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510(k) Data Aggregation
(50 days)
The Ultraxx™ Nephrostomy Balloon Catheter is used to dilate the musculofascial tract, renal capsule, and parenchyma to establish and maintain a percutaneous tract.
The Inflation Device is recommended for use with balloon dilatation catheters to create and monitor the pressure in the balloon and to deflate the balloon.
The Ultraxx™ Nephrostomy Balloon Catheter is a double-lumen catheter indicated for a nephrostomy procedure by dilating the musculofascial tract, renal capsule, and parenchyma to establish and maintain a percutaneous tract. The device is intended for limited duration use, not to exceed 24 hours in the body.
The Ultraxx Nephrostomy Balloon Catheter Set is comprised of the Ultraxx balloon catheter, Amplatz sheath, and inflation device. The Ultraxx Nephrostomy Balloon Catheter is constructed from a radiopaque nylon tubing with a dilatation balloon on its distal end. The outer diameter of the catheter is available in 6 French (Fr) with a working length of 55 centimeters (cm). The balloon of the catheter is constructed from polyethylene terephthalate (PET) and is available in nominal inflated diameters of 6 to 10 millimeters (mm) with a length of 15 cm. A radiopaque marker band is positioned on the distal end of the balloon catheter which confirms accurate placement of the catheter. The maximum rated balloon pressure is 20 atm. The Amplatz sheath is available in either polytetrafluoroethylene (PTFE) or a clear polyvinyl chloride (PVC). Both sheaths are available in inner diameters of 18, 24, or 32 Fr with a working length of 17 cm. The Cook Sphere Inflation Device was cleared on March 3, 2004 under K032840. The inflation device is a one-piece, plastic, disposable inflation device with a lock lever design to control the piston, a manometer, and a connecting tube with a male rotating adapter.
The set will be supplied sterile and is intended for one-time use. The set is packaged in a peel-open pouch with a three-year shelf life.
This document, K181713, is a 510(k) premarket notification for a medical device (Ultraxx™ Nephrostomy Balloon Catheter Set). For this type of submission, the primary goal is to demonstrate "substantial equivalence" to a legally marketed predicate device, rather than proving the device meets specific performance acceptance criteria through a traditional clinical study with a detailed test set, ground truth, and statistical analysis as one might find for a novel class III device or a new AI/ML-based diagnostic.
Therefore, the information typically included in a "Description of acceptance criteria and the study that proves the device meets the acceptance criteria" for a novel device, especially an AI one, is largely not applicable to this submission. This 510(k) explicitly states there were no changes to the subject device that would affect biocompatibility, sterility, or performance compared to the predicate devices.
However, I can extract the relevant information regarding the comparative claims made and the assessment of equivalence:
Device: Ultraxx™ Nephrostomy Balloon Catheter Set
Summary of Acceptance Criteria and Device Performance (as pertains to a 510(k) for substantial equivalence):
Acceptance Criteria (Implied for 510(k) Substantial Equivalence) | Reported Device Performance (as per 510(k)) |
---|---|
Identical Indications for Use to Predicate Device | Met: "identical indications for use" |
Identical Design to Predicate Device | Met: "identical... design" |
Identical Dimensions to Predicate Device | Met: "identical... dimensions" |
Identical Materials to Predicate Device | Met: "identical... materials" |
Identical Method of Operation to Predicate Device | Met: "identical... method of operation" |
Identical Fundamental Technological Characteristics to Predicate Device | Met: "identical... fundamental technological characteristics" |
No changes affecting Biocompatibility | Met: "no changes... that would affect biocompatibility" |
No changes affecting Sterility | Met: "no changes... that would affect... sterility" |
No changes affecting Performance | Met: "no changes... that would affect... performance" |
Packaging Integrity (for the new kit configuration) | Met: "Packaging integrity testing following simulated distribution was performed." "All predetermined acceptance criteria of the testing were met." |
Performance as Intended | Met: "perform as intended" |
Further Details (as per the provided document):
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Sample size used for the test set and the data provenance:
- Not applicable in the typical sense. This submission is based on demonstrating substantial equivalence to pre-existing, cleared devices. The "test set" here refers to the device itself and its components.
- The document mentions "Packaging integrity testing following simulated distribution was performed." The sample size for this specific test is not detailed, but it would have been an engineering/bench test rather than a clinical or data-driven evaluation of performance against a "test set" of patient data.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable. The "ground truth" for a 510(k) for substantial equivalence relies on comparison to a predicate device's known characteristics and performance, not on expert labeling of a dataset.
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Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Not applicable. No such adjudication process is described or implied for this type of submission.
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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 device is a physical medical device (catheter set) used in a procedure, not an AI/ML-based diagnostic or imaging device. Therefore, MRMC studies and AI assistance are irrelevant.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. As stated above, this is a physical medical device, not an algorithm.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc):
- Not applicable. The "ground truth" for this 510(k) is the established performance and characteristics of the predicate devices (K171601 and K032840), which presumably met their own regulatory requirements (likely via prior 510(k)s based on bench testing, limited animal/clinical data, and comparison to even older predicates).
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The sample size for the training set:
- Not applicable. No training set is used as this is not an AI/ML device.
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How the ground truth for the training set was established:
- Not applicable. No training set is used.
In conclusion, this 510(k) submission (K181713) for the Ultraxx™ Nephrostomy Balloon Catheter Set explicitly states that there were no changes to the device (Ultraxx balloon catheter, Amplatz sheath, and the Cook Sphere Inflation Device) that would affect biocompatibility, sterility, or performance compared to its predicate devices. The only "modification" from the predicate devices was that the two predicate devices (Ultraxx™ Nephrostomy Balloon Catheter and Cook Sphere Inflation Device) are now provided together as a convenience kit.
Therefore, the "study" proving the device meets acceptance criteria is primarily the demonstration of identical characteristics to the already cleared predicate devices, supported by specific bench testing for the new "packaging configuration" (packaging integrity testing following simulated distribution). The success criterion for this submission was demonstrating "substantial equivalence" to the predicates, which was met as indicated by the FDA’s clearance letter.
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The Gyrus ACMI EZDilate 3-Stage Balloon Dilatation Catheters are in adult and adolescent populations to endoscopically dilate strictures of the alimentary tract. It is also indicated in adults for endoscopic dilatation of the Sphincter of Oddi with or without prior sphincterotomy.
Both the predicate and proposed Gyrus ACMI EZDilate 3-Stage Balloon Dilatation Catheters consist of a semi-compliant nylon blow molded balloon; and, a shaft that communicates a fluid passage for expansion and collapse of the balloon portion, operated by an inflation device.
Like the predicate, the EZDilate Wire Guided Balloon is designed to be used with a 0.035 in. (0.89mm) guidewire and has a wire lumen sized appropriately. Each balloon catheter is packaged with a soft tip 0.035 in. (0.89mm) guidewire pre-loaded into the guidewire lumen. The guidewire is manufactured by Lake Region Medical; and, is cleared under K935198, Gastroenterology and Urology Guidewire Modifications. All wire-guided balloons with have lengths of 5.5cm and a catheter length of 240cm.
The balloon is inflated with a 60cc inflation device, which will be sold separately. The suggested inflation device is manufactured by Atrion (K032840).
The Gyrus ACMI EZDilate 3-StageWire Guided Balloon Dilatation Catheter is a reinforced catheter attached to a distal dilatation balloon. The semi-compliant balloon allows for a progressive radial expansion through three target sizes using one balloon. A silicone coating applied to the balloon increases ease of insertion, positioning of the balloon within the alimentary tract, and device removal.
The provided document K180086 describes the Gyrus ACMI EZDilate 3-Stage Balloon Dilatation Catheter and its substantial equivalence to predicate devices, rather than a clinical study establishing specific performance criteria against predefined metrics.
Therefore, I cannot provide:
- A table of acceptance criteria and reported device performance with numerical values, as these are not part of the substantial equivalence claim.
- Sample size used for the test set or data provenance, as this was not a clinical effectiveness study.
- Number of experts, their qualifications, or adjudication methods for ground truth, as ground truth establishment for a diagnostic output is not relevant here.
- Information on a multi-reader multi-case (MRMC) comparative effectiveness study or human reader improvement with AI assistance, as AI is not concerned in this submission.
- Information on a standalone algorithm performance, as AI is not concerned in this submission.
- Type of ground truth used (pathology, outcomes data, etc.), as this is a device clearance based on equivalence, not a diagnostic accuracy study.
- Sample size for the training set or how ground truth was established for it, as this is irrelevant for this type of device submission.
However, based on the provided text, I can infer the "acceptance criteria" and how the device (Gyrus ACMI EZDilate 3-Stage Balloon Dilatation Catheter) was shown to "meet" these criteria in the context of a 510(k) submission:
1. Acceptance Criteria (Implied for 510(k) Substantial Equivalence):
For a 510(k) submission, the primary "acceptance criterion" is demonstrating substantial equivalence to a legally marketed predicate device. This typically involves showing that the new device:
- Has the same intended use as the predicate device.
- Has the same technological characteristics as the predicate device, or that differences do not raise new questions of safety or effectiveness.
In this specific case, for the "minor process changes" that resulted in "rounders to the balloon; enhancing balloon visualization," the acceptance criteria for these particular changes would have been that the repeated performance tests demonstrated the device still met or exceeded the established specifications and safety profiles.
Reported Device Performance (against equivalence, not quantitative clinical metrics):
The submission asserts that the proposed Gyrus ACMI EZDilate 3-Stage Balloon Dilatation Catheter is "substantially equivalent" to the predicate devices and "presents no new questions of safety or effectiveness."
This is supported by:
- Identical intended use to a predicate Boston Scientific device (K112994).
- Identical design and scientific technology to its own predicate (K143609).
- No material changes from the predicate (K143609).
- Successful completion of a battery of performance tests following minor process changes.
2. Study that Proves the Device Meets the Acceptance Criteria:
The "study" in this context is the Traditional 510(k) Notification (K180086) document itself, which compares the new device to predicate devices and provides results from non-clinical performance testing.
Relevant information from the document:
- Sample size used for the test set and the data provenance: Not explicitly stated as this is a technical verification, not a clinical study. The performance tests would have been conducted on a sufficient number of device samples to ensure design verification and validation, according to internal company procedures and relevant standards.
- Number of experts and qualifications, and adjudication method: Not applicable as this is a device clearance based on engineering and design comparison, not subjective expert assessment of diagnostic output.
- If a multi-reader multi-case (MRMC) comparative effectiveness study was done, etc.: No, this is not an AI/diagnostic imaging device, and such a study was not performed or required for this type of 510(k) submission.
- If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable.
- The type of ground truth used: For the performance tests, the "ground truth" would be the established engineering specifications and safety limits for the device. For example, for "Balloon Burst Testing," the ground truth is a specific pressure at which the balloon must not burst, or a specific range. For "Dimensional Measurements," the ground truth is the specified dimensions.
- The sample size for the training set: Not applicable as this is not an AI/machine learning device.
- How the ground truth for the training set was established: Not applicable.
Specific Performance Tests Conducted (following minor process changes leading to improved balloon visualization):
The manufacturer conducted the following performance tests to demonstrate continued safety and effectiveness after minor process changes:
- Visual Inspection
- Dimensional Measurements
- Tensile Testing
- Fatigue Testing
- Luer Gauging Test
- Balloon Working Length
- Tip Stiffness Testing
- Compliance Testing
- Balloon Burst Testing
- Balloon Insertion Force Testing
- Balloon Retrieval Force Testing
- Balloon Friction Testing
- Balloon Deflation Testing
- Balloon Endoscope Compatibility Testing
The successful completion of these tests, along with the detailed comparison tables showing similarities in design features, intended use, and technological characteristics to the predicate devices, collectively serve as the "proof" that the device meets the implicit acceptance criteria for substantial equivalence to its predicates.
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The EZDilate 3-Stage Balloon Dilatation Catheters are in adult populations to endoscopically dilate strictures of the alimentary tract. It is also indicated in adults for endoscopic dilatation of Oddi with or without prior sphincterotomy.
The EZDilate 3-Stage Balloon Dilatation Catheter consists of a semi-compliant nylon blow molded balloon; and, a shaft that communicates a fluid passage for expansion and collapse of the balloon portion, operated by an inflation device. The EZDilate Wire Guided Balloon is designed to be used with a 0.035 in. (0.89mm) guidewire and has a wire lumen sized appropriately. Each balloon catheter is packaged with a soft tip 0.035 in. (0.89mm) guidewire pre-loaded into the guidewire lumen. All wire-guided balloons with have lengths of 5.5cm and a catheter length of 240cm. The balloon is inflated with a 60cc inflation device, which will be sold separately. The suggested inflation device is manufactured by Atrion (K032840).
The provided text describes a 510(k) premarket notification for a medical device, the EZDilate 3-Stage Balloon Dilatation Catheter. This type of submission focuses on demonstrating substantial equivalence to a legally marketed predicate device, rather than proving novel effectiveness or developing new acceptance criteria through extensive clinical studies. Therefore, much of the information requested in your prompt (e.g., sample size for test/training sets, number/qualifications of experts for ground truth, MRMC studies, standalone performance, adjudication methods) is not typically part of a 510(k) submission for this type of device and is not present in the provided document.
The "acceptance criteria" for a 510(k) are primarily demonstrating that the new device performs as intended and is as safe and effective as its predicate. The "study that proves the device meets the acceptance criteria" refers to the engineering and bench testing performed to show the device's functional integrity and similarity to the predicate.
Here's an attempt to answer your questions based on the available information, with explanations where information is not applicable or provided:
1. A table of acceptance criteria and the reported device performance
For a 510(k) relating to a balloon dilatation catheter, "acceptance criteria" are essentially the performance specifications derived from the device's design and intended use, and often benchmarked against its predicate. "Reported device performance" comes from bench testing. The document lists the types of tests performed.
Acceptance Criteria (Implied from tests and predicate comparison) | Reported Device Performance (Summary from "Summary of Performance Testing") |
---|---|
Mechanical Integrity/Dimensions: | Passed: |
- Correct dimensions | - First Article Inspection (Dimensional Measurements) |
- Resistance to tensile forces | - Tensile Testing |
- Ability to withstand repeated stress | - Fatigue Testing |
- Proper Luer connection | - Luer Gauging Test |
- Balloon working length as specified | - Balloon Working Length |
- Appropriate tip stiffness | - Tip Stiffness Testing |
Balloon Functionality: | Passed: |
- Consistent expansion across 3 stages | - Compliance Testing |
- Resistance to rupture at specified pressures | - Balloon Burst Testing |
- Ease of insertion | - Balloon Insertion Force Testing |
- Low friction for movement within scope | - Balloon Friction Testing |
- Effective deflation | - Balloon Deflation Testing |
- Compatibility with endoscopes | - Balloon Endoscope Compatibility Testing |
Biocompatibility: | Passed: |
- Non-toxic, non-irritating, non-sensitizing | - ISO 10993-1, 10993-5, 10993-7, 10993-10 (Compliance to standards) |
Sterility/Shelf Life: | Passed: |
- Sterile upon delivery (EO sterilization) | - Sterilization validated (Ethylene oxide) |
- Maintains integrity over time | - Six month shelf life data submitted (product launched with 3-year shelf life post-submission) |
Packaging Integrity: | Passed: |
- Maintain sterility and product integrity | - ISTA P2A, ASTM D4169-09, ASTM F2096-11, ASTM F88/F88M:2009, |
ASTM F1886/F1886M:2009, ASTM F1980-07 (Compliance to standards) |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Sample Size for Test Set: Not specified in the document. For bench testing of physical devices, sample sizes are typically determined by statistical methods for specific tests but are not explicitly reported in this summary.
- Data Provenance: The study described is entirely in-vitro bench testing of the device's physical and functional properties, performed by the manufacturer/contract manufacturer. There is no patient data involved (retrospective or prospective). The location of the testing laboratories is not specified beyond the manufacturer's location in the USA.
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)
- Not applicable. "Ground truth" in the context of device performance in a 510(k) for this type of device is established through engineering specifications, material properties, and comparison to the predicate device's known performance characteristics. Expert panels for diagnostic accuracy or clinical outcomes are not part of this type of submission.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable. Adjudication methods like 2+1 or 3+1 are used in clinical studies, particularly for diagnostic devices, to resolve disagreements among human readers or experts. This submission is based on bench 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
- Not applicable. MRMC studies are typically for diagnostic AI-powered devices to assess how the AI impacts human reader performance. The EZDilate is a physical medical device (catheter) and does not involve AI assistance or human readers in the context of diagnostic interpretation.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not applicable. This device is not an algorithm. "Standalone performance" refers to the performance of a diagnostic algorithm without human intervention, which is not relevant here.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- For this device, the "ground truth" for the bench testing is defined by engineering specifications, material standards (e.g., ISO, ASTM), and the performance characteristics of the legally marketed predicate device (Boston Scientific CRE Dilatation Balloon K112994). The tests confirm that the EZDilate catheter meets these predefined physical and functional benchmarks.
8. The sample size for the training set
- Not applicable. There is no concept of a "training set" for physical medical device submissions like this. Training sets are relevant for machine learning algorithms.
9. How the ground truth for the training set was established
- Not applicable, as there is no training set.
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