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510(k) Data Aggregation
(76 days)
The Cyl-Fil Oxygen System is intended to provide supplemental oxygen by prescription only. Cyl-Fil is a two component system. The first component consists of a high pressure regulator that delivers USP oxygen from a supply cylinder having two pressure settings. The second component is a light-weight portable, high pressure cylinder that is refilled by use of the Cyl-Fil pressure regulator.
The intended patient population is to supply, by prescription only, supplemental oxygen to patients requiring additional oxygen.
The Responsive Respiratory Cyl-Fil Oxygen System is a two component system. The first component is a high pressure regulator that delivers USP Grade oxygen at two pressure settings. The second component is a lightweight, portable high pressure cylinder with an oxygen specific post valve (similar to CGA-870 with an additional pin/hole location unique to the Cyl-Fil system) that incorporates a residual pressure retention device to insure that the USP oxygen is always retained in the cylinder. The portable cylinder is prepared and filled with USP oxygen according to industry and FDA requirements.
A supply cylinder supplies USP oxygen to the inlet connection (standard CGA-540) of the Cyl-Fil regulator. The Cyl-Fil regulator pressure setting delivers USP oxygen to the Cyl-Fil portable cylinder at a pressure and rate that does not exceed the safety rating of the cylinder, according to the cylinder manufacturer's specifications. The second Cyl-Fil regulator pressure setting delivers USP oxygen to an auxiliary outlet connection (CGA-1240) for continuous oxygen therapy support in the home.
The provided text describes a 510(k) premarket notification for the "Cyl-Fil Oxygen System," a medical device. This type of submission focuses on demonstrating substantial equivalence to a predicate device, primarily through non-clinical testing and comparison of technological characteristics. It does not typically involve detailed clinical studies with human subjects, complex statistical analysis of performance metrics like sensitivity/specificity, or multi-reader, multi-case studies, as would be expected for a device relying on AI or requiring efficacy testing.
Therefore, many of the requested categories for a study proving acceptance criteria are not applicable to this document. The "acceptance criteria" here are essentially that the device performs its intended function safely and effectively, and is substantially equivalent to existing predicate devices, as demonstrated by the non-clinical tests listed.
Here's a breakdown based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria (Implied) | Reported Device Performance |
---|---|
Delivery of USP Grade Oxygen at two pressure settings | The Cyl-Fil Oxygen System's high-pressure regulator delivers USP Grade oxygen at two pressure settings. One setting for filling the portable cylinder, ensuring it does not exceed the cylinder's safety rating. The second setting delivers USP oxygen to an auxiliary outlet for continuous oxygen therapy. |
Safe and effective operation for ambulatory oxygen use | The system is intended for patients prescribed oxygen for ambulatory use, allowing them to fill portable cylinders at home. It is deemed substantially equivalent in safety and effectiveness to predicate devices. |
System integrity for portable cylinder connection | The Cyl-Fil portable cylinder has a proprietary connection (similar to CGA-870 with additional pin/hole) unique to the system to maintain integrity. The regulator's initial outlet connects specifically to this portable cylinder. |
Maintenance of residual pressure in portable cylinder | The Cyl-Fil valve is designed to maintain a residual pressure (14 PSI to 72 PSI) to eliminate the need for evacuation between refills due to contamination, ensuring positive pressure is always retained. |
Compliance with relevant industry standards and safety ratings | Components are designed for 100% pure oxygen applications and tested accordingly. The device and its components (regulator, valve, cylinder) are stated to follow: CGA recommendations (Compressed Gas Association), DOT guidelines ("Compressed gas cylinders"), ISO 10297, ISO 15996, and ASTM G175. The regulator manufacturer (Inovo), valve manufacturer (Cavagna Group), and cylinder manufacturer (Luxfer Gas Cylinders) are established and certified (e.g., ISO certified) and are members of organizations instilling safety (CGA, DOT). |
Durability and structural integrity of components | Non-clinical tests performed include: Hydrostatic Test, Proof Pressure Test, Cycle Test, ASTM G175 (for regulator), and ISO 10297 & ISO 15996 (for valve). This indicates testing for pressure resistance, leakage, and endurance. |
Substantial equivalence to predicate oxygen regulators and valves | The Cyl-Fil regulator is stated to be substantially equivalent to other Class I Oxygen Regulators and Inovo's Oxygen Conserving Regulator (Class 2), citing similar components, material, and design. The Cyl-Fil portable cylinder valve is substantially equivalent to other Class I Oxygen cylinder valve manufacturers. The document repeatedly states "No significant difference in safety and effectiveness between Cyl-Fil and the above predicate devices." The additional features (two outlets, proprietary connection, residual pressure) are presented as allowing "the patient to utilize the supply gas more effectively" rather than posing new safety or effectiveness concerns. |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size for Test Set: Not applicable in the context of this 510(k) submission. No human subject "test set" data (e.g., patient cases) is mentioned. The testing refers to non-clinical, component-level engineering tests.
- Data Provenance: The data comes from non-clinical engineering tests performed on the device components (regulator, valve, cylinder) to ensure they meet specified standards and safety requirements. The specific testing facilities or retrospective/prospective nature of the engineering tests are not detailed beyond listing the types of tests and standards.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of Those Experts
- Not Applicable: This type of information is pertinent to studies involving expert review of medical images or other diagnoses to establish a "ground truth" for evaluating an algorithm or human performance. This 510(k) concerns a physical medical device (oxygen system) and its non-clinical performance, not diagnostic accuracy requiring expert ground truth.
4. Adjudication Method for the Test Set
- Not Applicable: Adjudication methods (like 2+1, 3+1) are used in clinical studies or algorithm evaluations where multiple experts provide opinions that need to be reconciled to establish a ground truth. This is not reported for the non-clinical engineering tests performed on the Cyl-Fil Oxygen System.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- No: A MRMC study was not done. This type of study assesses how human readers' performance (e.g., diagnostic accuracy) changes with and without AI assistance across multiple cases. It is not relevant for a physical oxygen delivery system.
6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study
- No: This is not an AI/algorithm-based device. Therefore, a standalone algorithm performance study is not applicable. The listed "Performance Testing" are standalone tests of the device's physical components.
7. Type of Ground Truth Used
- Engineering Standards and Specifications: The "ground truth" for the non-clinical tests is adherence to established engineering standards (ISO, ASTM, CGA, DOT) and the manufacturer's own safety and performance specifications for the components (e.g., pressure ratings, material compatibility with 100% oxygen, cycle life). The objective is to demonstrate that the device meets these pre-defined technical criteria.
8. Sample Size for the Training Set
- Not Applicable: There is no "training set" in the context of an AI algorithm for this device. If interpreted as samples used for development/testing of the physical device components, the text does not specify quantities beyond referring to "all brass constructed regulators and brass post valves" and "components are designed for use in 100% pure oxygen applications and tested accordingly." This implies standard manufacturing and quality control sample sizes for component testing.
9. How the Ground Truth for the Training Set Was Established
- Not Applicable: As there is no AI training set, this question is not relevant. The performance metrics for the device components are based on physical laws, material science, and established engineering standards.
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