBP)Identical to predicate.
    Trans Membrane Pressure (TMP) Alarms (CRRT)Default: +300 mmHgIdentical to predicate.
    TMPa (TPE)User settable; +50 to +100 mmHg; Default: +100 mmHgIdentical to predicate.
    Dialysate Conductivity and Temperature ControlNot controlled by PrisMaxIdentical to predicate.
    Patient Fluid Removal (CRRT) Range0 to 2000 ml/hr, Increment: 5 ml/hrIdentical to predicate.
    Patient Fluid Removal (TPE) Range0 to 1000 ml/hr, Increment: 5 ml/hrIdentical to predicate.
    Patient Fluid Removal Performance (Accuracy)± 30 ml/hr; ± 70 ml/3hr; ± 300 ml/24hr. Scales calibrated at ambient temperature, change < +3 °C (5.4 °F) during treatment.Identical to predicate.
    Access Pressure SensorRange: -250 to +450 mmHg, Accuracy: ±15 mmHgIdentical to predicate.
    Return Pressure SensorRange: -50 to +350 mmHg, Accuracy: ±5 mmHgIdentical to predicate.
    Filter Pressure SensorRange: -50 to +450 mmHg, Accuracy: ±15 mmHgIdentical to predicate.
    Effluent Pressure SensorRange: -350 to +400 mmHg (CRRT/TPE), Accuracy: ±15 mmHgIdentical to predicate.
    TPE Specific Settings (Patient Hematocrit)Range: 10 to 60%, Increment: 1%, Default: 30%Identical to predicate.
    TPE Specific Settings (Total Replacement Volume)Range: 0 to 10,000 ml, Increment: 1 ml, Default: 0 mlIdentical to predicate.
    TPE Specific Settings (Patient Plasma Loss Rate)Range: 0 or 10 to 1000 ml/hr, Increment: 5 ml/hr, Default: 0 ml/hrIdentical to predicate.
    TPE Specific Settings (Replacement Container Volume)Range: 0 to 5000 ml, Increment: 0.1 mlIdentical to predicate.
    Control Unit SoftwarePrisMax Version 2PrisMax Version 3
    Blood Warmer AccessoryPrismatherm Warmer, PrismaFlo Blood Warmer, Prismacomfort Blood Warmer, TherMax Blood WarmerIdentical to predicate.

    Summary of Device Performance: The document explicitly states that for all technical specifications listed, the "Proposed K19XXXX PrisMax Version 3" is identical ("SE" - Substantial Equivalence) to the "Proposed K190910 PrisMax Version 2," with the only explicitly identified difference being the Control Unit Software version (Version 3 vs. Version 2). The performance testing conducted confirms that PrisMax System Version 3 remains as safe and effective as the predicate.


    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 a "test set" in the context of clinical or imagery data. Instead, the evaluation relies on nonclinical performance testing of a physical device.

    • Sample Size for Test Set: Not applicable in the traditional sense of patient data. The "test set" would refer to the instantiated PrisMax System Version 3 device(s) and its components undergoing rigorous engineering and functional tests. The document does not specify the number of units tested.
    • Data Provenance: The tests are "nonclinical" and focus on functional performance. The document doesn't explicitly state the country of origin for the testing, but it is submitted to the U.S. FDA by Baxter Healthcare Corporation (Deerfield, Illinois, USA). The testing is prospective in the sense that newly manufactured or updated devices were tested to verify performance against established specifications.

    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 is not applicable as the document describes a nonclinical, engineering-focused substantial equivalence demonstration for a medical device (Continuous Renal Replacement Therapy system), not a diagnostic AI/imaging device requiring expert ground truth in a clinical context. The "ground truth" here is the established functional and safety specifications of the device, typically defined by engineering standards, regulatory requirements, and performance of the predicate device.


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

    This is not applicable. Adjudication methods like 2+1 or 3+1 are used for resolving discrepancies in expert interpretations of clinical data (e.g., medical images). This document describes nonclinical performance testing of hardware and software, where objective measurements and adherence to engineering specifications are the primary evaluation methods, not subjective expert reviews.


    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 is not applicable. An MRMC study is designed for evaluating the diagnostic performance of a system (often AI-assisted) in a clinical setting by comparing multiple readers' interpretations of multiple cases. The PrisMax System is a therapeutic and fluid management device, not a diagnostic tool, and its evaluation did not involve human "readers" or AI assistance in this context.


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

    This is not applicable as the PrisMax System is a physical medical device. While it contains software (Control Unit Software Version 3), the performance evaluation is of the integrated system, and not an algorithm in isolation for diagnostic purposes. The software verification and validation are part of the overall system's nonclinical testing.


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

    The "ground truth" for the nonclinical tests is based on:

    • Established engineering specifications and performance limits: These are derived from general medical device standards (e.g., IEC60601-2-16, IEC60601-1, IEC60601-1-2), regulatory guidelines, and the proven performance of the predicate device (PrisMax System Version 2).
    • Risk analysis: Ensuring the device does not perform in an unexpected or unsafe manner.
    • User needs and intended use: The design validation aimed to meet these.

    In essence, the ground truth is the successful demonstration of consistent functional performance within predefined, objective, and safety-critical parameters, validated against a well-established and previously cleared predicate device.


    8. The sample size for the training set

    This is not applicable. The PrisMax System is not an AI/machine learning model in the sense that it requires a "training set" of data to learn from for diagnostic or predictive purposes. It is a control unit for CRRT and TPE, meaning its software is deterministic and engineered to perform specific, pre-programmed functions and calculations based on input parameters.


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

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

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