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510(k) Data Aggregation
(181 days)
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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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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