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510(k) Data Aggregation
(50 days)
KDJ
stay•safe® catheter extension set with Safe-Lock, 12 inch:
The stay•safe catheter extension set with Safe-Lock is indicated for use in patients with acute and chronic end-stage renal disease undergoing peritoneal dialysis (PD) in a healthcare facility or at home. The stay•safe catheter extension set with Safe-Lock is used to connect a PD catheter with Safe-Lock compatible catheter adapter to PD systems that use stay•safe PIN technology.
stay•safe® catheter extension set with Luer-Lock, 6 inch;
stay•safe® catheter extension set with Luer-Lock, 12 inch;
and stay•safe® catheter extension set with Luer-Lock, 18 inch:
The stay•safe catheter extension set with Luer-Lock is indicated for use in patients with acute and chronic end-stage renal disease undergoing peritoneal dialysis (PD) in a healthcare facility or at home. The stay•safe catheter extension set with Luer-Lock is used to connect a PD catheter with Luer-Lock catheter adapter to PD systems that use stay•safe PIN technology.
stay•safe® to Luer-Lock Adapter, 4 inch:
The stay•safe to Luer-Lock adapter is indicated for use in patients with acute and chronic end-stage renal disease undergoing peritoneal dialysis (PD) in a healthcare facility or at home. The stay•safe to Luer-Lock adapter is used to connect a stay•safe catheter extension set to medical devices with a Luer-Lock connection.
The stay•safe® catheter extension set with Safe-Lock, 12 inch (Safe-Lock extension set) stay•safe® catheter extension set with Luer-Lock, 6 inch, stay•safe® catheter extension set with Luer-Lock, 12 inch, and stay•safe® catheter extension set with Luer-Lock, 18 inch (Luer-Lock extension sets), and stay•safe® to Luer-Lock adapter, 4 inch (Luer-Lock adapter), hereinafter collectively referred to as the "Catheter Extension Sets" are the subject devices of this 510(k).
The Safe-Lock extension set is a single-use device designed to connect a PD catheter to PD systems that use the stay•safe PIN technology. The Safe-Lock extension set is provided sterile and non-pyrogenic. The Safe-Lock extension set is sterilized using ethylene oxide (EO).
The Luer-Lock extension sets are single-use devices designed to connect a PD catheter to PD systems that use the stay•safe PIN technology. The Luer-Lock extension sets are provided sterile and non-pyrogenic. The Luer-Lock extension sets are sterilized using EO.
The Luer-Lock adapter is a single-use device designed to connect a stay•safe catheter extension set to a medical device with a Luer lock connector. The Luer-Lock adapter is provided sterile and non-pyrogenic. The Luer-Lock adapter is sterilized using EO.
The provided FDA 510(k) clearance letter (K250404) for Fresenius Medical Care Renal Therapies Group's stay•safe® catheter extension sets and adapter pertains to a Class II medical device (Peritoneal Dialysis System and Accessories, Product Code KDJ).
Crucially, this document details the substantial equivalence of the new device to a legally marketed predicate device (K173593), based on non-clinical performance testing and biocompatibility. It explicitly states that "No clinical studies were performed for the Catheter Extension Sets." This means the type of study typically associated with assessing an AI/Software as a Medical Device (SaMD) to meet acceptance criteria through human reader performance (like MRMC studies) or standalone algorithmic performance was not conducted because this is a physical medical device, not AI/SaMD.
Therefore, I will describe the acceptance criteria and supporting studies based on the provided document, acknowledging that they are for a physical medical device and not an AI/SaMD.
Acceptance Criteria and Study Proving Device Meets Acceptance Criteria
The acceptance criteria for the stay•safe® catheter extension sets and adapter are based on demonstrating substantial equivalence to a legally marketed predicate device (K173593) in terms of safety and efficacy. This is primarily achieved through non-clinical performance testing and biocompatibility assessments, rather than clinical efficacy studies involving human patient outcomes or AI performance metrics.
1. A table of acceptance criteria and the reported device performance:
The document doesn't provide a direct "table of acceptance criteria" with specific numerical targets and performance results for each test. Instead, it lists the types of performance tests conducted to support the determination of substantial equivalence. The implication is that the new devices met the predefined specifications for each test, which would be deemed "acceptable" for equivalence.
Based on the provided text, the categories of performance testing serve as the basis for acceptance. The "Reported Device Performance" is implicitly that the device met the requirements of each test, demonstrating substantial equivalence.
Category of Performance Criteria (Acceptance Basis for Substantial Equivalence) | Reported Device Performance (Implicitly Met) |
---|---|
Physical/Mechanical Performance: | |
- Weight Verification | Met specifications |
- Length Verification | Met specifications |
- Clamp Occlusion | Met specifications |
- Clamp Compression | Met specifications |
- Visual Inspection after Challenge Condition | Passed inspection after challenge |
- Leak Test | Passed leak test |
- Bond/Tensile Strength | Met strength requirements |
- Shipping and Packaging (Integrity) | Maintained integrity during shipping/packaging |
- Tubing Verification – Dimensional | Met dimensional specifications |
Biocompatibility (Safety): | |
- Chemical Characterization | Acceptable profile for patient contact |
- Cytotoxicity | Non-cytotoxic |
- Sensitization | Non-sensitizing |
- Irritation | Non-irritating |
- Systemic Toxicity (acute to chronic) | Non-systemically toxic |
- Pyrogenicity | Non-pyrogenic |
- Genotoxicity | Non-genotoxic |
- Hemocompatibility | Hemocompatible |
- Carcinogenicity | Non-carcinogenic |
2. Sample size used for the test set and the data provenance:
- Sample Size: The document does not specify the exact sample sizes (number of units tested) for each of the performance or biocompatibility tests. This information is typically detailed in the engineering test reports or biocompatibility reports submitted as part of the 510(k) package, but not in the summary letter itself.
- Data Provenance: The data originates from non-clinical laboratory testing conducted by Fresenius Medical Care Renal Therapies Group, LLC, the device manufacturer. This is by nature prospective testing, as it is performed specifically to support the 510(k) submission for the new devices. The country of origin of the data is implied to be within the US, given the submission is to the US FDA.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not Applicable: For a physical medical device cleared via substantial equivalence based on non-clinical performance and biocompatibility testing, there are no "experts" in the sense of clinicians establishing a "ground truth" for a test set in the way one would for an AI/SaMD (e.g., radiologists annotating images). The "ground truth" for these tests is defined by engineering specifications, regulatory standards (e.g., ISO 10993-1 for biocompatibility), and established test methods. The "experts" involved are engineers and scientists responsible for designing, conducting, and interpreting these tests according to predefined protocols and standards. Their qualifications would be in relevant fields such as biomedical engineering, materials science, and toxicology.
4. Adjudication method for the test set:
- Not Applicable: As there are no human-read interpretations or clinical assessments requiring reconciliation, there is no "adjudication method" in the context of clinical expert consensus. Test results are objectively measured against predefined acceptance criteria (e.g., a leak test either passes or fails, a tensile strength measurement is or is not within specification). Any discrepancies in test results would be handled through standard quality control and engineering investigation procedures.
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:
- No, an MRMC study was not done. This type of study is specifically relevant for software/AI devices that assist human readers in diagnosing or interpreting medical images/data. The device in question is a physical catheter extension set and adapter, not an AI or imaging device. The document explicitly states: "No clinical studies were performed for the Catheter Extension Sets."
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
- No, a standalone performance study was not done. This is also relevant for AI/SaMD devices. The Catheter Extension Sets do not contain any software or algorithms. The document explicitly states: "Not applicable. The Catheter Extension Sets do not contain software."
7. The type of ground truth used:
- Engineering Specifications and Standardized Test Methods: The "ground truth" for the performance tests relies on established engineering specifications, mechanical properties of materials, and successful adherence to recognized industry standards (e.g., ISO for biocompatibility testing). For instance, a "leak test" has an objective pass/fail criterion based on absence of fluid leakage under defined pressure, not a clinical interpretation. Biocompatibility results are compared against toxicological limits and biological responses as defined by ISO 10993-1.
8. The sample size for the training set:
- Not Applicable: This pertains to machine learning models. As this is a physical medical device, there is no "training set."
9. How the ground truth for the training set was established:
- Not Applicable: There is no training set for this type of device.
In summary, the FDA's clearance for the stay•safe® catheter extension sets and adapter is based on a demonstration of substantial equivalence to an existing predicate device, supported by a comprehensive battery of non-clinical performance tests and biocompatibility assessments, validating its physical and material properties for its intended use, rather than clinical efficacy studies or AI/SaMD specific evaluations.
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(263 days)
KDJ
These sets are used during Peritoneal Dialysis therapy to transfer peritoneal dialysis solution to the patient catheter from the source solution container.
The MiniCap Extended Life PD Transfer Set with Twist Clamp – Code 5C4482A and MiniCap Extended Life PD Transfer Set with Twist Clamp - Extra Short - Code 5C4483 are single use, sterile, non-pyrogenic devices for use with Baxter peritoneal dialysis systems. A Transfer Set is connected to a Titanium Adapter that is at the end of an implanted peritoneal catheter. The Transfer Sets stay connected to the patient and allow for the exchange of peritoneal dialysis solution into and out of the peritoneal cavity as prescribed.
This document is a 510(k) Premarket Notification from the FDA regarding Baxter Healthcare Corporation's MiniCap Extended Life PD Transfer Sets. It focuses on demonstrating substantial equivalence to a legally marketed predicate device, not on proving that a device meets specific acceptance criteria through a study as one might conduct for a new AI/software-as-a-medical-device (SaMD) product.
Therefore, the requested information (acceptance criteria, details of a study proving device performance, sample sizes, ground truth establishment, MRMC studies, etc.) is not applicable to this type of FDA submission (510(k) for a physical medical device, specifically a transfer set for peritoneal dialysis).
Here's why and what information is provided:
Why the requested information is not applicable:
- Device Type: The "device" in question is a physical medical device (Peritoneal Dialysis Transfer Set), not an AI/software product. The typical acceptance criteria and study designs for SaMD (which would involve accuracy, sensitivity, specificity, human reader performance, etc.) do not apply here.
- Submission Type (510(k)): A 510(k) submission aims to demonstrate "substantial equivalence" to a predicate device already on the market. It does not require a full clinical trial or a study proving independent performance against specific clinical acceptance criteria in the same way a PMA (Premarket Approval) or a SaMD submission might. The focus is on showing the new device is as safe and effective as a previously cleared device, not necessarily proving new clinical benefit or performance from scratch.
- Nature of Changes: The document explicitly states the primary change is a "material change" from Dichlorobenzoyl peroxide cured silicone to platinum cured silicone for the tubing. This triggers a need to demonstrate that this material change does not negatively impact the device's fundamental function, safety, or biocompatibility.
What information is provided in the document and how it relates to device proving safety and effectiveness for a 510(k):
Instead of a "study proving the device meets acceptance criteria" in the AI/SaMD sense, the document details "non-clinical tests" and "performance data" that support the device's safety and functional equivalence after a material change.
-
A table of acceptance criteria and the reported device performance:
- Acceptance Criteria: While not presented in a formal table with specific numerical targets like for an AI model's operating characteristics, the document implies acceptance criteria by stating "All results meet their acceptance criteria." These criteria would be tied to the functional tests described, ensuring the device performs as intended (e.g., no leaks, proper flow rate, withstands pressure, biocompatibility).
- Reported Device Performance: Instead of performance metrics like accuracy, the "performance data" section lists the types of tests conducted:
- Visual Inspection
- Initial Pressure Test (clamp in closed position)
- Cycling (conditioning step prior to pressure tests)
- 8 psi Pressure Test Post Cycling (clamp in both open and closed position)
- 5 lb Pull of Tubing to Barb Connection
- Functionality after Iodine Exposure (over 48 hours continuous and 6 months simulated use)
- Flow Rate (after iodine exposure)
- Shelf Life
- Biocompatibility Testing: Per ISO 10993-1 and FDA Guidance: Cytotoxicity, Sensitization, Intracutaneous Reactivity, Acute Systemic Toxicity, Material Mediated Pyrogenicity, Sub-chronic Toxicity, Genotoxicity, Implantation, Hemolysis, Extractables and Leachables (per ISO 9003-18:2020), Toxicological Evaluation (per ISO 10993-17:2002).
- No specific numerical results are provided in this summary document, only the types of tests performed and the general conclusion that "The non-clinical data supports the safety of the proposed devices and demonstrates that the proposed devices perform comparably to the predicate device that is currently marketed for the same intended use."
-
Sample sizes used for the test set and the data provenance:
- Sample Size: Not explicitly stated for each test in this summary. For physical device testing, sample sizes are typically determined by statistical methods for device reliability, manufacturing process validation, and regulatory standards (e.g., ISO, ASTM standards for material testing, biocompatibility). These are generally much smaller than data sets for AI models.
- Data Provenance: Not applicable. These are laboratory/bench tests, not clinical data from patients or specific countries.
-
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 AI models, refers to verified labels (e.g., disease presence/absence in an image). For a physical medical device like this, "ground truth" would be the engineering specifications and performance standards established by the manufacturer and relevant regulatory bodies. Experts involved would be engineers, material scientists, toxicologists, and quality control professionals.
-
Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- Not Applicable. This is a concept used in medical image annotation or clinical trial data interpretation by multiple readers. For physical device testing, results are typically objective (e.g., pass/fail a pressure test) and follow standardized protocols.
-
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:
- No. This is a physical medical device, not an AI or imaging diagnostic device. MRMC studies are not relevant.
-
If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not Applicable. This is a physical medical device.
-
The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- Ground Truth: For this device, the "ground truth" is defined by established engineering specifications, material properties, and performance standards expected for a product of this type. It's based on objective measurements from laboratory tests and compliance with recognized standards (e.g., ISO 10993 for biocompatibility).
-
The sample size for the training set:
- Not Applicable. This is not an AI/ML model.
-
How the ground truth for the training set was established:
- Not Applicable. This is not an AI/ML model.
In summary: The provided document is a regulatory letter for a 510(k) submission of a physical medical device undergoing a material change. The information required for your query predominantly applies to software/AI medical devices, particularly those involving image analysis or diagnostic support. The "study" mentioned in the document refers to a series of non-clinical functional and biocompatibility tests designed to ensure the modified physical device maintains safety and performance comparable to its predicate.
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(86 days)
KDJ
This bag is intended for the collection of effluent during Automated Peritoneal Dialysis (APD) Therapy.
Baxter's Cycler Drainage Bag product line currently consists of a sterile 15L Cycler Drainage Bag (5C4145P). This 15 L Cycler Drainage Bag is a single use device intended for the collection of effluent during Automated Peritoneal Dialysis (APD) Therapy and can be used with Baxter's APD Sets with Cassette, Manifold Sets and Extension Sets. The purpose of this drain bag is to allow the collection of the spent effluent in the event that a patient does not have access to a drain from the location where APD therapy is performed. The basis for this submission is the addition of a non-sterile version of the 15L Cycler Drainage Bag to the current product line. The product line does not come into direct or indirect contact with the patient's body tissue. The intended use, material, design, and function of the proposed device will be the same as the currently marketed 15 L Cycler Drainage Bag.
The provided document describes a 510(k) premarket notification for a new non-sterile version of Baxter's 15L Cycler Drainage Bag (product code 5C4145NS), comparing it to the currently marketed sterile version (5C4145P) which serves as the predicate device. The primary difference is the sterility status.
1. Table of Acceptance Criteria and Reported Device Performance:
Test | Acceptance Criteria | Reported Device Performance (Implied) |
---|---|---|
Capacity/Leak (5C4145P) | The product shall hold 16 liters of water for 24 hours without leak. | Met |
Capacity/Leak (5C4145NS) | The product shall hold 16 liters of water for 48 hours without leak. | Met |
Drain Line Spike/Leak | Force to spike drain line connector shall be no more than 35 lbf with no leak at 8psig for 10 seconds. | Met |
Drain Line Spike Removal (5C4145P) | Force to remove spike connector after a 24-hour therapy shall be no less than 3 lbf. | Met |
Drain Line Spike Removal (5C4145NS) | Force to remove spike connector after a 48-hour therapy shall be no less than 3 lbf. | Met |
Clamp Closure Force | Manual shut-off clamp closure force on tubing lines shall be no more than 26 lbf. | Met |
Clamp Opening Force | Manual shut-off clamps on lines shall open with a force no more than 10 lbf. | Met |
Bioburden Measurement | The drain bag shall have less than or equal to 100 CFUs per set. | Met |
Microbial Travel (5C4145NS) | Upper boundaries for bacterial travel distance for both ascending and descending positions at 35-39℃ after 48 hours are less than the distance required to contaminate the APD cassette. | Met (demonstrated mitigation of contamination risk) |
Cycler System Level (5C4145NS) | For both the HomeChoice and HomeChoice Claria cyclers: Under least favorable conditions, the drain flow rate lower bound > 50ml/min. | Met |
Spike Tip Protector Removal Force (5C4145P) | The axial force to remove the spike tip protector shall not be less than 4.5 N (1.0 lbf) or greater than 45 N (10.0 lbf). | Met |
Pull Ring Tip Protector Removal Force (5C4145P) | The axial force to remove the pull ring tip protector shall not be less than 4.5 N (1.0 lbf) or greater than 54 N (12.0 lbf). | Met |
Solvent Bond Leak Strength (5C4145P) | The subsystem, after being subjected to a 5 lbf pull force shall not leak when subjected to 8 psig pressure for 10 seconds. | Met |
Connection Duration Test (5C4145P) | Drain bag and APD sets connected after 48 hours. | Met |
Biocompatibility | Evaluation in accordance with ISO-10993 Biological Evaluation of Medical Devices Part 1, classified as "non-contact". | Biocompatibility standards met for non-contact device. |
Sterilization (5C4145P) | Sterility Assurance Level (SAL) of 10^-6 according to ANSI/AAMI ST67:2019 and ANSI/AAMI/ISO 11135-1:2014. | Met (for sterile version; not applicable to the proposed non-sterile version) |
Shelf Life | 5 years | Supported by aging testing. |
Note: The document states that "All results meet the acceptance criteria," therefore, the reported device performance for all listed criteria is implicitly "Met."
2. Sample Size Used for the Test Set and the Data Provenance:
The document does not explicitly state the sample sizes for each specific test or the data provenance (e.g., country of origin) for the test sets. The tests are described as "design verification tests" conducted by Baxter Healthcare Corporation. It is implied these are internal company tests, so the data provenance would be internal to Baxter, likely in the US (where Baxter is headquartered). The studies appear to be prospective, as they were conducted to support the premarket notification for a new product configuration.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts:
This information is not provided. The tests described are largely objective engineering and microbiological performance tests (e.g., leak tests, force measurements, bioburden, microbial travel), which typically rely on predefined specifications and instrumentation rather than expert consensus on a "ground truth" in the diagnostic sense.
4. Adjudication Method for the Test Set:
Not applicable. As noted above, the tests are objective performance evaluations against established engineering and safety specifications, not subjective 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 medical accessory (drainage bag), not a diagnostic imaging or AI-enabled device. Therefore, MRMC studies and AI-related effectiveness are not relevant.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done:
Not applicable. This device is a medical accessory, not an algorithm.
7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.):
The "ground truth" for the performance tests outlined (Capacity/Leak, Drain Line Spike/Leak, Clamp forces, Bioburden, Microbial travel, Cycler System Level, Removal forces, Solvent Bond Leak Strength, Connection Duration) is based on engineering specifications, established industry standards (e.g., ISO, AAMI), and risk analyses. For biocompatibility, it's adherence to ISO-10993. For microbial travel, it's the lack of contamination reaching a critical point (APD cassette). These are objective, measurable criteria, not subjective human interpretations.
8. The Sample Size for the Training Set:
Not applicable. This device is a physical medical accessory, not an AI/machine learning algorithm requiring a training set.
9. How the Ground Truth for the Training Set Was Established:
Not applicable. No training set is involved.
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(28 days)
KDJ
This set is used during Peritoneal Dialysis therapy to transfer peritoneal dialysis solution to the patient from the source solution container.
The MiniCap Extended Life PD Transfer Sets are single use, sterile, non-pyrogenic devices for use with Baxter peritoneal dialysis systems. A Transfer Set is connected to a Titanium Adapter that is at the end of an implanted peritoneal catheter. The Transfer Sets stay connected to the patient and allows for the exchange of peritoneal dialysis solution into and out of the peritoneal cavity as prescribed.
The provided document describes the K192705 premarket notification for the "MiniCap Extended Life PD Transfer Sets." The acceptance criteria and the study performed to prove the device meets these criteria are outlined in the "DISCUSSION OF NONCLINICAL TESTS" and "Performance Data" sections.
Here's a breakdown of the requested information:
1. A table of acceptance criteria and the reported device performance
The document does not explicitly present a table of "acceptance criteria" alongside "reported device performance" with specific quantitative results. Instead, it states that "All results meet their acceptance criteria." The performance data is described as a list of functional tests performed to ensure proper design and function. The acceptance criteria for these tests are implied to be satisfactory performance without specific pass/fail values mentioned.
Acceptance Criteria (Implied) | Reported Device Performance |
---|---|
Proper design and function for intended use | All functional test results met their acceptance criteria |
Biocompatibility in accordance with ISO-10993 and FDA Guidance | All biocompatibility tests passed |
Visual integrity | Visual Inspection passed |
Pressure integrity in closed position | Initial Pressure Test (clamp in closed position) passed |
Durability after conditioning | Cycling (Conditioning Step Prior to Pressure Tests) performed successfully |
Pressure integrity after cycling (closed position) | 8 psi Pressure Test Post Cycling (clamp in closed position) passed |
Pressure integrity after cycling (open position) | 8 psi Pressure Test Post Cycling (clamp in open position) passed |
Strength of tubing-to-barb connections | 5 lb Pull of Tubing to Barb Connections passed |
Absence of cytotoxicity | Cytotoxicity test passed |
Absence of sensitization | Sensitization test passed |
Absence of intracutaneous reactivity | Intracutaneous reactivity test passed |
Absence of acute systemic toxicity | Acute Systemic toxicity test passed |
Absence of material-mediated pyrogenicity | Material Mediated Pyrogenicity test passed |
Absence of sub-chronic toxicity | Sub-chronic Toxicity test passed |
Absence of genotoxicity | Genotoxicity test passed |
Absence of hemolysis | Hemolysis test passed |
Acceptable levels of extractables and leachables | Physical or Chemical Information (Extractables & Leachables) assessment passed |
2. Sample size used for the test set and the data provenance
The document does not specify the sample size for any of the functional or biocompatibility tests. It also does not explicitly state the provenance of the data (e.g., country of origin, retrospective or prospective).
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This information is not provided. The document outlines non-clinical testing, which typically involves laboratory testing rather than expert-based ground truth establishment as seen in diagnostic device studies.
4. Adjudication method for the test set
This information is not applicable and is not provided. Adjudication methods like 2+1 or 3+1 are typically used in clinical studies where multiple experts are resolving discrepancies in observational data. This document describes non-clinical laboratory testing.
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
A multi-reader, multi-case (MRMC) comparative effectiveness study was not done. This document describes non-clinical testing of a medical device (transfer sets), not a diagnostic algorithm involving human readers or AI assistance.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This is not applicable. The device is a physical medical device (transfer sets), not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
For the functional tests, the "ground truth" would be established by predefined engineering specifications and performance standards relative to the device's intended use. For biocompatibility, the ground truth is established by the accepted standards within ISO 10993 and FDA guidance documents, which define what constitutes a biologically safe material for medical device contact. It's based on objective laboratory measurements and analyses, not expert consensus, pathology, or outcomes data in the clinical sense.
8. The sample size for the training set
This is not applicable. The device is a physical medical device, not an AI/ML algorithm that requires a training set.
9. How the ground truth for the training set was established
This is not applicable as there is no training set for this device.
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(181 days)
KDJ
The stay safe catheter extension set with Safe-Lock is indicated for use in patients with acute and chronic end-stage renal disease undergoing peritoneal dialysis (PD) in a healthcare facility or at home. The stay safe catheter extension set with Safe-Lock is used to connect a PD catheter with Safe-Lock compatible catheter adapter to PD systems that use stay safe PIN technology.
The stay safe catheter extension set with Luer-Lock is indicated for use in patients with acute and chronic end-stage renal disease undergoing peritoneal dialysis (PD) in a healthcare facility or at home. The stay safe with Luer-Lock is used to connect a PD catheter with a Luer-Lock catheter adapter to PD systems that use stay safe PIN technology.
The stay safe to Luer-Lock adapter is indicated for use in patients with acute and chronic end-stage renal disease undergoing peritoneal dialysis (PD) in a healthcare facility or at home. The stay safe to Luer-Lock adapter is used to connect a stay safe catheter extension set to medical devices with a Luer-Lock connection.
The stay safe® catheter extension set with Safe-Lock (hereinafter referred to as "Safe-Lock extension set") is a single-use device designed to connect a PD catheter to PD systems that use staysafe PIN technology. The Safe-Lock extension set is provided sterile and non-pyrogenic. The Safe-Lock extension set is sterilized using ethylene oxide (EO).
The stay safe® catheter extension sets with Luer-Lock (hereinafter referred to as "Luer-Lock extension sets") are single-use devices designed to connect a PD catheter to PD systems that use stay safe PIN technology. The Luer-Lock extension sets are provided sterile and non-pyrogenic. The Luer-Lock extension sets are sterilized using EO.
The stay safe® to Luer-Lock adapter (hereinafter referred to as "Luer-Lock adapter") is a single-use device designed to connect a stay safe catheter extension set to a medical device with a Luer lock connector. The Luer-Lock adapter is provided sterile and non-pyrogenic. The Luer-Lock adapter is sterilized using EO.
The provided document is a 510(k) premarket notification for several medical devices: "stay safe® catheter extension set with Safe-Lock," "stay safe® catheter extension set with Luer-Lock," and "stay safe® to Luer-Lock adapter." These are accessories for peritoneal dialysis systems.
The document describes the acceptance criteria and the studies performed to demonstrate that the devices meet these criteria. However, it is important to note that the type of acceptance criteria and studies are not based on AI/ML performance, but rather on the safety and effectiveness of the physical medical devices. Therefore, many of the typical questions for AI/ML device evaluations (e.g., sample size for test/training set, expert ground truth, MRMC studies, effect size of human improvement with AI) are not applicable here.
Here's a breakdown of the requested information based on the provided text, with explanations for non-applicable points:
Acceptance Criteria and Device Performance for Physical Medical Devices
The acceptance criteria for these devices are primarily focused on their physical and biological properties to demonstrate substantial equivalence to predicate devices, ensuring safety and effectiveness for their intended use in peritoneal dialysis.
1. A table of acceptance criteria and the reported device performance
The document lists performance data categories rather than specific quantitative acceptance criteria or numerical reported performance values. The overarching acceptance criterion is demonstrating "substantial equivalence" to predicate devices, implying that the new devices perform safely and effectively for their intended use.
Acceptance Criteria Category (Testing Performed) | Reported Device Performance Summary (as per document) |
---|---|
Performance Testing | |
Tubing verification | Testing conducted to support substantial equivalence. |
Clamp performance (where applicable) | Testing conducted to support substantial equivalence. |
Connectology (stay safe, Safe-Lock/Luer-Lock) | Testing conducted to support substantial equivalence. |
Package verification | Testing conducted to support substantial equivalence. |
Engagements bond/tensile strength | Testing conducted to support substantial equivalence. |
Device weight verification | Testing conducted to support substantial equivalence. |
Cleaning agents compatibility | Testing conducted to support substantial equivalence. |
Latex content verification | Testing conducted to support substantial equivalence. |
Particulate visual inspection | Testing conducted to support substantial equivalence. |
Shipping and packaging | Testing conducted to support substantial equivalence. |
Maintenance of sterility | Testing conducted to support substantial equivalence. |
ISO 594-2 (for Luer-Lock extension set/adapter) | Testing conducted to support substantial equivalence. |
Biocompatibility Testing | |
Simulated Use Leachables Testing | Testing conducted to support biological safety. |
Cytotoxicity, ISO Elution Method with MEM | Testing conducted to support biological safety. |
Sensitization, Guinea Pig Maximization | Testing conducted to support biological safety. |
Intracutaneous Irritation | Testing conducted to support biological safety. |
Acute Systemic Toxicity | Testing conducted to support biological safety. |
Systemic Toxicity, Short-Term Repeated Exposure | Testing conducted to support biological safety. |
Material-Mediated Pyrogenicity | Testing conducted to support biological safety. |
Genotoxicity (Bacterial Review Mutation Assay, in vitro Mouse Lymphoma Gene Mutation Assay, Mouse Micronucleus in vivo Assay) | Testing conducted to support biological safety. |
Hemocompatibility, ASTM Hemolysis (Indirect) - Extract | Testing conducted to support biological safety. |
Toxicological risk assessment | Performed. |
Human Factors Validation Testing | |
Usability | Validated for safe and effective use in accordance with FDA guidance. |
2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
This information is not provided in the document, as the studies are primarily about physical and biological testing of the device for manufacturing and material safety and performance, not data-driven algorithmic performance or clinical trial data. These tests would involve specific numbers of physical units of the device.
- Sample Size: Not specified for the performance and biocompatibility tests.
- Data Provenance: Not applicable in the context of AI/ML. The tests are laboratory-based and conducted on the manufactured device units.
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 device is a physical medical accessory, not an AI/ML algorithm requiring expert interpretation to establish ground truth for image or diagnostic data. Ground truth here refers to the validated physical and biological properties of the device, established through standardized testing methodologies.
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 in clinical trials or AI/ML evaluations to resolve disagreements among human readers or experts in establishing ground truth. For these physical devices, the "ground truth" is determined by meeting engineering and biocompatibility standards.
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. MRMC studies are specific to AI/ML devices where the performance of human readers, with and without AI assistance, is compared. This document concerns a physical medical accessory, not an AI-powered device. No human-in-the-loop study involving AI was conducted.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This is not applicable. This refers to the performance of an AI algorithm on its own. The devices are physical medical accessories, not software algorithms.
7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)
The "ground truth" for these physical devices is established through compliance with recognized standards and validated test methods for material properties, mechanical integrity, sterility, and biocompatibility. These involve:
- Engineering specifications and design requirements.
- ISO standards (e.g., ISO 10993-1 for biocompatibility, ISO 594-2 for Luer connections).
- Laboratory testing results (e.g., tensile strength measurements, bacterial cultures for sterility, chemical analysis for leachables).
- Demonstration of functional performance (e.g., proper connection, fluid flow).
- Toxicological risk assessment.
There is no "expert consensus" on imaging or diagnostic outcomes, nor pathology or outcomes data in the context of an AI/ML device.
8. The sample size for the training set
This is not applicable. A training set is used for machine learning models. These are physical medical devices, and the document explicitly states:
- "Software Verification and Validation Testing: Not applicable. The [device] does not contain software." (Applicable to all three device types).
9. How the ground truth for the training set was established
This is not applicable due to the reason stated in point 8.
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KDJ
Multiple Tubing Segment (MTS) Set with stay safe® PIN Connectors: The Multiple Tubing Segment (MTS) Set with stay safe PIN Connectors is indicated for use by patients with acute and chronic end-stage renal disease undergoing peritoneal dialysis (PD) in a healthcare facility or at home. The MTS Set is placed during set-up to make additional connections to the cycler set when an interruption in treatment is necessary. This device is compatible with stay safe Peritoneal Dialysis (PD) connectology system and is to be used only with Fresenius Medical Care (FMCNA) Cyclers and Cycler Sets.
stay·safe® Drain Set: The stay safe Drain Set is indicated for use by patients with acute and chronic end-stage renal disease undergoing peritoneal dialysis (PD) in a healthcare facility or at home. The staysafe Drain Set is used to connect directly to the stay safe catheter extension set to enable drainage and/or effluent sampling as needed. This device is compatible with Fresenius Medical Care (FMCNA) Peritoneal Dialysis (PD) stay safe catheter extension sets.
Multiple Tubing Segment (MTS) Set with stay safe® PIN Connectors: The MTS Set is a single-use device that provides additional connections/disconnections when used with a stay safe compatible cycler set during acute and chronic peritoneal dialysis (PD) treatment. The MTS Set is provided sterile and non-pyrogenic. The MTS Set is sterilized using ethylene oxide (EO). The MTS Set consists of two (2) stay safe PIN Connectors at the proximal end, tubing, and a Safe-Lock connector at the distal end.
stay·safe® Drain Set: The Drain Set is a single-use device that connects directly to the patient's stay safe catheter extension set to enable effluent drainage as needed. The Drain Set is provided sterile and non-pyrogenic. The Drain Set is sterilized using ethylene oxide (EO). The Drain Set consists of an empty three (3) L drain bag, a stay safe PIN connector, a sample port, tubing, and a low force clamp.
The provided text describes two medical devices: the Multiple Tubing Segment (MTS) Set with stay safe® PIN Connectors and the stay safe® Drain Set. Both are accessories for peritoneal dialysis.
Here's an analysis of the acceptance criteria and supporting studies for both devices, structured as requested. Please note that the document focuses on performance testing to demonstrate substantial equivalence to predicate devices, rather than a clinical effectiveness study in the typical sense of AI/reader studies.
Multiple Tubing Segment (MTS) Set with stay safe® PIN Connectors
1. Table of Acceptance Criteria and Reported Device Performance
Test | Test Method Description | Acceptance Criteria | Reported Device Performance |
---|---|---|---|
Tubing verification (ID & OD) | Inner diameter (ID) and outer diameter (OD) of the MTS Set tubing measured using a calibrated non-contact measurement system. | The PVC tubing shall have an ID of 0.158" ± 0.005" and an OD of 0.236" ± 0.005". | Pass, results within acceptance criteria |
Tubing verification (Hardness) | Hardness of the resin of the MTS Set tubing measured using a durometer. | The resin hardness of the PVC tubing shall be of 70 ± 3 durometer. | Pass, results within acceptance criteria |
stay•safe PIN connector and male Safe-Lock connector performance | A simulated PD treatment was performed using the MTS Set, Liberty Cycler, and Liberty Cycler Set to verify compatibility. The stay•safe patient connector of the MTS Set was inserted in the blue clip of the stay•safe organizer. | The patient and male Safe-Lock connectors shall be compatible with the stay•safe PD connectology system of the Liberty Cycler Set. No leaks or disconnections. The stay•safe patient connector shall fit with the stay•safe organizer. | Pass, results within acceptance criteria |
Bond/tensile strength | An Instron machine was used to perform a pull-off test for each bonded engagement. | The test samples shall resist a minimum force of 10 lbs at each bonded engagement. | Pass, results within acceptance criteria |
Packaging verification (Vents) | The MTS Set packaging (polyethylene bag) was visually inspected to verify the presence of 4 (four) vents. | The device bag (packaging bag) shall have 4 vents according to drawing P134D-A763. | Pass, results within acceptance criteria |
Packaging verification (Units per bag) | The MTS Set packaging (polyethylene bag) was visually inspected to verify that each bag consisted of one MTS Set device. | The devices shall be packaged individually in a polyethylene bag. | Pass, results within acceptance criteria |
Weight verification | Cases (corrugated cartons) of MTS Sets were weighed using a calibrated scale to verify the quantity of devices per case. | The outer packaging shall contain 10 individually packaged units. | Pass, results within acceptance criteria |
Shipping and packaging | A simulated shipping and distribution test was conducted per ASTM D4169-16 Standard Practice for Performance Testing of Shipping Containers and Systems, Distribution Cycle 13, Assurance Level II. | Visual Inspection: No loose or missing caps, no kinks in tubing, no damage to components and/or tubing (cracks, holes, cuts). No damage to bag or case labels. | Pass, results within acceptance criteria |
Biocompatibility | Evaluation for biocompatibility in accordance with ISO 10993-1:2009/(R)2013, including: Simulated use Leachables, Cytotoxicity (ISO Elution Method with MEM), Sensitization (Guinea Pig Maximization), Intracutaneous Irritation, Acute Systemic Toxicity, Systemic Toxicity (Short-term repeated exposure), Materials-Mediated Pyrogenicity, and Hemocompatibility (ASTM Hemolysis (Indirect) – Extract). A toxicological risk assessment was also performed. | The proposed device is biologically safe for its intended use. | Pass, results within acceptance criteria |
Human Factors Validation Testing | Validation for safe and effective use in accordance with FDA guidance Applying Human Factors and Usability Engineering to Medical Devices (03 February 2016). | No specific quantitative acceptance criteria are listed, but the implication is that the design was found safe and effective for human use. | Pass |
2. Sample Size and Data Provenance (Test Set)
- The document does not explicitly state exact sample sizes for each test (e.g., number of MTS Sets tested for tubing verification, bond strength, etc.).
- It describes "test samples" for bond/tensile strength, "cases (corrugated cartons) of MTS Sets" for weight verification, and a general reference to methods for tubing, connector, and packaging verification.
- Data provenance is not specified (e.g., country of origin). The studies appear to be performed internally by the manufacturer or a contract lab.
- The studies are retrospective in the sense that they are conducted on manufactured devices as part of the market clearance process.
3. Number of Experts and Qualifications (Ground Truth for Test Set)
- Not applicable. These are engineering and biological performance tests, not AI-based diagnostic studies requiring expert review for ground truth.
4. Adjudication Method (Test Set)
- Not applicable. The tests involve objective measurements and visual inspections against predefined criteria, not expert adjudication.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- No. This is not an AI-based diagnostic device.
6. Standalone Performance Study (Algorithm Only)
- No. This is not an AI-based diagnostic device.
7. Type of Ground Truth Used
- The ground truth for these tests is based on established engineering standards (e.g., ASTM, ISO), internal design specifications (e.g., tubing dimensions, vent count, force resistance), and standardized biological evaluation methods.
8. Sample Size for Training Set
- Not applicable. This is not an AI-based device requiring a training set.
9. How Ground Truth for Training Set was Established
- Not applicable.
stay safe® Drain Set
1. Table of Acceptance Criteria and Reported Device Performance
Test | Test Method Description | Acceptance Criteria | Reported Device Performance |
---|---|---|---|
Tubing verification (ID & OD) | Inner diameter (ID) and outer diameter (OD) of the Drain Set tubing measured using a calibrated non-contact measurement system. | The PVC tubing shall have an ID of 0.168” ± 0.005” and an OD of 0.265” ± 0.005”. | Pass, results within acceptance criteria |
Tubing verification (Hardness) | Hardness of the resin of the Drain Set tubing measured using a durometer. | The resin hardness of the PVC tubing shall be of 70 ± 3 durometer. | Pass, results within acceptance criteria |
stay•safe PIN connector performance | The stay•safe patient connector of the Drain Set was inserted in the blue clip of the stay•safe organizer. | The stay•safe patient connector shall fit with the stay•safe organizer. | Pass, results within acceptance criteria |
Clamp performance | An Instron machine measured the force required to close the clamps. | Force required must be less than 10 lbf. | Pass, results within acceptance criteria |
Drop test | The principles of ISO 15747:2010 Plastic Containers for Intravenous Injections were applied: The Drain Set was filled to capacity with water and dropped from a height of 0.375 m. | Acceptance criteria from ISO 15747:2010 were applied: The Drain Bag shall not leak (visual inspection). | Pass, results within acceptance criteria |
Bond/tensile strength | An Instron machine was used to perform a pull-off test for each bonded engagement. | The test samples shall resist a minimum force of 10 lbs at each bonded engagement. | Pass, results within acceptance criteria |
Packaging verification (Clear/textured side) | A visual inspection was performed to verify that Drain Set bag has a clear and a textured side. | The Drain Set shall have a clear and a textured side. | Pass, results within acceptance criteria |
Packaging verification (Vents) | The Drain Set packaging (polyethylene bag) were visually inspected to verify the presence of 4 vents. | The device bag (packaging bag) shall have 4 vents according to drawing P134D-A763. | Pass, results within acceptance criteria |
Packaging verification (Units per bag) | The Drain Set packaging (polyethylene bag) was visually inspected to verify that each bag consisted of one MTS Set device. (Note: The document mistakenly refers to "MTS Set device" here instead of "Drain Set device".) | The devices shall be packaged individually in a polyethylene bag. | Pass, results within acceptance criteria |
Weight verification | Cases (corrugated cartons) of Drain Sets were weighed using a calibrated scale to verify the quantity of devices per case. | The outer packaging shall contain 10 individually packaged units. | Pass, results within acceptance criteria |
Shipping and packaging | A simulated shipping and distribution test was conducted per ASTM D4169-16 Standard Practice for Performance Testing of Shipping Containers and Systems, Distribution Cycle 13, Assurance Level II. | Visual Inspection: No loose or missing caps, no kinks in tubing, no damage to components and/or tubing (cracks, holes, cuts). No damage to bag or case labels. | Pass, results within acceptance criteria |
Biocompatibility | Evaluation for biocompatibility in accordance with ISO 10993-1:2009/(R)2013, including: Simulated use Leachables, Cytotoxicity (ISO Elution Method with MEM), Sensitization (Guinea Pig Maximization), Intracutaneous Irritation, Acute Systemic Toxicity, Systemic Toxicity (Short-term repeated exposure), Materials-Mediated Pyrogenicity, and Hemocompatibility (ASTM Hemolysis (Indirect) – Extract). A toxicological risk assessment was also performed. | The proposed device is biologically safe for its intended use. | Pass, results within acceptance criteria |
Human Factors Validation Testing | Validation for safe and effective use in accordance with FDA guidance Applying Human Factors and Usability Engineering to Medical Devices (03 February 2016). | No specific quantitative acceptance criteria are listed, but the implication is that the design was found safe and effective for human use. | Pass |
2. Sample Size and Data Provenance (Test Set)
- The document does not explicitly state exact sample sizes for each test (e.g., number of Drain Sets tested for tubing verification, bond strength, etc.).
- It describes "test samples" for bond/tensile strength, "cases (corrugated cartons) of Drain Sets" for weight verification, and a general reference to methods for tubing, clamp, and packaging verification, and a single "Drain Set" for the drop test.
- Data provenance is not specified (e.g., country of origin). The studies appear to be performed internally by the manufacturer or a contract lab.
- The studies are retrospective as they are conducted on manufactured devices as part of the market clearance process.
3. Number of Experts and Qualifications (Ground Truth for Test Set)
- Not applicable. These are engineering and biological performance tests, not AI-based diagnostic studies requiring expert review for ground truth.
4. Adjudication Method (Test Set)
- Not applicable. The tests involve objective measurements and visual inspections against predefined criteria, not expert adjudication.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- No. This is not an AI-based diagnostic device.
6. Standalone Performance Study (Algorithm Only)
- No. This is not an AI-based diagnostic device.
7. Type of Ground Truth Used
- The ground truth for these tests is based on established engineering standards (e.g., ASTM, ISO), internal design specifications (e.g., tubing dimensions, vent count, force resistance, no-leak for drop test), and standardized biological evaluation methods.
8. Sample Size for Training Set
- Not applicable. This is not an AI-based device requiring a training set.
9. How Ground Truth for Training Set was Established
- Not applicable.
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(90 days)
KDJ
The Cycler Drain Bag Set is indicated for use by patients with acute and stage renal disease undergoing peritoneal dialysis (PD) in a healthcare facility or at home. The Cycler Drain Bag Set is an optional receptacle that connects to the Luer-lock end of a Cycler Set drain line in order to collect patient effluent during PD treatments. This device is to be used only with Fresenius Medical Care (FMCNA) Cyclers and Cycler Sets.
The Drain Bag Set (tubings and flexible bags) is a passive, closed drainage system used as an optional receptacle during an APD treatment. The Drain Bag Set is used to collect effluent in bags rather than letting the effluent flow directly to a drain. The Drain Bag Set connects to the drain line of a cycler set to collect patient effluent by means of gravity and the pumping action of a Peritoneal Dialysis (PD) cycler. The Drain Bag Set connects to the drain line using a standard Luer lock connection. The Drain Bag Set consists of three (3) interconnected 7-liter drain bags, each with a sampling port and an occluding clamp. The tubing lines that connect each drain bag to the drain line have a snap-disconnect tubing segment. This tubing segment allows the user to disconnect individual bags by snapping the tubing apart.
The provided document describes the acceptance criteria and performance data for the Cycler Drain Bag Set (K173363), a medical device used in peritoneal dialysis.
Here's an analysis of the requested information:
1. Table of Acceptance Criteria and Reported Device Performance
Test Conducted | Acceptance Criteria | Reported Device Performance |
---|---|---|
Drop Test | The drain bag shall not leak (visual inspection). Acceptance criteria from ISO 15747:2010 were applied. | Pass, results within acceptance criteria |
Internal Pressure Test | The drain bag shall not leak (visual inspection). Acceptance criteria from ISO 15747:2010 were applied. | Pass, results within acceptance criteria |
Hanger Holes Tensile Strength | The drain bag hanger holes shall withstand a tensile load of 15 N for 60 minutes. Acceptance criteria from ISO 15747:2010 were applied. | Pass, results within acceptance criteria |
Film Roughness Test | The drain bag's film shall have a roughness ≤ 0.75 µm (Roughness Average). | Pass, results within acceptance criteria |
Tensile Strength of Bonding | All bonded engagements between plastic composites shall require >10 lbf to detach. | Pass, results within acceptance criteria |
Maintenance of Sterility testing | Acceptance criteria from ISO 11607-1:2006/(R)2010 - A1:2014 were applied. | Pass, results within acceptance criteria |
Male Luer lock connector testing | Acceptance criteria from ISO 594-2:1998 were applied. | Pass, results within acceptance criteria |
Drain Bag Set Capacity | The Drain Bag Set shall hold at least 24 L of water (volume ≥ 24 L). | Pass, results within acceptance criteria |
Sampling Port Leakage Test | The sampling port shall not leak after being punctured with a 23 gauge needle one time for 15 seconds and subjected to a pressure of 20 kPa under water for 15 seconds. Acceptance criteria from ISO 15747:2010 were applied. | Pass, results within acceptance criteria |
Snap Connector Breakage Test | The snap connector shall have a break point between 60 oz-in and 120 oz-in. | Pass, results within acceptance criteria |
Clamp Test | No leaks past the clamp. Acceptance criteria from ISO 8638:2010 were applied. | Pass, results within acceptance criteria |
Vibratory (ship) Testing | No tubing kinks or loose or damaged components. | Pass, results within acceptance criteria |
2. Sample Size Used for the Test Set and Data Provenance
The document does not specify the exact sample sizes used for each individual test. It states "The samples" were used for various tests (e.g., sampling port leakage test) but doesn't quantify how many samples.
The data provenance is from in-house laboratory testing performed by Fresenius Medical Care. It is not externally sourced and is not described as retrospective or prospective clinical data. The tests performed are primarily engineering and material science tests according to established ISO and ASTM standards.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
This information is not applicable and therefore not provided in the document. The tests performed are objective, quantitative engineering and material assessments against pre-defined industry standards (e.g., ISO, ASTM). They do not involve expert interpretation or clinical ground truth determination in the way a diagnostic AI device would.
4. Adjudication Method for the Test Set
This information is not applicable. Since the tests are objective physical and performance assessments against documented standards, there is no need for an adjudication method by experts. The results are "Pass" or "Fail" based on whether the measured values meet the specified criteria.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and the Effect Size of How Much Human Readers Improve with AI vs. without AI Assistance
This information is not applicable. The device is a physical medical accessory (drain bag set) and does not involve AI or human reader interpretation for its function. Therefore, no MRMC comparative effectiveness study was performed.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
This information is not applicable. As mentioned, the device is a physical accessory and does not contain any algorithms or software.
7. The Type of Ground Truth Used
The "ground truth" for the performance tests conducted is based on established international and industry standards (ISO 15747:2010, ISO 11607-1:2006/(R)2010 - A1:2014, ISO 594-2:1998, ISO 8638:2010, ASTM D4169-14) and pre-defined engineering specifications (e.g., film roughness ≤ 0.75 µm, tensile strength >10 lbf, break point between 60 oz-in and 120 oz-in, capacity ≥ 24 L). These are objective, measurable criteria.
8. The Sample Size for the Training Set
This information is not applicable. This is a physical device, and the testing described here is for performance verification. There is no "training set" in the context of machine learning or AI algorithms.
9. How the Ground Truth for the Training Set Was Established
This information is not applicable for the same reasons as point 8.
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(218 days)
KDJ
The PuraCath™ Firefly IM Peritoneal Dialysis Connector Disinfecting System is intended for use by PD (peritoneal dialysis) patients as a method of controlling air and touch contamination while performing a solution exchange dialysis patiens as a nethod of connector Disinfecting System is comprised of Firefly™ UV Purification Device, FireflyTM Transfer Catheter, FireflyTM Luer Cover, and FireflyTM 99% IPA bottle.
The effectiveness of the PuraCath Firefly Peritoneal Dialysis Connector Disinfecting System was tested in viro against The enectivelless of the Funceoccus epidermidis, Escherichia coli, Pseudomonas aeruginosa, Streptococus Staphylococcus autous, Staphylococcus aureus, and Candida albicans yielding ≥ 4log reduction in microorganisms.
The PuraCath Firefly Peritoneal Dialysis Connector Disinfecting System may be used in the home or a healthicare facility.
The PuraCath Firefly Peritoneal Dialysis Connector Disinfecting System provides a way for patients to ensure the cleanliness of the fluid connections associated with ambulatory peritoneal dialysis. The system accomplishes cleaning with a combination of alcohol, flushing with sterile dialysate, and ultraviolet (UV) light. The System consists of the components shown below.
The Firefly UV Purification Device is a multi-year reusable device which helps to clean the connection between the Firefly Transfer Catheter and the dialysate Y-set (Y-set). The UV Purification Device is powered by off-the-shelf, replaceable AA batteries. The UV Purification Device directs ultraviolet (UV) light through the Transfer Catheter connector. UV Purification Device uses lights and an audible alert to indicate device status.
The Firefly Transfer Catheter is a sterile, 6 month use, disposable device providing communication between the indwelling patient catheter and the Y-set. A proprietary, UV transparent control valve on the end of the Transfer Catheter allows for draining and filling the peritoneum. The control valve is actuated manually, adjustable between fully open and fully closed. The Transfer Catheter also has a flush feature. The flush feature allows for flushing of air and potential contaminants from the Y-set prior to fluid exchange.
The Firefly Luer Cover is a 6 month use, disposable, UV transparent component designed to protect the Transfer Catheter connector between uses and to aid in keeping the control valve closed.
The Firefly IPA Dropper Bottle provides a convenient way to apply 99% IPA solution to the inside of the Y-set and Transfer Catheter connectors.
Acceptance Criteria and Study for the Firefly™ Peritoneal Dialysis Connector Disinfecting System
This document describes the acceptance criteria and the study conducted to prove that the Firefly™ Peritoneal Dialysis Connector Disinfecting System meets those criteria, as detailed in the provided FDA 510(k) summary (K151620).
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria (Required Performance) | Reported Device Performance |
---|---|
Microbiological Efficacy: Achieve ≥ 4 log reduction in specified microorganisms. | Achieved ≥ 4 log reduction in each tested microorganism: Staphylococcus aureus, Staphylococcus epidermidis, Pseudomonas aeruginosa, Escherichia coli, Streptococcus pneumoniae, Methicillin-resistant Staphylococcus aureus, and Candida albicans. |
Biocompatibility: Meet ISO 10993 standards for medical devices. | Evaluation conducted in accordance with FDA Blue Book Memorandum #G95-1 and ISO 10993. Tests included Cytotoxicity, Sensitization, and Irritation or Intracutaneous Reactivity. (Specific pass/fail results not detailed, but implied by "conducted in accordance" and accepted by FDA). |
Sterilization: Ensure proper sterilization of components. | Testing conducted to confirm proper sterilization. (Specific acceptance criteria for sterilization, e.g., sterility assurance level (SAL), not explicitly stated, but assumed to meet applicable standards). |
Electrical Safety and Electromagnetic Interference (EMI): Comply with relevant electrical safety and EMI standards. | Testing conducted to confirm compliance with electrical safety and electromagnetic interference standards. (Specific standards, e.g., IEC 60601-1, are listed as adhered to). |
Life Cycle Testing: Demonstrate durability and performance over expected lifespan. | Life cycle testing conducted. (Specific performance metrics and duration not explicitly detailed). |
Light Leak Testing: Ensure no light leakage from the UV Purification Device. | Light leak testing conducted. (Specific acceptance criteria not explicitly detailed). |
Transit Testing: Withstand transport and shipping conditions. | Transit testing conducted. (Specific acceptance criteria not explicitly detailed). |
Water Ingress Testing: Ensure protection against water entry. | Water ingress testing conducted. (Specific acceptance criteria not explicitly detailed). |
Human Factors - Usability: Demonstrate intuitive and safe use by intended users. | Human factors - usability studies conducted. (Specific acceptance criteria not explicitly detailed). |
Adherence to Performance Standards: Compliance with listed ISO/AAMI/IEC standards. | All applicable requirements of ISO 14971-1:2012, AAMI/ANSI HE75:2009, ISO 62366-1:2015, ISO 15223-1:2012, IEC 60601-1, ISO 10993-1:2009, ISO 10993-7:2008, and ISO 594-2:1998 were met. |
Substantial Equivalence: Demonstrate substantial equivalence to predicate devices in terms of intended use, design, materials, operation, function, and sterilization method. | Concluded as substantially equivalent to predicate devices based on presented data. |
2. Sample Sizes Used for the Test Set and Data Provenance
The provided document primarily details in vitro studies for microbiological efficacy and various bench tests for physical and electrical performance.
- Microbiological Testing: The sample size for the microbiological efficacy testing is not explicitly stated. It is described as "in vitro antimicrobial efficacy studies," suggesting laboratory-based experiments using cultured microorganisms.
- Other Performance Tests (Biocompatibility, Sterilization, Electrical Safety, Life Cycle, Light Leak, Transit, Water Ingress, Human Factors): The sample sizes for these tests are not explicitly stated in the summary. These would typically involve testing a representative number of devices or components.
- Data Provenance: All described studies are pre-market, laboratory-based in vitro and bench testing. No clinical data from human subjects is mentioned for performance evaluation. The data provenance is implied to be from the manufacturer's testing facilities or accredited laboratories. There is no indication of country of origin of the data beyond the manufacturer being US-based, and the submission being to the US FDA.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
This information is not provided in the given 510(k) summary. For in vitro and bench testing, "ground truth" is typically established by the reference standards and protocols of the tests themselves, conducted by qualified scientists and engineers in a laboratory setting, rather than through expert consensus on observational data.
4. Adjudication Method for the Test Set
This concept is not applicable to the type of studies presented (in vitro microbiological tests and various bench performance tests). Adjudication methods like 2+1 or 3+1 are typically used in clinical studies or image review settings where human interpretation introduces variability requiring a consensus process.
5. Multi Reader Multi Case (MRMC) Comparative Effectiveness Study
No, a Multi Reader Multi Case (MRMC) comparative effectiveness study was not conducted or described. This type of study assesses the impact of a device (often AI) on human reader performance, which is not relevant for this device as it is a physical disinfecting system, not an AI-assisted diagnostic tool.
6. Standalone Performance (Algorithm Only without Human-in-the Loop Performance)
Yes, a form of standalone performance was assessed. The "Microbiological testing" section describes the device's ability to achieve a "≥ 4 log reduction in micro-organisms" in vitro. This demonstrates the device's inherent capability to disinfect independently of human factors (beyond proper operation of the system). Similarly, other bench tests (e.g., electrical safety, life cycle) evaluate the device's inherent performance characteristics as a standalone product. The device itself is not an "algorithm" in the sense of software for interpretation, but rather a physical system.
7. Type of Ground Truth Used
The ground truth for the performance evaluations described in this document is primarily based on:
- In Vitro Microbiological Reference Standards: For the microbiological testing, the ground truth is the known concentration of specified microorganisms and the quantitative measurement of their reduction after exposure to the device. This is a highly controlled, objective, and quantifiable measure.
- Engineering Specifications and Standardized Testing Protocols: For other performance tests (e.g., electrical safety, life cycle, light leak), the ground truth is established by meeting predefined engineering specifications and adhering to recognized industry standards (e.g., ISO, IEC, AAMI/ANSI). These are objective, measurable criteria.
- Physical Measurements and Observations: For tests like transit or water ingress, the ground truth is the observable outcome or measured performance against defined pass/fail criteria.
8. Sample Size for the Training Set
This is not applicable. The Firefly™ Peritoneal Dialysis Connector Disinfecting System is a physical medical device, not a machine learning or AI algorithm that requires a "training set" of data.
9. How the Ground Truth for the Training Set Was Established
This is not applicable as there is no "training set" for this device.
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(41 days)
KDJ
MiniCap Extended Life PD Transfer Sets: This set is used during Peritoneal Dialysis therapy to transfer peritoneal dialysis solution to the patient from the source solution container.
Locking Titanium Adapter for Peritoneal Dialysis Catheter: The Locking Titanium Adapter for Peritoneal Dialysis Catheter is intended to secure the peritoneal catheter tubing to the Baxter transfer set used during Peritoneal Dialysis therapy.
Locking Cap for Peritoneal Dialysis Catheter Adapter: This device is indicated for use in the treatment of patients receiving peritoneal dialysis therapy, to cap the Locking Titanium Adapter for Peritoneal Dialysis Catheter between Baxter Transfer Set installations.
The MiniCap Extended Life PD Transfer Sets are single use, sterile, non-pyrogenic devices for use with Baxter peritoneal dialysis systems. A Transfer Set is connected to a Titanium Adapter that is at the end of an implanted peritoneal catheter. The Transfer Sets stay connected to the patient and allows for the exchange of peritoneal dialysis solution into and out of the peritoneal cavity as prescribed.
The Locking Titanium Adapter for Peritoneal Dialysis Catheter (Titanium Adapter) and Locking Cap for Peritoneal Dialysis Catheter (Locking Cap) are single use, sterile, non-pyrogenic devices for use with Baxter peritoneal dialysis systems. The Titanium Adapter is a device that is secured to the end of a peritoneal dialysis catheter and is used to connect the peritoneal dialysis catheter to the Transfer Sets. The Locking Cap is used to cap the end of the Titanium Adapter between Transfer Set installations.
This document describes the premarket notification (510(k)) for two sets of medical devices from Baxter Healthcare Corporation:
- MiniCap Extended Life PD Transfer Sets
- Locking Titanium Adapter for Peritoneal Dialysis Catheter and Locking Cap for Peritoneal Dialysis Catheter Adapter
The submission declares that these devices are substantially equivalent to legally marketed predicate devices. The majority of the information provided pertains to non-clinical performance testing and biocompatibility.
1. Acceptance Criteria and Reported Device Performance
The documents state that "All results meet their acceptance criteria, and support that the proposed device is appropriately designed for its intended use." However, specific numerical acceptance criteria and the detailed reported performance values (e.g., exact leak rates, torque values, flow rates) are not provided in the given text. Instead, the document lists the functional tests performed.
Table of Acceptance Criteria and Reported Performance (Based on provided text - specific values are not available):
Test Performed | Acceptance Criteria | Reported Device Performance |
---|---|---|
MiniCap Extended Life PD Transfer Sets: | ||
Leak Test Twist Clamp Closed | Not specified, implied to be "no leak" | Met acceptance criteria (implied) |
Twist Clamp Torque to Open/Close | Not specified, implied to be within functional range | Met acceptance criteria (implied) |
Leak Test Transfer Set to Patient Connector | Not specified, implied to be "no leak" | Met acceptance criteria (implied) |
Patient Connector Torque On to Transfer Set | Not specified, implied to be within functional range | Met acceptance criteria (implied) |
Patient Connector Torque Off from Transfer Set | Not specified, implied to be within functional range | Met acceptance criteria (implied) |
MiniCap Test Attachment Torque On/Off to Transfer Set | Not specified, implied to be within functional range | Met acceptance criteria (implied) |
Leak Test MiniCap to Transfer Set | Not specified, implied to be "no leak" | Met acceptance criteria (implied) |
Flow Test CAPD Therapy and APD Therapy | Not specified, implied to be within functional range | Met acceptance criteria (implied) |
Locking Titanium Adapter & Locking Cap for Peritoneal Dialysis Catheter: | ||
Titanium Adapter/Patient Catheter Tubing Seal Test | Not specified, implied to be "no leak" | Met acceptance criteria (implied) |
Tensile Pull Test Titanium Adapter to Patient Catheter Tubing | Not specified, implied to be above a minimum threshold | Met acceptance criteria (implied) |
Locking Cap Removal Torque Test | Not specified, implied to be within functional range | Met acceptance criteria (implied) |
Locking Cap Torque On Test | Not specified, implied to be within functional range | Met acceptance criteria (implied) |
Tensile Strength Adapter Catheter to Luer End of Titanium Adapter | Not specified, implied to be above a minimum threshold | Met acceptance criteria (implied) |
Adapter Catheter to Titanium Adapter - Torque On Test | Not specified, implied to be within functional range | Met acceptance criteria (implied) |
Adapter Catheter to Titanium Adapter - Torque Off Test | Not specified, implied to be within functional range | Met acceptance criteria (implied) |
Leak Test Adapter Catheter to Titanium Adapter | Not specified, implied to be "no leak" | Met acceptance criteria (implied) |
Simulation Testing | Not specified, general functional performance | Met acceptance criteria (implied) |
Biocompatibility (for all devices): | ||
Cytotoxicity | Non-cytotoxic | Met acceptance criteria (implied) |
Systemic Toxicity (Acute and Sub-chronic) | No significant systemic toxic effects | Met acceptance criteria (implied) |
Irritation (Intracutaneous Reactivity) | Non-irritating | Met acceptance criteria (implied) |
Sensitization | Non-sensitizing | Met acceptance criteria (implied) |
Hemocompatibility | Biocompatible with blood components | Met acceptance criteria (implied) |
2. Sample Size Used for the Test Set and Data Provenance
The document does not explicitly state the sample sizes used for the functional and biocompatibility test sets. It generically mentions "nonclinical tests." The data provenance is not specified regarding country of origin or whether it was retrospective or prospective, but as these are non-clinical (laboratory/bench) tests, typical clinical study provenance details would not apply. The tests were presumably conducted by Baxter Healthcare Corporation.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
This section is not applicable as the provided documentation describes non-clinical performance and biocompatibility testing of physical devices, not assessment of diagnostic accuracy or a similar task that would require expert-established ground truth.
4. Adjudication Method for the Test Set
This section is not applicable for the same reasons as point 3. Adjudication methods are typically relevant for clinical studies involving human interpretation or subjective assessments.
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 devices are physical medical instruments (transfer sets, adapters, caps) used in peritoneal dialysis, not AI-powered diagnostic or assistive technologies. Therefore, an MRMC study related to AI assistance for human readers is irrelevant to this submission.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done
This section is not applicable as the devices are not algorithms or AI systems.
7. The Type of Ground Truth Used
For the functional tests, the "ground truth" is established by predefined engineering specifications and performance standards for the device's operation (e.g., no leaks, specific torque values, adequate flow rates). For biocompatibility, the ground truth is established by the biological responses observed in standardized tests performed according to ISO 10993 standards. These are objective measures rather than expert consensus, pathology, or outcomes data in a clinical sense.
8. The Sample Size for the Training Set
This section is not applicable as the devices are physical medical instruments, not machine learning algorithms that require training data.
9. How the Ground Truth for the Training Set was Established
This section is not applicable for the same reasons as point 8.
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FlexiCap Disconnect Cap with Povidone-Iodine Solution (5C4456): This device is intended for use in the treatment of patients with renal failure to isolate the Luer patient line connector of the Baxter APD (Automated Peritoneal Dialysis) disposable set during temporary disconnections and during the dwell phase of therapy.
MiniCap with Povidone-Iodine Solution (5C4466P): This device is a plastic disconnect cap for peritoneal dialysis and contains povidone-iodine intended to protect the female Luer connector of the Baxter transfer set.
FlexiCap Disconnect Cap with Povidone-Iodine Solution (FlexiCap) is a single use device that connects to the patient line connector of the Baxter Automated Peritoneal Dialysis (APD) set and is designed to isolate the line during temporary disconnections and the dwell phase of peritoneal dialysis therapy sessions. The FlexiCap consists of a molded low density polyethylene cap which contains a polyurethane foam sponge and 10% povidone-iodine (PVP-I) solution.
MiniCap with Povidone-Iodine Solution (MiniCap) is a single use device that connects to a Baxter transfer set and is designed to isolate the line between peritoneal dialysis therapy sessions. The MiniCap consists of a molded low density polyethylene cap which contains a polyurethane foam sponge and 10% Povidone-Iodine (PVP-I) solution.
This document is a 510(k) premarket notification for two devices: the FlexiCap Disconnect Cap with Povidone-Iodine Solution and the MiniCap with Povidone-Iodine Solution, both manufactured by Baxter Healthcare Corporation.
Here's a breakdown of the requested information based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The document states that "All tests met the acceptance criteria" for both devices, but it does not specify the quantitative acceptance criteria themselves. It only lists the types of tests performed.
Test Name | Acceptance Criteria (Not specified) | Reported Device Performance |
---|---|---|
Torque-On Test | (Not specified) | Met acceptance criteria |
Leak Test | (Not specified) | Met acceptance criteria |
Iodine Efficacy Test | (Not specified) | Met acceptance criteria |
Cytotoxicity | (Not specified) | Met acceptance criteria |
Irritation/Intracutaneous | (Not specified) | Met acceptance criteria |
Sensitization | (Not specified) | Met acceptance criteria |
2. Sample size used for the test set and the data provenance
The document does not explicitly state the sample sizes used for each specific test (Torque-On, Leak, Iodine Efficacy, Biocompatibility tests). It mentions "non-clinical tests" and "bench tests."
The data provenance is from non-clinical bench testing conducted by Baxter Healthcare Corporation. No information on country of origin for data or whether it's retrospective or prospective is provided for the non-clinical tests.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This information is not applicable as the tests described are non-clinical bench tests (e.g., Torque-On, Leak, Iodine Efficacy, Biocompatibility). These types of tests do not typically involve human experts establishing ground truth in the same way clinical studies or image interpretation tasks would. The "ground truth" for these tests would be defined by the physical or chemical standards and specifications against which the devices are measured.
4. Adjudication method for the test set
This information is not applicable as the tests described are non-clinical bench tests. Adjudication methods like 2+1 or 3+1 are typically used in studies where human interpretation or consensus is required (e.g., clinical trials, image reading).
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 information is not applicable. This document describes the substantial equivalence of medical devices (disconnect caps for peritoneal dialysis) based on non-clinical performance and biocompatibility data, not an AI-powered diagnostic or assistive tool. Therefore, an MRMC study or evaluation of human reader improvement with AI assistance is entirely outside the scope of this submission.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This information is not applicable. The devices are physical medical products and do not involve any algorithms or AI for standalone performance evaluation.
7. The type of ground truth used
For the non-clinical tests (Torque-On, Leak, Iodine Efficacy), the ground truth is based on pre-defined technical specifications and performance standards. These standards would dictate what constitutes an acceptable torque value, an acceptable leak rate, or an effective iodine concentration/release.
For Biocompatibility tests (Cytotoxicity, Irritation/Intracutaneous, Sensitization), the ground truth is established against standardized biological evaluation criteria, specifically ISO-10993 Part 1 and FDA Blue Book Memorandum #G95-1. These standards define the acceptable biological responses for device materials in contact with the body.
8. The sample size for the training set
This information is not applicable. The devices are physical products, not AI models that require a training set. The "training" in this context refers to manufacturing and quality control processes to meet specifications, not an algorithmic training set.
9. How the ground truth for the training set was established
This information is not applicable. As these are physical medical devices and not AI algorithms, there is no "training set" in the context of machine learning. The focus is on ensuring the manufactured products consistently meet established design specifications and performance criteria through quality control and testing processes.
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