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510(k) Data Aggregation
(483 days)
The Dräger Alcotest 6510 is an apparatus for indicating the presence of alcohol in the breath.
The Dräger Alcotest 6510 is a device intended to measure alcohol in human breath. Measurements obtained by this device are used in the diagnosis of alcohol intoxication.
The Drager Alcotest 6510 is designed to measure deep lung air to determine the level of alcohol in the blood. The alcohol sensor is of the electrochemical fuel cell type. As the user's breath moves through the sensor, the sensor generates an electrical current that is proportional to the concentration of ethanol in the breath.
Here's an analysis of the provided text regarding the Dräger Alcotest 6510, focusing on acceptance criteria and study details:
The provided 510(k) summary for the Dräger Alcotest 6510 does not explicitly define specific numerical acceptance criteria for its performance. Instead, it relies on demonstrating substantial equivalence to a predicate device (OmegaPoint Systems Personal Breath Alcohol Tester BreathKey™ Model G10 and BreathKey™ Model G30X) and general conformance to Department of Transportation (DOT) standards. The study mentioned focuses on user understanding and proper device usage rather than quantitative performance metrics against a defined ground truth.
Therefore, a table of acceptance criteria and reported device performance as typically understood for diagnostic devices with specific sensitivity/specificity targets cannot be fully generated from this document. However, I can infer the implicit "acceptance criteria" and what was reported for overall safety and effectiveness:
Implicit Acceptance Criteria and Reported Device Performance
Criteria Category | Implicit Acceptance Criteria | Reported Device Performance |
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Safety | The device is safe for its intended use. | "The results of bench, DOT and user testing indicates that the new device is as safe and effective as the predicate device." "After analyzing bench tests, electrical safety...it can be concluded that Dräger Alcotest 6510 is as safe and effective as the predicate and comparative devices." |
Effectiveness | The device is effective in indicating the presence of alcohol in the breath and determining the level of alcohol in the blood, comparable to the predicate device. Users should be able to read, understand, and properly use the device to obtain comparable results. | "The results of bench, DOT and user testing indicates that the new device is as safe and effective as the predicate device." "User studies showed that intended users of the device could read and understand the instructions, could properly use the device and obtain results that were comparable to those provided by a predicate device administered by a trained individual." |
Substantial Equivalence | The device is substantially equivalent to the predicate device in terms of indications for use, construction, sensor type, anatomical site, test sample, and general performance (after considering differences in specific parameters like measurement range, blowing time, etc., and ensuring these differences do not raise new questions of safety or effectiveness). | Detailed comparison table provided, highlighting similarities (Indications for Use, Construction, Sensor, Anatomical Site, Test Sample, DOT approval) and differences (Where Used, Measurement Range, Blowing Time, Mouthpiece, Power source, Warm-up time, Size, Weight). The conclusion explicitly states "Dräger Alcotest 6510 is as safe and effective as the predicate and comparative devices." |
User Comprehension/Usage | Intended users can understand instructions and properly operate the device. | "A clinical trial was performed to establish that the user could read and understand the instructions provided, and properly use the device." "User studies showed that intended users of the device could read and understand the instructions, could properly use the device..." |
Here's the additional information based on the provided text:
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Sample size used for the test set and the data provenance:
- Sample Size: The document refers to "user testing" and "user studies" and a "clinical trial" but does not specify a numerical sample size for these tests.
- Data Provenance: Not explicitly stated (e.g., country of origin). The submission is from Germany, but the testing location is not mentioned. It can be inferred as prospective given the nature of a "user testing" or "clinical trial" to establish user understanding and proper usage.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- The document implies that the comparison for "comparable results" was against a "predicate device administered by a trained individual." This "trained individual" or the data from the predicate device serves as an indirect form of ground truth comparison.
- However, the number and specific qualifications of experts involved in establishing a formal "ground truth" for the test set (e.g., a panel of toxicologists or law enforcement officers interpreting results) are not specified. The focus of the highlighted clinical trial was user understanding and proper usage, not an independent assessment of accuracy against a gold standard performed by multiple experts.
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Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- The document does not describe any formal adjudication method. The "user studies" primarily assessed if users could properly use the device and obtain "comparable results" to a predicate device. This suggests a direct comparison rather than a multi-reader/multi-adjudicator approach.
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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, an MRMC comparative effectiveness study was not done. This device is a standalone breath alcohol tester, not an AI-assisted diagnostic tool that would involve "human readers" or "AI assistance" in the typical sense of MRMC studies for image analysis or other complex diagnoses. The "user studies" evaluated human users' ability to operate the device, not an improvement in their diagnostic performance with AI.
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If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
- The Dräger Alcotest 6510 is a standalone device without a human-in-the-loop AI component. Its performance is the algorithm (electrochemical fuel cell sensor converting breath ethanol to an electrical current, processed by an internal microprocessor) combined with the user's interaction.
- The "bench tests" and "DOT conformance testing" represent evaluations of the device's technical, standalone performance against controlled standards and specifications. The document states these results were analyzed.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- The primary ground truth implied for this device's effectiveness is its ability to produce results "comparable to those provided by a predicate device administered by a trained individual" and its DOT approval. For breath alcohol, the "ground truth" (or gold standard) in regulatory contexts often involves laboratory blood alcohol concentration (BAC) measurements or highly calibrated, legally accepted evidential breath testing devices.
- For the "user testing" specifically, the ground truth was the correct operation of the device and the comprehension of instructions, likely assessed by observers or direct comparison.
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The sample size for the training set:
- The document does not mention a training set in the context of machine learning or AI development. This device is based on established electrochemical fuel cell technology, not on a machine learning model that would require a separate training set.
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How the ground truth for the training set was established:
- As no training set (for AI/ML) is mentioned, this question is not applicable. The device's underlying principles are physics and chemistry-based, with calibration and validation typically performed through bench testing and comparisons to established standards.
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