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510(k) Data Aggregation

    K Number
    K191023
    Manufacturer
    Date Cleared
    2019-05-16

    (29 days)

    Product Code
    Regulation Number
    892.1550
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    Dolphin/IQ, K170859, Dolphin/4D, K170859

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

    Dolphin/Q, Dolphin/4D and Dolphin/MAX are medical Doppler devices intended for noninvasive measurements of blood flow velocities in arteries and veins in adults and Pediatric. The Dolphin systems can be used in hospitals, clinics and physician offices.

    Device Description

    Dolphin/IQ, Dolphin/4D and Dolphin/MAX systems are part of the Dolphin product family of non-invasive peripheral vascular diagnostic systems. The Dolphin/IQ, Dolphin/4D and Dolphin/MAX are transcranial Doppler (TCD) systems for measurement of blood flow velocity intracranially, extracranially and in the peripheral circulation. Both systems share identical Doppler hardware and software. The Dolphin/IQ is a module, that needs to connect to an external computer and display for its' operation while the Dolphin/4D is a complete integrated system that includes and integrated computer system with hard disk, and touch screen display. Dolphin/Max is similar to the Dolphin/4D system, except that it also has an internal rechargeable battery and an external power supply. The functionality and performance of Dolphin/4D and Dolphin/4D and Dolphin/MAX systems is identical. Dolphin systems support the same Doppler probes: 1.6 MHz PW hand held probe, 2 MHz PW hand held probe, 2 MHz PW monitoring probe, 4 MHz CW/PW hand held probe and 8 MHz CW/PW hand held probe. Dolphin systems support the same accessories: IR wireless remote control, External Channels connection box, wired remote control foot switch and monitoring head set.

    Wherever the term Dolphin is used in this document, it applies to the Dolphin/IQ, Dolphin/4D and Dolphin/MAX. Otherwise, each product is specifically by name.

    The Dolphin devices are based on Doppler technology and are designed for standard intended use for Transcranial Doppler systems operated only by experienced medical staff.

    AI/ML Overview

    The provided text is a 510(k) summary for the Dolphin/IQ, Dolphin/4D, and Dolphin/MAX ultrasonic pulsed Doppler imaging systems. It asserts substantial equivalence to a previously cleared predicate device (Dolphin/IQ and Dolphin/4D, K170859).

    Here's an analysis based on the requested information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly present a table of "acceptance criteria" against which specific "device performance" metrics are reported in a granular way that would be typical for an AI/ML device. Instead, it focuses on demonstrating substantial equivalence to a predicate device.

    However, based on the Comparison Table (Section 5.4.1), we can infer performance characteristics that are expected to be "identical" or "equivalent" to the predicate. The key performance criterion explicitly mentioned is Measurement Accuracy.

    Acceptance Criteria (Implied)Reported Device Performance
    Measurement accuracy (Blood flow velocity)± 10% accuracy (Identical to predicate)
    Acoustic Output (Ispta.3)Below maximal FDA guideline limits (≤ 720 mW/cm²)
    Acoustic Output (MI)≤ 1.9
    Acoustic Output (ISPPA)≤ 190 W/cm²
    Battery Operating Time (Dolphin/MAX only)At least 3 hours of routine examination

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

    The document explicitly states: "No clinical study was conducted to support this application." Therefore, there is no test set in the context of clinical data, no sample size, and no data provenance for such a test set. This submission relies on "non-clinical performance testing" and comparison to a predicate device.

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

    As no clinical study was conducted, there are no "experts used to establish the ground truth for the test set."

    4. Adjudication Method for the Test Set

    Not applicable, as no clinical study or test set was used.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done

    No MRMC study was conducted. The device is a diagnostic ultrasound system, not an AI-assisted interpretation tool for human readers in the way an AI/ML diagnostic software might be.

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

    The device itself is a standalone medical Doppler device. The "performance" discussed relates to its physical and functional specifications. It is not an AI algorithm in the contemporary sense that would have separate standalone performance evaluated. The comparison is made against the performance of its predicate device, which is also a standalone medical device.

    7. The Type of Ground Truth Used

    For the key performance metric of "Measurement accuracy," the "ground truth" would implicitly be the established accuracy of the predicate device, which is stated as ± 10%. For the acoustic output criteria, the "ground truth" is compliance with FDA guidelines and standards (e.g., IEC 60601-2-37, NEMA UD 2 & 3). For the Dolphin/MAX battery, the stated 3-hour operating time would have been verified through internal testing.

    8. The Sample Size for the Training Set

    Not applicable, as no AI/ML algorithm was being developed or trained. This is a traditional medical device submission for an ultrasound system.

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

    Not applicable, as there was no training set.


    Summary of the Study that Proves the Device Meets Acceptance Criteria:

    The "study" to prove the device meets acceptance criteria primarily consists of non-clinical performance testing and a comparison to a legally marketed predicate device.

    • Non-Clinical Performance Testing: The document states that the devices "have been thoroughly tested through verification of specifications and validation, including software validation." This would include engineering bench tests to verify parameters such as measurement accuracy, acoustic output, and electrical safety. The specific details of these non-clinical tests (e.g., the number of devices tested, the protocols, the exact results) are not provided in this 510(k) summary but would have been part of the full submission to the FDA. The compliance with standards such as IEC 60601-1, IEC 60601-1-2, IEC 60601-2-37, NEMA UD 2-2004, and UD 3-2004 indicates that specific tests related to electrical safety, electromagnetic compatibility, acoustic output, and diagnostic ultrasound equipment performance were conducted and successfully met.

    • Predicate Device Comparison (Substantial Equivalence): The core of the submission is to demonstrate that the Dolphin/IQ, Dolphin/4D, and Dolphin/MAX systems are "substantially equivalent" to predicate devices (Dolphin/IQ and Dolphin/4D, K170859). The comparison table (Section 5.4.1) highlights that the new devices share identical or equivalent technical characteristics, indications for use, clinical applications, frequency modes, transducers, patient contact materials, user controls, display modes, various measurement parameters, and measurement accuracy to the predicate. The few differences (e.g., the addition of Dolphin/MAX with an internal battery, new accessories) are discussed and deemed not to impact product performance or effectiveness. The predicate device's existing clearance implies its performance already met FDA requirements, and by demonstrating equivalence, the new devices are considered to do the same.

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