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510(k) Data Aggregation

    K Number
    K202699
    Date Cleared
    2020-12-29

    (104 days)

    Product Code
    Regulation Number
    868.5140
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K111374, K013041, K062900, K082164

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

    The E-Cath STIM acc. Tsui System is indicated for delivery of medication for regional anesthesia and pain management. Route of administration may be intraoperative, percutaneous, or perineural. To assist the physician pinpoint the area of application an electrical stimulus can be applied to the conduction needle removal, to assist the physician pinpoint conduction catheter placement, an electrical stimulus can be applied to the conduction catheter tip via the catheter adapter.

    The E-Cath STIM acc. Tsui System is contraindicated for the epidural space.

    Device Description

    The Over-the-needle (OTN) Catheter Systems are available in different designs with cannula and catheter in different sizes. The system includes: SonoPlex cannula, permanent cannula, E-Cath catheter, locking cap.

    AI/ML Overview

    The provided document is a 510(k) premarket notification for a medical device (E-Cath STIM acc. Tsui). It is a special 510(k) for a device modification, intending to combine features from previously cleared devices. The document mainly focuses on demonstrating substantial equivalence to predicate devices through bench testing and compliance with recognized standards, rather than clinical studies with human participants. Therefore, several of the requested categories, such as "multi-reader multi-case (MRMC) comparative effectiveness study," "sample size for the test set," "number of experts," "adjudication method," and "standalone (i.e., algorithm only) performance" are not applicable to this type of submission.

    Here's a breakdown of the available information:

    1. Table of Acceptance Criteria and the Reported Device Performance:

    TestAcceptance CriteriaReported Device Performance
    Needle: Bending RigidityAccording to EN ISO 9626: ≤ 0.48mm under an applied force of 15N by a span width of 17.5mm.The bending rigidity of the subject/predicate/reference device's needles is less than 0.46mm. Conclusion: In compliance.
    Needle: Breaking ResistanceAccording to EN ISO 9626: Not to break during a bending test for 20 periods at an angle defined by cannula size.The tested cannulas did not break during the test. Conclusion: In compliance.
    Needle: Bonding to HubAccording to EN ISO 7864: Pull-off force ≥ 44N.For the subject/predicate/reference device's needles, a force significantly higher than the target value has to be applied. Conclusion: In compliance.
    Needle: Penetration ForceEN 13097: No specific pass/fail criteria; objective comparison only.The subject/predicate/reference device's needles show appropriate penetration/insertion forces. Compared to the predicate device, PAJUNK's needles are in compliance. Conclusion: In compliance.
    Catheter: Leak TightnessInternal protocols based on risk assessment and clinical evaluation (standard DIN EN 1618 does not define criteria). Catheter system must be tight for a defined period and pressure.All systems are tight during the test for both the subject device and the predicate/reference devices. Conclusion: In compliance. The subject/predicate/reference device's catheters meet the acceptance criterion.
    Catheter: Tensile StrengthInternally defined acceptable value to be met without tear-off (standard DIN EN 10555-1 and DIN EN 1618 do not define criteria).The catheters of the E-Cath Systems meet the acceptance criterion (without tear-off). Conclusion: In compliance. The subject/predicate/reference device's catheters meet the acceptance criterion.
    Catheter: Flow RateInternally defined by the sponsor based on risk management and clinical evaluation (standard DIN EN 10555-1 and DIN EN 1618 do not define criteria).The flow rate of the tested E-Cath catheter meets the acceptance criterion. The subject/predicate/reference device's catheters meet the acceptance criterion and have proven to supply appropriate flow rates.

    2. Sample Size Used for the Test Set and the Data Provenance:

    • Sample Size: Not explicitly stated for each test, but implied to be sufficient for demonstrating compliance with the referenced ISO/EN standards for medical device components. The tests refer to "tested cannulas" and "tested catheters."
    • Data Provenance: Bench testing, compliance with international standards (ISO, EN, DIN). Results are compared against predicate and reference devices, implying these are internal company data.
    • Retrospective/Prospective: Not applicable in the context of bench testing for a device modification. The tests are performed on the device itself.

    3. 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 these tests is defined by international standards (e.g., ISO 9626, ISO 7864, DIN EN 1618, DIN EN 10555-1) and internal protocols for performance criteria where standards are not specific. This does not involve expert medical opinion for "ground truth" in the diagnostic sense.

    4. Adjudication Method for the Test Set:

    • Not applicable. Performance is measured against predefined, objective, quantifiable acceptance criteria established by international standards or internal engineering/risk assessment protocols.

    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. This is a medical device (anesthesia conduction kit), not an AI diagnostic or image analysis system.

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

    • Not applicable. This is a physical medical device.

    7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.):

    • The "ground truth" for the device's performance is established by compliance with recognized international standards for medical device components (e.g., mechanical properties, sterility, biocompatibility) and internal engineering/risk assessment protocols where standards allow for manufacturer-defined criteria (e.g., leak tightness, tensile strength, flow rate).

    8. The Sample Size for the Training Set:

    • Not applicable. This is not a machine learning model, so there is no "training set."

    9. How the Ground Truth for the Training Set was Established:

    • Not applicable. As above, this is not a machine learning model.
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    K Number
    K152952
    Device Name
    E-Cath
    Date Cleared
    2016-07-13

    (281 days)

    Product Code
    Regulation Number
    868.5120
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K111374, K033018, K013041, K082164

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

    The Over-the-needle (OTN) Catheter System is indicated for delivery of medication for regional anesthesia and pain management. Route of administration may be intraoperative, percutaneous, or perineural. The Over-the-needle (OTN) Catheter System is contraindicated for the epidural space.

    Device Description

    The Over-the-needle (OTN) Catheter Systems are available in different designs with cannula and catheter in different sizes. The system includes: SonoPlex cannula, permanent cannula. E-Cath catheter, filter, FixoLong or FixoCath, locking cap and optional ultrasound cover.

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for a medical device, the "Over-the-Needle (OTN) Catheter System E-Cath." The purpose of the document is to demonstrate that this new device is substantially equivalent to legally marketed predicate devices, meaning it is as safe and effective.

    The supplied text pertains to a medical device, specifically an anesthesia conduction catheter, not an AI/imaging device. Therefore, many of the requested criteria for AI/imaging device studies (like MRMC studies, expert consensus for imaging, training set details) are not applicable to this document. The "tests" described are engineering and material property tests to ensure the physical device meets relevant standards and performs comparably to its predicate.

    However, I can extract the relevant acceptance criteria and study information that is present in the document for this specific type of medical device:


    Device Acceptance Criteria and Performance

    The document demonstrates substantial equivalence by comparing the new device against predicate devices and relevant international standards through various bench tests.

    1. Table of Acceptance Criteria and Reported Device Performance

    Test CategorySpecific Test / ParameterAcceptance CriteriaReported Device Performance
    Intended UseIndication for UseSubstantially Equivalent to predicate device K143164 regarding delivery of medication for regional anesthesia and pain management (intraoperative, percutaneous, or perineural administration), and contraindicated for epidural space.The subject device's Indications for Use are identical to the predicate device K143164.
    Needle StabilityBending Rigidity≤ 0.48mm under an applied force of 15N by a span width of 17.5mm (according to EN ISO 9626).The bending rigidity of both the predicate device's needles and the subject device's needles is less than 0.46mm. Additionally, the tested cannulas did not break during the breaking resistance test (bent at a defined angle for 20 periods, meaning bent in two directions), meeting the acceptance criterion of "not to break."
    Bonding to Hub≥ 44N pull-off force (according to EN ISO 7864).For both the subject device's and predicate device's needles, a force significantly higher than 44N was required to achieve pull-off. The cannula meets this acceptance criterion.
    Penetration ForceNot explicitly defined (objective comparison only per EN 13097).The subject device's needles as well as the predicate device's needles show equivalent penetration/insertion forces.
    Catheter PerformanceLeak TightnessDefined through internal protocols based on risk assessment and clinical evaluation (standard DIN EN 1618 does not define criteria).The catheters of both the subject device and the predicate device meet the acceptance criterion for tightness (i.e., both are tight during the test for a defined period and pressure).
    Tensile StrengthDefined through internal protocols based on risk assessment and clinical evaluation; "internally defined acceptable value to be met without tear off" (standard DIN EN 10555-1 and DIN EN 1618 do not define criteria).The catheters of both the subject device and the predicate device meet the acceptance criterion (i.e., they meet the internally defined "must-value" without tear off).
    Flow RateDefined through internal protocols based on risk assessment and clinical evaluation; "internally defined must-value" (standard DIN EN 10555-1 and DIN EN 1618 do not define criteria).The catheters of both the subject device and the predicate device meet the acceptance criterion and have proven to have equivalent flow rates.
    SterilizationSterility Assurance Level (SAL)10⁻⁶Achieved using Ethylene Oxide sterilization (validated according to ISO 11135-1 Overkill Approach: 1 sublethal, 2 half, 1 full cycle).
    ResidualsEO: 25ppm (25µg/g/device); ECH: 25ppm (25µg/g/device); Pyroburden/endotoxin: 0.06 EU/ml and 2.15 EU/device (acc. to FDA GUIDELINE ON VALIDATION OF LIMULUS AMEBOCYTE LYSATE TEST).All limits for residuals (EO, ECH) and pyroburden/endotoxin are met.
    Shelf LifeSterility & PerformanceRemains sterile and performs as intended for 5 years.Sterility tests after 5 years on worst-case devices showed they remained sterile. Performance tests (LUER connection, bonding stability, tensile strength, bending rigidity) on real-time aged components showed no decrease in performance after 5 years.
    BiocompatibilityBiocompatibility ISO 10993-1Compliant with ISO 10993-1, 2nd and 3rd edition.Components meet biocompatibility requirements, evidenced by successful completion of tests including: In vitro Cytotoxicity (ISO 10993-5), Irritation (ISO 10993-10), In vitro Haemolysis Test (ISO 10993-04), Acute Systemic Toxicity (ISO 10993-11), Test for delayed type hypersensitivity (ISO 10993-10), Reverse Mutation Assay (ISO 10993-03), Implantation (ISO 10993-06), Implantation Histopathology (ISO 10993-06).

    Study Details (as applicable to a non-AI medical device 510k submission)

    2. Sample size used for the test set and the data provenance:

    • The document does not explicitly state the sample sizes for the "bench tests" performed. It refers to standard test procedures (e.g., EN ISO 9626, EN ISO 7864, EN 13097, DIN EN 1618, DIN EN 10555-1). These standards typically specify minimum sample sizes for material and performance testing.
    • The data provenance is from Germany (PAJUNK GmbH Medizintechnologie is based in Baden-Wuerttemberg, Germany, and the contract sterilizer is in Wiesbaden, Germany).
    • The studies were prospective bench tests comparing the new device to the predicate and to established international standards.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    • This is not applicable as the "ground truth" for this device is based on compliance with engineering and material standards and direct comparison of physical properties with an already FDA-cleared predicate device. It does not involve subjective expert assessment of medical images or clinical outcomes in the same way as an AI diagnostic tool. Compliance is proven by laboratory testing measurements.

    4. Adjudication method for the test set:

    • This is not applicable. The "tests" are objective measurements against defined engineering standards and comparisons to a physical predicate device, not subjective assessments requiring adjudication.

    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. This is a physical medical device (catheter system), not an AI-assisted diagnostic tool. No human reader studies (MRMC or otherwise) were conducted or relevant for this type of submission.

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

    • This is not applicable. This question pertains to AI algorithms. The device is a physical catheter system, not an algorithm. Bench tests were performed on the physical device itself.

    7. The type of ground truth used:

    • The "ground truth" (or basis for acceptance) for this submission is:
      • International Engineering Standards: e.g., EN ISO 9626, EN ISO 7864, EN 13097, DIN EN 10555-1, DIN EN 1618 for physical properties, ISO 11135-1 for sterilization, ISO 10993-1/4/5/6/7/10/11 for biocompatibility.
      • Comparison to a Legally Marketed Predicate Device: Direct comparison of physical and performance characteristics to the Halyard - Irvine: On-Q QuikBloc Over-the-Needle (OTN) Catheter Set (K143164).
      • Internal Protocols and Clinical Evaluation: For some properties where international standards did not define specific pass/fail criteria (e.g., catheter leak tightness, tensile strength, flow rate), PAJUNK® established internal acceptable values based on risk assessment and clinical evaluation.

    8. The sample size for the training set:

    • This is not applicable. This is a physical medical device, not an AI model requiring a training set.

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

    • This is not applicable. As above, no training set for an AI model was used.
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