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510(k) Data Aggregation

    K Number
    K173256
    Manufacturer
    Date Cleared
    2018-03-02

    (143 days)

    Product Code
    Regulation Number
    880.6885
    Why did this record match?
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The SYSTEM 1 endo Liquid Chemical Sterilant Processing System is intended for liquid chemical sterilization of cleaned, immersible, and reusable semi-critical heat-sensitive medical devices and their accessories in healthcare facilities.

    The SYSTEM 1 endo Processor automatically dilutes the S40 Sterilant Concentrate to its use dilution (> 1820 mg/L peracetic acid), liquid chemically sterilizes the load during a controlled 6-minute exposure at 45.5 to 60°C and rinses the load with 0.2 micron filtered water.

    The SYSTEM 1 endo Processor uses only S40 Sterilant Concentrate to liquid chemically sterilize medical devices.

    Device Description

    The SYSTEM 1 endo Liquid Chemical Sterilant Processing System is a liquid chemical sterilization system, utilizing peracetic acid to process totally immersible semi-critical heat-sensitive medical devices and their accessories. The system consists of the SYSTEM 1 endo Processor and S40 Sterilant Concentrate, interchangeable Processing Trays/Containers, and Quick Connects.

    The SYSTEM 1 endo Processor is an automated, self-contained device that uses S40 Sterilant Concentrate to create and maintain the conditions necessary for liquid chemical sterilization in 6 minutes. Following processing, the liquid chemically sterilized articles are rinsed with 0.2 micron filtered potable water and are ready for use or may be prepared for storage. The processor, which is computer controlled and continually monitored, provides printed documentation of each cycle. The SYSTEM 1 endo Processor uses only S40 Sterilant Concentrate. Upon loading the single-use cup, the active ingredient in S40 - peracetic acid - is combined with inert ingredients (builders) to form a use dilution which inhibits corrosion of metals, polymers and other materials.

    The interchangeable processing trays/containers are made to accommodate a variety of semi-critical instrument types and models. Each container is designed to maintain instruments in position while specific SYSTEM 1 endo Quick Connects, if required, facilitate delivery of the sterilant use-solution and rinse water to internal channels.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and the study that proves the device meets them, based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    TestAcceptance CriteriaReported Device Performance
    In-Use TestingClinically used, cleaned semi-critical heat-sensitive medical devices exposed to varied clinical soils were effectively liquid chemically sterilized.PASS
    Electrical Safety ConformanceUL 61010-1:2012 Ed.3+R:29 Apr2016 Electrical Equipment for Measurement, Control, and Laboratory Use Part 1: General Requirements
    UL 61010-2-040:2016 Ed.2 Electrical Equipment For Measurement, Control, And Laboratory Use Part 2-040: Particular Requirements For Sterilizers And Washer-Disinfectors Used To Treat Medical MaterialsPASS
    Water Filter Performance through Use LifeThe 0.2 micron MaxLife filter maintained its integrity and achieved effective bacterial retention performance after numerous Liquid Chemical Sterilization Cycles and Diagnostic Cycles representing 6 months of active use.PASS
    Water Filter Integrity TestThe Diagnostic Cycle correctly detects loss of filter integrity or absence of a filter.PASS
    Cycle QualificationAll cycle specifications were met for three (3) cycles each, Liquid Chemical Sterilization and Diagnostic.PASS
    Software ValidationThe software that controls the system was validated and determined to operate effectively and as designed.PASS

    Points not explicitly addressed in the provided text:

    The provided text (a 510(k) Summary for a medical device) focuses on demonstrating substantial equivalence to a predicate device, rather than a typical clinical study report for AI/machine learning devices. Therefore, several points in your requested information are not applicable or explicitly mentioned in this type of document.

    Here's how the remaining points relate to the provided text:

    2. Sample size used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective)

    • Test Set Sample Size: Not explicitly stated for each test. For "In-Use Testing," it mentions "Clinically used, cleaned semi-critical heat-sensitive medical devices," implying a sample was used but the size isn't quantified. For Water Filter Performance, refers to "numerous Liquid Chemical Sterilization Cycles and Diagnostic Cycles." For Cycle Qualification, it states "three (3) cycles each, Liquid Chemical Sterilization and Diagnostic."
    • Data Provenance: Not explicitly stated. The document is submitted to the FDA in the USA, suggesting the testing was likely conducted in accordance with US regulatory standards, but the physical location or origin of the samples/data is not mentioned.
    • Retrospective or Prospective: Not explicitly stated, though "In-Use Testing" implies real-world usage, which could be prospective if the testing was specifically set up for this submission.

    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)

    • Not applicable for this type of device. The device is a liquid chemical sterilant processing system. Ground truth is established through microbiological testing (e.g., absence of viable microorganisms) and engineering verification, not human expert interpretation of images or other subjective data. No experts (like radiologists) are involved in establishing ground truth for this device's performance.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    • Not applicable for this type of device. Adjudication methods are typically used in studies where human interpretation or classification is compared, often with disagreements needing resolution. For a sterilization system, the performance is measured objectively against predefined microbial reduction targets or engineering specifications.

    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 device is not an AI-assisted diagnostic tool that involves human readers.

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

    • Partially applicable, but not in the AI sense. The "device performance" in this context (sterilization efficacy, electrical safety, filter performance, software operation) is inherently "standalone" in that it's the system itself performing its intended function. There isn't an "algorithm-only" performance study distinct from the device's operational performance, as the device is the sterilizing algorithm/process. The tests described (e.g., In-Use Testing, Water Filter Performance) evaluate the device's standalone capability.

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

    • Microbiological Negativity / Sterility: For the "In-Use Testing," the ground truth of "effectively liquid chemically sterilized" implies the absence of viable microorganisms (i.e., sterility) after processing. This would typically be verified through standard microbiological culture methods.
    • Engineering Specifications: For Electrical Safety, Water Filter Performance, Water Filter Integrity Test, Cycle Qualification, and Software Validation, the ground truth is adherence to predefined engineering specifications, industry standards (e.g., UL standards), or functional requirements.

    8. The sample size for the training set

    • Not applicable. This is not an AI/machine learning device that requires a training set. The device operates based on fixed chemical and physical parameters, not learned data.

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

    • Not applicable. No training set is used for this device.
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    K Number
    K170956
    Manufacturer
    Date Cleared
    2017-09-22

    (175 days)

    Product Code
    Regulation Number
    880.6885
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K161683

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

    The SYSTEM 1E Liquid Chemical Sterilant Processing System is intended for liquid chemical sterilization of cleaned, immersible, and reusable critical and semi-critical heat-sensitive medical devices in healthcare facilities. The SYSTEM 1E Processor dilutes the S40 Sterilant Concentrate to its use dilution (>1820 mg/L peracetic acid), liquid chemically sterilizes the load during a controlled 6-minute exposure at 45.5 to 60°C, and rinses the load with extensively treated* potable water. After completion of a cycle, critical devices should be used immediately; semi-critical devices should be used immediately or may be handled and stored in a manner similar to that of high level disinfected endoscopes. Critical devices not used immediately should be processed again before use.

    The SYSTEM 1E Processor uses only S40 Sterilant Concentrate to liquid chemically sterilize medical devices.

    • The extensive treatment of EPA potable water consists of:
    1. Pre-filtration through two pre-filters:
    • · Pre-filter A is a gross depth filter that removes approximately 2.5 micron or larger particles/contaminants.
    • · Pre-filter B is a surface filter that removes particles/contaminants > 0.1 micron.
    1. UV Irradiation:
    • During transit through the UV water treatment chamber, a UV dose sufficient to achieve a > 6-log reduction of MS2 virus is delivered to the water.
    1. 0.1 micron filtration:

    · The water prepared by pre-filtration and UV irradiation is filtered through redundant, 0.1-micron (absolute rated) membranes to remove bacteria, fungi and protozoa > 0.1 micron.

    Device Description

    The SYSTEM 1E Liquid Chemical Sterilant Processing System is a liquid chemical sterilization system, utilizing peracetic acid to process totally immersible, heat sensitive, flexible and rigid endoscopes and their accessories, and microsurgical instruments. The system consists of the SYSTEM 1E Processor and the S40 Sterilant Concentrate, interchangeable processing trays/containers and Quick Connects. The device was originally cleared under K090036. Five Special 510(k)s were cleared that subsequently made minor modifications to hardware, software, specifications, and labeling. This premarket notification introduces a new processing tray that will accommodate ultrasound endoscopes and other large flexible devices and their associated Quick Connects. Additionally, minor inconsistent statements in the cleared Indications for Use are corrected, and clarification is provided on post-processing handling and storage of critical and semi-critical medical devices.

    The SYSTEM 1E Processor is an automated, self-contained device which creates and maintains the conditions necessary for liquid chemical sterilization in 6 minutes. Following processing, the liquid chemically sterilized articles are rinsed with extensively treated water produced by passing EPA potable tap water through pre-filters, an ultraviolet light treatment subsystem, and then through two 0.1 micron filter membranes. The processor, which is computer controlled and continually monitored, provides printed documentation of each cycle.

    S40 Sterilant Concentrate is a single use chemical sterilant concentrate developed exclusively for use in the SYSTEM 1E Processor. The active ingredient in S40 Sterilant Concentrate, peracetic acid, is combined with inert ingredients (builders) to form a use dilution which inhibits corrosion of metals, polymers and other materials.

    The interchangeable processing trays/containers are made to accommodate a variety of instrument types, models and procedure specific sets. Each container is designed to maintain instruments in appropriate position while specific Quick Connects for the SYSTEM 1E Processor, if required, facilitate delivery of the liquid chemical sterilant use dilution and rinse water to internal channels.

    AI/ML Overview

    This document is a 510(k) summary for the SYSTEM 1E Liquid Chemical Sterilant Processing System, seeking substantial equivalence to a previously cleared device (K161683). The primary changes are the addition of a new Ultrasound Processing Tray and related Quick Connects, and minor labeling updates. The document relies heavily on the predicate device's performance data, as the technological principles are largely identical.

    Here's an attempt to extract the requested information based on the provided text, acknowledging that much of the "study" detail refers to previously established performance for the predicate device.


    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly present "acceptance criteria" in a typical quantitative clinical trial format. Instead, it describes performance characteristics and equivalency to the predicate device. The primary performance criterion is achieving sterilization.

    Feature / Criterion (as implied)Reported Device Performance (Proposed SYSTEM 1E Processor)Comment (Comparison to predicate K161683)
    Sterilization Efficacy
    Sporicidal Activity (B. subtilis, C. sporogenes)Meets efficacy requirements (in vitro)Identical to predicate
    Confirmatory Sporicidal Activity (B. subtilis, C. sporogenes)Meets efficacy requirements (in vitro)Identical to predicate
    Fungicidal Activity (Trichophyton mentagrophytes)Solution is fungicidal (in vitro)Identical to predicate
    Bactericidal Activity (Salmonella choleraesuis, Staphylococcus aureus, Pseudomonas aeruginosa)Solution is bactericidal (in vitro)Identical to predicate
    Virucidal Activity (Herpes simplex Type 1, Adenovirus Type 5, Poliovirus Type 1)Solution is virucidal (in vitro)Identical to predicate
    Tuberculocidal Activity (Mycobacterium terrae)Solution is tuberculocidal (in vitro)Identical to predicate
    Simulated-Use Test (Geobacillus stearothermophilus spores)Meets efficacy requirement: > 6 log10 reduction (manual application)Identical to predicate
    Clinical In-UseNo surviving microorganisms on representative medical devices testedIdentical to predicate
    Processing Cycle Parameters
    Contact Time6 minutesIdentical to predicate
    Use Dilution Temperature45.5-60°C (allowable), 46-55°C (typical)Identical to predicate
    Peracetic acid concentration>1820 mg/LIdentical to predicate
    Incoming water temperature$\ge 43^\circ C$Identical to predicate
    Temperature to start exposure phase$\ge 46^\circ C$Identical to predicate
    Temperature alarm point during exposure phase60°CIdentical to predicate
    Rinse water preparationPre-filtered, UV treated ($\ge$ 6-log reduction of virus), redundant 0.1 micron filteredIdentical to predicate
    Number of rinses2Identical to predicate
    Water Filter Integrity TestConducted at end of every liquid chemical sterilant processing cycle and during Diagnostic cycleIdentical to predicate
    Approximate Cycle Time25 minutesIdentical to predicate
    Biocompatibility
    Cytotoxicity / Residue ReductionTwo rinses effectively reduce sterilant residues to safe levels (with UV treated, dual 0.1 micron membrane filtered water)Identical to predicate
    Device Material CompatibilityCompatible with medical devices (tested flexible endoscopes through 300 cycles and rigid devices through 150 cycles). No functional changes to flexible devices. Some cosmetic changes (fading) on specific materials without harm to base material.Identical to predicate

    Study Proving Device Meets Acceptance Criteria

    The document states, "Based on the intended use, technological characteristics and non-clinical performance data, the subject device is as safe, as effective and performs as well as the legally marketed predicate device (K161683)..." This indicates that the primary "study" is a demonstration of substantial equivalence to a previously cleared device. For the specific modifications introduced in this submission (new Ultrasound Processing Tray and Quick Connects), the document states: "Any new safety and efficacy concerns were addressed through verification testing."

    Since this is a 510(k) submission primarily demonstrating substantial equivalence, direct clinical efficacy studies for the new model in comparison to the predicate are not detailed. Instead, the focus is on showing that the minor changes do not introduce new questions of safety or effectiveness and that the established sterilization efficacy of the previous model (K161683) still applies.

    Specific Study Types Mentioned/Implied:

    • Microbial Efficacy Testing: This refers to in vitro and simulated-use tests proving the sporicidal, fungicidal, bactericidal, virucidal, and tuberculocidal claims. These are likely standardized tests (e.g., AOAC Official Methods, EPA Virucidal Testing, Ascenzi Quantitative Suspension Test).
    • Biocompatibility Testing: Focusing on cytotoxicity, residue reduction, and device material compatibility after repeated processing cycles.
    • Verification Testing: Specifically for the new Ultrasound Processing Tray and Quick Connects, to address any new safety and efficacy concerns. This would typically involve validating fluid flow, sterilant contact, rinse effectiveness, and material compatibility for the new components and devices intended to be processed in them.

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

    The document does not specify a "test set" in the context of a dataset for an AI model. This is a medical device sterilization system, not an AI/Software as a Medical Device.

    • Microbial Efficacy (In vitro/Simulated-Use): The exact sample sizes for these tests are not provided in the summary, but they would typically involve established protocols for sterility testing.
    • Device Material Compatibility: "testing finished flexible endoscopes through 300 cycles and rigid devices through 150 cycles."
    • Data Provenance: Not explicitly stated as "country of origin" for data, but the tests cited (AOAC, EPA, Ascenzi) are standard scientific and regulatory compliance tests. The company STERIS Corporation is based in Ohio, USA. The testing context is for regulatory approval within the USA (FDA). The nature of these tests is generally prospective in a lab setting, following predefined validated protocols.

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

    This information is not applicable. The device is a sterilizing system, not an AI diagnostic tool that requires human experts for ground truth establishment on a test set of data. The "ground truth" for sterilization is the absence of viable microorganisms, determined through microbiological testing.


    4. Adjudication Method for the Test Set

    This information is not applicable for the same reasons as #3.


    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 information is not applicable. This is not an AI/Software as a Medical Device, and no human reader interpretation is involved.


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

    This information is not applicable. The device is a physical sterilizing system and does not involve AI algorithms in the sense of image interpretation or diagnostic performance. Its performance is evaluated through its ability to mechanically and chemically sterilize devices autonomously.


    7. The type of ground truth used

    The "ground truth" for this device is sterility, meaning the complete absence of viable microorganisms. This is established through various microbiological tests:

    • Spore-kill validation: Using highly resistant bacterial spores (e.g., Bacillus subtilis, Clostridium sporogenes, Geobacillus stearothermophilus) that are considered the gold standard for sterilization efficacy.
    • Absence of other microorganisms: Fungi, bacteria, viruses, and mycobacteria are also tested, demonstrating broader microbicidal activity.
    • Clinical In-Use data: Demonstrating no surviving microorganisms on representative medical devices after processing.

    8. The sample size for the training set

    This information is not applicable. This is not an AI/Machine Learning device that requires a "training set" of data.


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

    This information is not applicable for the same reasons as #8.

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