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510(k) Data Aggregation

    K Number
    K182302
    Date Cleared
    2019-05-17

    (266 days)

    Product Code
    Regulation Number
    870.4210
    Reference & Predicate Devices
    Predicate For
    N/A
    Why did this record match?
    Reference Devices :

    K043179

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The CardioGard Emboli Protection Cannula combines the function of a standard arterial cannula with an added suction mechanism to capture debris that may result from cardiac surgery.

    The CardioGard Emboli Protection Cannula is intended for perfusion of the ascending aorta during short term (<6 hours) cardiopulmonary bypass (CPB) procedures. The CardioGard suction lumen is intended for the removal of particulate emboli during surgical procedures that require CPB.

    Device Description

    The CardioGard Emboli Protection Cannula (CardioGard Cannula) is a sterile, single-use, disposable double lumen arterial cannula. The CardioGard Cannula features a tip configuration that diffuses oxygenated blood from the heart-lung machine into the ascending aorta through the Cannula Outlet, while also aspirating blood and embolic matter through the Suction Lumen Inlet. The flow rates through the two cannula lumens are carefully controlled so that emboli are suctioned back to the heart-lung machine for filtration while still enabling sufficient blood flow to the patient.

    AI/ML Overview

    This document describes a 510(k) premarket notification for the CardioGard Emboli Protection Cannula, assessing its substantial equivalence to a previously cleared device (K141465). The focus of the changes in the modified device is to reduce device bulk and improve ease of use, while maintaining safety and effectiveness.

    Here's an analysis of the acceptance criteria and supporting studies:

    1. Table of Acceptance Criteria and Reported Device Performance:

      The document provides a comparative table (starting on page 5) outlining various design and performance characteristics between the "Cleared Device" (predicate) and the "Modified Device" (current submission). It doesn't explicitly state "acceptance criteria" for each row, but rather describes how the modified device compares to the predicate and notes whether they are "Same" or "Substantially equivalent" with a discussion of differences.

      ParameterAcceptance Criteria (Implied)Reported Device Performance (Modified Device)
      Intended UseSame as predicate.Same as predicate.
      Use DurationSame as predicate (≤ 6 hours).Same as predicate (≤ 6 hours).
      Cannula DesignSubstantially equivalent to predicate, aiming for reduced bulk and improved ease of use.Two lumen, curved tip with two ports (aortic perfusion, embolic particle suction). Suction tube angles 90° to reduce cannula profile.
      Tip Angle30° to 60° (same as predicate).30° to 60° (substantially equivalent).
      Tip ShapeSubstantially equivalent to predicate, with features for ease of insertion and reduced back pressure.Angled and tapered with dispersion side holes. Tip tapered for ease of insertion, dispersion side holes added to reduce back pressure.
      FlangeRedesigned for ease of suturing.Redesigned flange to facilitate suturing in place.
      DimensionsSubstantially equivalent to predicate, with slight modifications to reduce bulk and improve ease of use.Tip Size: Starts at 24Fr, ends at 22Fr. Main tube: diameter: 5/16" tapered to 3/8", length: 19–21 cm. Suction tube: diameter: 3/16" tapered to 1/4", length: 18–19 cm. (Slight modifications from predicate for bulk reduction/ease of use).
      ConnectorsAddition of connector to suction tube for user convenience.Connectors on both main and suction tubes (added connector to suction tube for user convenience).
      CapsColor-coded caps on both tubes for user convenience.Caps on both tubes: red for main tube and yellow for suction tube (color-coded for user convenience).
      Main (perfusion) Flow Rate1 - 6 L/min (same as predicate).1 - 6 L/min (same).
      Suction Flow Rate0 - 1.0 L/min (reduced maximum from predicate to ensure 5 L net forward flow).0 - 1.0 L/min (substantially equivalent, max suction flow rate reduced to provide for 5 L net forward flow).
      Pressure DropWithin accepted range for aortic cannulas (substantially equivalent to predicate).Pressure drop for both devices within accepted range for aortic cannulas (graphical comparison indicates substantial equivalence).
      Biological Safety - MaterialsBiocompatibility confirmed in accordance with ISO 10993.Tip: Polycarbonate (changed from PVC). Tubes: PVC (Plastisol) with stainless steel inner spring (same). Connectors: Polycarbonate (changed from ABS plastic). Caps: Polyethylene with PVC (Plastisol) outer cover (changed from Polyethylene). Biocompatibility confirmed.
      SterilizationEtO sterilized, single-use, disposable, non-pyrogenic (same method and characteristics).EtO sterilized, single-use, disposable, non-pyrogenic (same).
      EtO Sterilization ValidationSAL 10^-6^ using overkill method, half-cycle technique (EN ISO 11135-1:2008), EO/ECH residuals < ISO 10993-7:2008 limits.Validated to SAL 10^-6^; EO and ECH residual levels comply with ISO 10993-7.
      LAL Endotoxin TestingEndotoxin levels < 0.5 EU/mL extract or < 20 EU/device.Verified endotoxin levels well below limits for medical devices in contact with cardiovascular system (≤0.5 EU/mL extract or ≤20 EU/device).
      Pyrogenicity TestingPyrogen-free.Verified pyrogen-free.
      Biocompatibility TestingMeet acceptance criteria of applicable standard (ISO 10993-1:2009 for externally communicating devices, <24 hours contact with blood).All tests (cytotoxicity, irritation, sensitization, acute systemic toxicity, genotoxicity/mutagenicity, hemolysis, partial thromboplastin time, complement activation, in-vivo thrombogenicity) met acceptance criteria.
      Packaging IntegrityMeet pre-defined acceptance criteria at all time periods (time 0, env. conditioning, simulated transport, 3-year accelerated aging).All tests (Peel Strength, Burst, Dye Penetration, Package Label integrity) met pre-defined acceptance criteria.
      Device IntegrityMeet pre-defined acceptance criteria at all time periods (time 0, env. conditioning, simulated transport, 3-year accelerated aging).All tests (Visual Inspection, Dimensional Verification, Force at Break, Tip force at break, Pressure Drop, Back pressure, Liquid Leakage, Tube kinking, Tube bending, Tube hardness, Resistance to clamping, Tube printing ink integrity) met pre-defined acceptance criteria.
      Dynamic HemolysisSimilar gradual increases in plasma free hemoglobin as compared to a commercially available arterial cannula (Medtronic Select 3D II).Demonstrated similar gradual increases in plasma free hemoglobin to the Medtronic Select 3D II (K043179).
      Functional PerformanceSubstantially equivalent embolic particle capture as compared to the original CardioGard Cannula under simulated use conditions.Demonstrated substantially equivalent embolic particle capture as compared to the original CardioGard Cannula (K141465) in a simulated use test.
    2. Sample sizes used for the test set and data provenance:

      • Functional Performance (Simulated Use Test): The document states "The functional performance of the modified CardioGard Cannula was validated a simulated use test set-up with direct comparison to the predicate device." It does not specify the numerical sample size for this test. It refers to "test conditions simulating aortic manipulation, maximum flow rates, and typical flow rates."
      • Dynamic Hemolysis Testing: Conducted in an "in vitro blood loop with bovine blood circulating at a net forward flow of 5 L/min for 6 hours." No specific numerical sample size for devices is given.
      • Packaging and Device Integrity Tests: Performed at "time 0 and after environmental conditioning, simulated transportation, and 3-year accelerated aging." No specific numerical sample size for devices is given.
      • Provenance: All nonclinical data appears to be from in-vitro laboratory testing or simulated environments, not from human or animal subjects, therefore data provenance in terms of country of origin or retrospective/prospective clinical study is not applicable in the usual sense.
    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

      Not applicable. The tests performed are non-clinical (laboratory and simulated use tests), not involving human interpretation or clinical ground truth established by medical experts for a "test set" as typically understood in AI/imaging studies.

    4. Adjudication method for the test set:

      Not applicable, as this is not a study requiring expert adjudication of results.

    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 comparative effectiveness study was not done. This device is a medical cannulation tool, not an AI software/diagnostic device that would involve human readers or AI assistance in interpretation.

    6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:

      Not applicable. This is a physical medical device, not an algorithm or AI system. The "functional performance" mentioned refers to the device's physical ability to capture particles in a simulated environment.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

      The "ground truth" for the non-clinical tests is established by:

      • Standardized testing methodologies: Adherence to international standards (e.g., EN ISO 11135-1:2008 for sterilization, ISO 10993-7:2008 for residuals, USP <85> for endotoxins, USP <151> for pyrogenicity, ISO 10993-1:2009 for biocompatibility).
      • Direct comparison to a legally marketed predicate device: For dynamic hemolysis and functional performance (embolic particle capture), the performance of the modified device was compared against the predicate device (K141465) or another commercially available arterial cannula (Medtronic Select 3D II).
      • Pre-defined acceptance criteria: For packaging and device integrity, explicit acceptance criteria were used.
    8. The sample size for the training set:

      Not applicable. This is a physical medical device, not an AI/machine learning system that requires a "training set."

    9. How the ground truth for the training set was established:

      Not applicable, as no training set was used.

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