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510(k) Data Aggregation
(101 days)
ODN
The NxStage System One is indicated for the treatment of acute and chronic renal failure, or fluid overload using hemofiltration, hemodialysis, and/or ultrafiltration, in an acute or chronic care facility.
The System is also indicated for home hemodialysis, including home nocturnal hemodialysis.
All treatments must be administered under physician's prescription, and must be performed by a trained and qualified person, considered to be competent in the use of this device by the prescribing physician.
The NxStage System One is comprised of the NxStage Cycler, an electromechanical control unit; the NxStage Cartridge, a sterile, single-use extracorporeal blood and fluid management circuit (with or without a preattached high permeability filter) that mounts integrally within the NxStage Cycler. The combined system is designed to deliver hemofiltration, hemodialysis and/or ultrafiltration in an acute or chronic care facility. The NxStage System One is also indicated for home hemodialysis, including home nocturnal hemodialysis.
This document is a 510(k) Premarket Notification for the NxStage System One, a high permeability hemodialysis system. It seeks to demonstrate substantial equivalence to a previously cleared predicate device (K141752).
Based on the provided document, here's an analysis regarding acceptance criteria and supporting studies:
1. Table of Acceptance Criteria and Reported Device Performance
The document presents a comparison of technological characteristics between the proposed device and the predicate device in Table 1. However, this table does not directly state acceptance criteria in terms of performance metrics (e.g., minimum accuracy, maximum allowable deviation) against which the proposed device was tested. Instead, it states that the "Proposed Device (NxStage System One)" is "Same" for most parameters compared to the "Predicate Device (NxStage System One)".
The closest the document comes to defining acceptance criteria is under "Effluent Volume Accuracy" for the predicate device, where specifications for different software versions are provided. However, it only states that the proposed device is "Same," implying it meets these same specifications without explicitly presenting the proposed device's performance against them.
Therefore, a table of acceptance criteria and reported device performance cannot be fully constructed from the provided text as the explicit acceptance criteria and quantitative performance results for the proposed device are not detailed, beyond stating they were "met."
Inference of Acceptance Criteria (from Predicate Device Specifications as implied by "Same"):
Parameter | Acceptance Criteria (from Predicate) | Reported Device Performance (Implied) |
---|---|---|
Flow Rates: Blood | 10-600 ml/min | Same (Implied to meet 10-600 ml/min) |
Flow Rates: Prescription Fluid /Dialysate | 0-18000 ml/hr | Same (Implied to meet 0-18000 ml/hr) |
Flow Rates: Ultrafiltration | 0-2400 ml/hr | Same (Implied to meet 0-2400 ml/hr) |
Transmembrane Pressure | Yes (Implies capability) | Same (Implied to have capability) |
Monitoring: Venous Pressure | 0 to 400 mmHg | Same (Implied to monitor 0 to 400 mmHg) |
Monitoring: Effluent Fluid Pressure | 0 to 500 mmHg | Same (Implied to monitor 0 to 500 mmHg) |
Monitoring: Air Detector | Reduction of detector signal lasting 6 ms minimum (Approximates a 60 microliter bubble at 400 mmHg venous pressure and 600 ml/min blood flow) | Same (Implied to meet this specification) |
Monitoring: Blood Leak Detector | 15% reduction in detector signal lasting 20 seconds minimum. Signal reduction % based on a 0.35 ml/min leak rate of 32 Hct blood. | Same (Implied to meet this specification) |
Effluent Volume Accuracy (Software versions 4.7 and below) | Greater of 300 ml/12 hr or 3% of exchange volume | Same (Implied to meet this specification) |
Effluent Volume Accuracy (Software versions 4.8 and higher) | Therapy Fluid Flow Rate (L/hr) > 3 ml/hr: +100 or +5% UF; ≤ 3 ml/hr: +25 ml/hr* (*Representing 95/90 tolerance interval established under controlled laboratory testing conditions) | Same (Implied to meet this specification) |
IV Prescription Fluid | Off-line, sterile- physician prescribed, indicated for infusion | Same (Implied to handle this type) |
Dialysate | Available as pre-packaged pre-mixed sterile fluids or via the PureFlow SL | Same (Implied to be compatible with these types) |
Compatible Blood Tubing Set | NxStage Standard Cartridge | Same (Implied to be compatible) |
Software | Software version 4.10 | Same (Implied to use or be compatible with 4.10) |
2. Sample Size Used for the Test Set and Data Provenance
The document states: "No Clinical testing was conducted." All testing mentioned is "Non-Clinical Test/Performance Testing - Bench."
- Sample Size: Not explicitly stated for bench testing. The document refers to "Simulated treatments" but does not give a number of simulations or samples used.
- Data Provenance: Not applicable as no clinical data was used. All testing appears to be in-house bench testing.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
Not applicable. Since no clinical testing was conducted and all testing was "Non-Clinical Test/Performance Testing - Bench," there was no need for expert ground truth establishment in a clinical context. The "ground truth" for bench testing would be established by the engineering specifications and validated test methods.
4. Adjudication Method for the Test Set
Not applicable, as no clinical testing with human subjects or expert review was performed.
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
Not applicable. This is a 510(k) for a medical device (hemodialysis system), not an AI-powered diagnostic or interpretive device that would involve human readers.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) Was Done
Not applicable in the context of an "algorithm only" performance that would typically compare to human clinicians. This device is a treatment system. The "Non-Clinical Test/Performance Testing - Bench" can be considered a form of standalone performance assessment against engineering specifications, but it's not "algorithm only" in the sense of a software-as-a-medical-device (SaMD) context. It's the performance of the integrated electromechanical control unit with its software and cartridge.
7. The Type of Ground Truth Used
For the non-clinical bench testing, the "ground truth" would be established by:
- Engineering specifications and design requirements: The device's performance was measured against these predefined technical standards and parameters (e.g., flow rates, pressure monitoring ranges, accuracy for effluent volume).
- Physical measurements and simulated conditions: The testing simulates treatment conditions and measures the device's output against expected physical and chemical outcomes.
8. The Sample Size for the Training Set
Not applicable. This device is not an AI/ML model that requires a "training set" in the conventional sense. The "training" for a traditional medical device involves its design, development, and iterative testing/refinement against engineering principles and specifications.
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there is no "training set" for an AI/ML model. The "ground truth" for the device's design and development (analogous to a training process for an AI) comes from established medical standards for hemodialysis, regulatory requirements, risk analysis, and engineering principles.
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(172 days)
ODN
The NxStage System One is indicated for the treatment of acute and chronic renal failure, or fluid overload using hemofiltration, hemodialysis, and/or ultrafiltration, in an acute or chronic care facility.
The System is also indicated for home hemodialysis, including home nocturnal hemodialysis.
All treatments must be administered under physician's prescription, and must be performed by a trained and qualified person, considered to be competent in the use of this device by the prescribing physician.
The NxStage System One is comprised of the NxStage Cycler, an electromechanical control unit; the NxStage Cartridge, a sterile, single-use extracorporeal blood and fluid management circuit (with or without a preattached high permeability filter) that mounts integrally within the NxStage Cycler. The combined system is designed to deliver hemofiltration, hemodialysis and/or ultrafiltration in an acute or chronic care facility. The NxStage System One is also indicated for home hemodialysis, including home nocturnal hemodialysis.
This document describes the NxStage System One, a hemodialysis system. The FDA 510(k) clearance (K141752 dated December 19, 2014) indicates that the device is substantially equivalent to a previously cleared NxStage System One (K140526).
Here's an analysis of the provided information regarding acceptance criteria and the study that proves the device meets those criteria:
1. Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria are implicitly defined by the chosen "primary effectiveness endpoint" and "primary safety endpoint" of the pivotal clinical study.
Acceptance Criteria | Reported Device Performance (NxStage System One) |
---|---|
Effectiveness (Primary Endpoint): Ability to deliver the clinically prescribed amount of therapy, defined by attainment of a delivered volume that is at least 90% of the prescribed volume. Performance is deemed successful if the upper boundary of the 95% confidence interval of the difference in success rates between NHD and DHD is less than 10%. | Effectiveness: Probability of successful treatment: 90.9% in Daily Hemodialysis (DHD) phase vs. 91.7% in Nocturnal Hemodialysis (NHD) phase. The upper limit of the confidence interval (2.9%) was less than the protocol-specified limit (10%). This met the non-inferiority criterion. |
Safety (Primary Endpoint): Composite intradialytic and interdialytic adverse event (AE) profile. The study aimed to show similarity in AE rates between NHD and DHD. | Safety: Composite AE rate per 100 treatments: 8.3 in DHD phase vs. 6.9 in NHD phase. The event profiles were similar for both phases. No unanticipated adverse device effects and one death not related to the study device. Rate of severe AEs per 100 treatments: 0.9 for DHD vs. 0.3 for NHD. |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: A total of 58 End Stage Renal Disease (ESRD) patients participated in the clinical study. 39 completed the study period, and 19 discontinued.
- Data Provenance: The study was a US prospective, multi-center clinical study.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
This information is not explicitly provided in the document. The "ground truth" for the clinical study was based on patient outcomes, delivered therapy volumes, and reported adverse events during the observational clinical trial. The study was conducted "under physician's prescription," implying medical oversight, but specific details about expert adjudication for individual patient data points are not detailed.
4. Adjudication Method for the Test Set
This information is not explicitly provided. The clinical study collected data on delivered therapy and adverse events. The assessment of these outcomes would have been part of the clinical trial protocol, but there is no specific mention of an independent adjudication committee for all events or for the effectiveness endpoint.
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 question is not applicable to the provided document. The NxStage System One is a hemodialysis device, not an AI-powered diagnostic or interpretive tool that would involve human readers or AI assistance in the interpretation of medical images or data. The study compared two different treatment regimens (Nocturnal Hemodialysis vs. Daily Hemodialysis) using the same device, not human performance with and without AI.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
This question is not applicable. The device is a hemodialysis system, not an algorithm, and it always involves a human-in-the-loop (trained and qualified person, prescribing physician, and patient). The "effectiveness" measurement was based on the system's ability to deliver therapy, not an independent algorithmic output.
7. The Type of Ground Truth Used (Expert Consensus, Pathology, Outcomes Data, etc.)
The ground truth for the clinical study was based on patient outcomes data, specifically:
- Effectiveness: Measured by the actual delivered volume of therapy compared to the prescribed volume.
- Safety: Measured by the occurrence and rates of intradialytic and interdialytic adverse events.
8. The Sample Size for the Training Set
The document does not describe a "training set" in the context of machine learning or AI. For the clinical study, the patients (all 58 of them) effectively served as the "test set" for evaluating the performance of the device in the two different treatment regimens. If "training set" refers to data used for initial device development and non-clinical testing, that information is not detailed here beyond "System Verification and Software Validation" and "Simulated dialysis treatments."
9. How the Ground Truth for the Training Set Was Established
As there is no explicit "training set" described in the context of a machine learning or AI algorithm, this question is not fully applicable. For the non-clinical testing (System Verification and Software Validation, Regression testing, etc.), the ground truth would have been established through engineering specifications, validated test protocols, and simulated conditions to ensure the device performs as designed.
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