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510(k) Data Aggregation

    K Number
    K162271
    Date Cleared
    2017-04-26

    (257 days)

    Product Code
    Regulation Number
    880.5570
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K132880

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

    The Medcomp® Pro-Lock CT Safety Infusion Set is intended for use in the administration of fluids and drugs as well as blood sampling through implanted vascular access ports. The Medcomp Pro-Lock CT Safety Infusion Set is also indicated for power injection of contrast media into the central venous system with implanted vascular access ports indicated for power injection. The maximum recommended infusion rate at 11.8 cPs is 5ml/sec for 20 gauge non-coring Huber style needles.

    Device Description

    The 20G x ¾" (19mm) Pro-Lock™ CT Safety Infusion Set is composed of a Huber style needle for port septum access having a safety feature designed to aid in the prevention accidental needle sticks when manually activated during needle removal. The needle is connected to a conventional style extension set. The proximal end of the extensions tubing attaches to a female Luer connector with removable cap creating a fluid path to the port. A nonremovable pinch clamp is located between the female Luer and needle cannula which is designed to restrict fluid flow through the extension tubing when engaged. The needle cannula is constructed with a Huber style needle. The cannula is stainless steel and is shielded by a removable star needle guard of plastic construction.

    AI/ML Overview

    The provided document is a 510(k) Premarket Notification from the FDA for a medical device (Pro-lock™ CT Safety Infusion Set). It focuses on demonstrating substantial equivalence to a predicate device through performance testing and biocompatibility.

    Therefore, many of the requested criteria, such as those related to AI algorithm performance studies (e.g., sample size for training set, number of experts for ground truth, MRMC studies, standalone performance), are not applicable to this type of device submission. This document describes a physical medical device, not an AI/ML software device.

    However, I can extract information related to the device's acceptance criteria and studies to demonstrate its performance where applicable from the document.


    Here's an analysis based on the provided document:

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria are implicitly defined by the successful completion of the listed tests and the demonstration of substantial equivalence to the predicate device. The document does not explicitly state quantitative acceptance limits for each test in a table, but rather lists the tests performed to ensure the device meets relevant standards and performs similarly to the predicate.

    Test PerformedTest Method / Acceptance (Implicitly met if "results...effectively demonstrate" as stated)Reported Device Performance (as compared to predicate)
    Functional/Performance Tests
    Priming VolumePer Internal Test MethodProposed Device: 0.20cc
    Predicate Device: 0.18cc (Difference noted, but implied acceptable due to substantial equivalence claim)
    Gravity FlowISO 10555-1: 2013Not explicitly detailed, but implied to be comparable to predicate.
    Needle Insertion/Extraction ForceISO 10555-6: 2015Not explicitly detailed, but implied to be comparable to predicate.
    Air LeakageISO 8536-8: 2004Not explicitly detailed, but implied to be comparable to predicate.
    Liquid LeakageISO 10555-1: 2013, Annex CNot explicitly detailed, but implied to be comparable to predicate.
    Luer Lock FittingsISO 594-2: 1998Not explicitly detailed, but implied to be comparable to predicate.
    Occlusion with ClampPer Internal Test MethodDevice designed to restrict fluid flow when engaged.
    Extension Tensile and % ElongationISO 10555-1: 2013Not explicitly detailed, but implied to be comparable to predicate.
    Power Injection SimulationISO 10555-1: 2013Maximum Infusion Rate: 5 ml/sec at 11.8 cPs for 20 gauge. Maximum Flow Rate: 5ml/second at 325 psi max. (Matches predicate specifications).
    Port Septum/Needle Evaluation for CoringPer Internal Test MethodDevice is "anti-coring Huber style needle."
    Break Pull Test/Static Load Pull TestISO 10555-1: 2013Not explicitly detailed, but implied to be comparable to predicate.
    Needle to Extension Joint PullISO 10555-1: 2013Not explicitly detailed, but implied to be comparable to predicate.
    Corrosion ResistanceISO 11070: 2014Not explicitly detailed, but implied to be acceptable.
    Shelf Life (3 years)ISO 11607-1: 2009+A1:2014, ASTM F1980-16, ISO 10555-1: 2013, ASTM F-1929-15, ASTM F-1140Not explicitly detailed, but implied to be met.
    Shipping TestISO 11607-1: 2009+A1:2014, ISTA-2A-2011, ASTM F-1929-15, ASTM F-1140Not explicitly detailed, but implied to be met.
    Simulated Use Study: Sharps Injury PreventionFDA's Guidance: Medical Devices with Sharps Injury Prevention FeaturesDevice has a "safety feature designed to aid in the prevention accidental needle sticks when manually activated during needle removal." Ergonomics of safety feature improved over predicate.
    Living Hinge FatiguePer Internal Test MethodNot explicitly detailed, but implied to be acceptable.
    Force at BreakPer Internal Test MethodNot explicitly detailed, but implied to be acceptable.
    Evaluation of Magnetic Field Interactions, Heating, and ArtifactsASTM F2052-15, ASTM F2119-07, F2182-11a, F2213-06, F 2503-13Not explicitly detailed, but implied to be acceptable for MRI compatibility.
    Biocompatibility Tests
    Sensitization/IrritationISO 10993-10: 2010Biocompatibility performed per ISO 10993-1, endpoints tested successfully. (Implicitly acceptable).
    Acute Systemic ToxicityISO 10993-11: 2006Biocompatibility performed per ISO 10993-1, endpoints tested successfully. (Implicitly acceptable).
    CytotoxicityISO 10993-5: 2009Biocompatibility performed per ISO 10993-1, endpoints tested successfully. (Implicitly acceptable).
    PyrogenicityISO 10993-11: 2006Biocompatibility performed per ISO 10993-1, endpoints tested successfully. (Implicitly acceptable).
    HemocompatibilityISO 10993-4: 2002 Amended 2006Biocompatibility performed per ISO 10993-1, endpoints tested successfully. (Implicitly acceptable).
    Material CharacterizationISO 10993-18: 2005Biocompatibility performed per ISO 10993-1, endpoints tested successfully. (Implicitly acceptable), noting change in clamp material from acetal to polypropylene.

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

    The document does not specify the exact sample sizes (number of units tested) for each of the performance and biocompatibility tests. It only lists the tests performed and the relevant standards. These tests are laboratory-based, non-clinical tests.

    • Data Provenance: The tests are "bench / performance data / non-clinical testing" conducted by the manufacturer, Medcomp®, located in Harleysville, Pennsylvania, USA. The data is retrospective in the sense that it was generated prior to the 510(k) submission to demonstrate the device's characteristics.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts

    This question is not applicable. The "ground truth" here is established by the accepted international and internal test methods and standards (e.g., ISO, ASTM), not by expert consensus in a clinical scenario. The tests are designed to objectively measure physical, chemical, and biological properties.

    4. Adjudication Method for the Test Set

    This question is not applicable. Adjudication methods like 2+1 or 3+1 are used in clinical trials, particularly for imaging studies where subjective interpretation is involved. These are objective, quantitative, non-clinical laboratory tests where the results are measured against defined criteria within the standard.

    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 question is not applicable. This is a physical medical device (an infusion set), not an AI/ML diagnostic or assistive device. No human-in-the-loop study with AI was performed.

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

    This question is not applicable. This is a physical medical device, not an AI algorithm.

    7. The Type of Ground Truth Used

    The "ground truth" or basis for evaluation is defined by:

    • Established Industry Standards: ISO and ASTM standards (e.g., ISO 10555-1, ISO 10993 series, ASTM F2052, etc.) that specify test methods and acceptable limits for medical devices of this type.
    • Internal Test Methods: Where no specific external standard exists, internal test methods are used, and their validity is implicitly accepted by the FDA's clearance.
    • Substantial Equivalence: The primary "ground truth" for 510(k) clearance is demonstrating that the new device is as safe and effective as a legally marketed predicate device (K132880) through comparison of design, materials, indications for use, and performance testing.

    8. The Sample Size for the Training Set

    This question is not applicable. This device does not involve a "training set" for an AI/ML algorithm.

    9. How the Ground Truth for the Training Set Was Established

    This question is not applicable, as there is no training set for an AI/ML algorithm.

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