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510(k) Data Aggregation

    K Number
    K222773
    Device Name
    Feeding Tube
    Date Cleared
    2023-08-17

    (337 days)

    Product Code
    Regulation Number
    876.5980
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    This product is intended for use in neonatal and pediatric patients to provide nutrition via nasal or orogastric placement. The Polyurethane Feeding Tube is not intended for use beyond 30 days. The PVC Feeding Tube is not intended for use beyond 24 hours.

    Device Description

    The Feeding Tube consists of the following main components: a feeding tube single lumen catheter and an enteral only connector hub with integral tethered connection closure plug. The catheter tubing is made of Polyurethane or PVC. The catheter tubing has an orange or purple radiopaque stripe of barium sulfate embedded in the tubing wall which can be visualized on x-ray, for exact placement of the tip. The single lumen catheter tubing has side holes for better flow and to provide multiple openings for aspiration. The proposed Feeding Tube is sterilized by Ethylene Oxide Gas to achieve a SAL of 10-6 and supplied sterility maintenance package which could maintain the sterility of the device during the shelf life of three years.

    AI/ML Overview

    This document is a 510(k) premarket notification decision letter from the FDA to Anhui Tiankang Medical Technology Co., Ltd. regarding their "Feeding Tube" device. It primarily focuses on the device's substantial equivalence to a predicate device and outlines the non-clinical performance data provided to support this claim.

    Based on the provided text, the device is a medical feeding tube, and the "acceptance criteria" and "proof" relate to demonstrating its safety and effectiveness through non-clinical performance testing and biocompatibility testing, rather than a study involving human subjects or an AI algorithm. Thus, many of the typical elements of AI/ML device acceptance criteria (e.g., sample size for test set, expert adjudication, MRMC studies, standalone algorithm performance, training set details) are not applicable here as this is a traditional medical device submission.

    Here's an analysis of the acceptance criteria and the study (non-clinical testing) that proves the device meets them, based only on the information provided:

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria are primarily defined by adherence to recognized international standards and successful completion of specific physical and biological tests. The "reported device performance" indicates that the subject device met these standards and test requirements.

    Acceptance Criteria (Test/Standard)Reported Device Performance (as stated in the document)
    Biocompatibility Testing
    In Vitro Cytotoxicity Test (ISO 10993-5:2009)Performed, result not explicitly stated but implied to be acceptable as "does not show any adverse effect" for the material difference.
    Intracutaneous Reactivity Test (ISO 10993-10:2010)Performed, result not explicitly stated but implied to be acceptable as "does not show any adverse effect" for the material difference.
    Skin Sensitization Test (ISO 10993-10:2010)Performed, result not explicitly stated but implied to be acceptable as "does not show any adverse effect" for the material difference.
    Acute Systemic Toxicity (ISO 10993-11:2017)Performed, result not explicitly stated but implied to be acceptable as "does not show any adverse effect" for the material difference.
    Subacute Toxicity (ISO 10993-11:2017)Performed, result not explicitly stated but implied to be acceptable as "does not show any adverse effect" for the material difference.
    Implantation Effects (ISO 10993-6:2017)Performed, result not explicitly stated but implied to be acceptable as "does not show any adverse effect" for the material difference.
    Sterilization & Shelf Life Testing
    Sterilization Validation (ISO 11135)Validated to achieve a SAL of 10-6.
    EO Residue (ISO 10993-7:2008)Performed, result not explicitly stated but compliant.
    ECH Residue (ISO 10993-7:2008)Performed, result not explicitly stated but compliant.
    Ageing Test (ASTM F1980-16 for 3-year shelf life)Shelf life of three years determined based on stability studies.
    Package Integrity (ASTM F88/F88M-15, ASTM F1929-2015, ASTM F1886/F1886M-16)All packaging deemed acceptable for protection of product and sterility maintenance after testing (Seal strength, Blue Dye Penetration, Visual Inspection).
    Performance Testing (Mechanical/Physical)
    Radiopacity Verification (ISO 20695:2020)Compliant with ISO 20695:2020.
    Tube Markings (ISO 20695:2020)Compliant with ISO 20695:2020.
    Liquid Leakage Testing (ISO 20695:2020, 50-60 kPa internal pressure)"Feeding tube set shall not show signs of leakage sufficient to form a falling drop of water" - stated as tested and met the updated standard.
    Fluid Leakage - Connector (ISO 80369-3 and ISO 80369-20, 300-330 kPa)"The connector shall not leak" at applied pressure - stated as tested and met the standards.
    Stress Cracking - Connector (ISO 80369-3 and ISO 80369-20)"The connector shall have adequate resistance to stress cracking" - stated as tested and met the standards.
    Resistance to Separation from Axial Load - Connector (ISO 80369-3 and ISO 80369-20)"The connector shall not separate from the reference connector" - stated as tested and met the standards.
    Resistance to Separation from Unscrewing - Connector (ISO 80369-3 and ISO 80369-20, <0.26 N.m)"The connector shall separate from the reference connector applied unscrewing torque less than 0.26 N.m" - stated as tested and met the standards.
    Resistance to Overriding - Connector (ISO 80369-3 and ISO 80369-20, 0.15-0.17 N.m)"The connector shall not override the threads or lugs of the reference connector" - stated as tested and met the standards.
    Connector Compatibility (ISO 80369-3 reference connectors)"The connector shall be compatible with ISO 80369-3 reference connectors" - stated as evaluated per ISO 80369-3 for ENFit dimensional verification. "Non-ENFit Connector" also tested and results showed it "does not present the risks contemplated by ISO 80369-1".
    Tensile Testing (ISO 20695:2020)Tested and met the updated standard.

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

    The document does not specify the exact sample sizes (number of units tested) for each non-clinical performance and biocompatibility test. It simply states that the tests were "performed" according to the relevant standards.
    Data provenance is not directly addressed in terms of "country of origin for data" or "retrospective/prospective" as these are non-clinical, in-vitro/bench tests, not clinical studies. The testing would have been conducted by the manufacturer or a contracted lab to demonstrate compliance.

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

    Not applicable. Ground truth, in the context of device performance, is established by adherence to codified international standards and test methods (e.g., ISO, ASTM). These tests are objective measurements, not subjective evaluations requiring expert consensus from human readers or assessors.

    4. Adjudication method for the test set

    Not applicable. As described above, these are objective physical and biological tests, not human assessments requiring adjudication.

    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 a physical medical device (feeding tube), not an AI/ML diagnostic or assistive device for human readers. No MRMC study was performed or is relevant to this submission.

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

    Not applicable. This device does not involve an algorithm.

    7. The type of ground truth used

    The "ground truth" for this device's acceptance is established by international standards and validated test methodologies. For example, a successful biocompatibility test result (per ISO 10993) is the "ground truth" that the material is biocompatible. Similarly, meeting specified force or leakage requirements (per ISO 80369-3, ISO 20695) constitutes the "ground truth" for mechanical performance.

    8. The sample size for the training set

    Not applicable. This device is a physical medical device and does not involve AI/ML requiring a training set.

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

    Not applicable. As above, no training set is relevant for this type of device.

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