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510(k) Data Aggregation

    K Number
    K190532
    Device Name
    TruDi NAV Wire
    Manufacturer
    Date Cleared
    2019-05-03

    (60 days)

    Product Code
    Regulation Number
    882.4560
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K171687

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

    The TruDi™ NAV Wire is intended for use as an electromagnetically navigable guidewire to provide access and confirmation of placement in the patient anatomy. The device is intended for use during ENT procedures where reference to a rigid anatomical structure can be identified relative to a CT-based model of the anatomy.

    Device Description

    The subject device, TruDi™ NAV Wire, is a single-use electromagnetically (EM) navigated, flexible guidewire, which is compatible for use with the TruDi™ Navigation System to provide access and confirmation of placement in patient anatomy during intranasal and paranasal surgeries. The TruDi™ NAV Wire is intended to provide real-time tracking at the distal tip of the guidewire in the nasal anatomy and is intended to be used during ENT procedures where reference to a rigid anatomical structure can be identified relative to a CT-based model of the anatomy. The subject device, TruDi™ NAV Wire, may be used with compatible non-ferromagnetic instruments that have a lumen of greater than 1mm in diameter and a luer lock mechanism to fix the wire onto the instrument.

    AI/ML Overview

    The provided text describes the "TruDi™ NAV Wire," an electromagnetically navigable guidewire. Here's a breakdown of the acceptance criteria and study information:

    1. Acceptance Criteria and Reported Device Performance

    The document does not explicitly provide a table of acceptance criteria with numerical targets and the device's reported performance against those targets in a readily digestible format for certain tests. Instead, it states that "Bench testing has been performed and met all acceptance criteria for attributes..." and then lists the attributes. For sterility, it mentions a specific level.

    Here's a table based on the provided text, outlining the tests performed and the general statement of performance:

    Test/AttributeAcceptance CriteriaReported Device Performance
    Simulated Use TestingMet acceptance criteria"met all acceptance criteria"
    Dimensional SpecsMet acceptance criteria"met all acceptance criteria"
    Insertion DurabilityMet acceptance criteria"met all acceptance criteria"
    Rotational DurabilityMet acceptance criteria"met all acceptance criteria"
    Suction DurabilityMet acceptance criteria"met all acceptance criteria"
    Joint Separation ForceMet acceptance criteria"met all acceptance criteria"
    StiffnessMet acceptance criteria"met all acceptance criteria"
    Swivel Functional Perf.Met acceptance criteria"met all acceptance criteria"
    Frictional ForceMet acceptance criteria"met all acceptance criteria"
    Location Accuracy (Sensor Sensitivity)Met acceptance criteria"met all acceptance criteria"
    SterilizationSterility Assurance Level (SAL) of 10^-6 (per ISO 11135:2014)"demonstrated a sterility assurance level of 10-6"
    Ethylene Oxide ResidualsMeet ISO 10993-7:2008 requirements"meet ISO 10993-7:2008 requirements"
    BiocompatibilityBiocompatible per ISO 10993-1"successfully completed to determine...is biocompatible"
    Packaging Shelf LifeMeet ASTM F1980-07, ASTM F88/F88M-09, and ASTM F2096-11 requirements for 3 months"confirmed to meet a shelf life of three months"

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

    The document does not specify the sample size used for the test set for any of the bench tests (simulated use, durability, etc.).
    The data provenance is not explicitly stated as retrospective or prospective, nor is the country of origin. Since these are bench tests, they are typically conducted in a laboratory setting.

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

    This information is not applicable as the studies described are bench tests on the device's physical and functional properties, not clinical studies requiring expert ground truth for interpretation of outcomes.

    4. Adjudication Method for the Test Set

    This information is not applicable as the studies described are bench tests and do not involve human interpretation or adjudication in the way clinical studies with ground truth establishment would. The tests would likely have pre-defined pass/fail criteria.

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

    No, an MRMC comparative effectiveness study was not done. The document explicitly states: "Clinical data was not necessary for the TruDi™ NAV Wire." The studies described are non-clinical bench tests.

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

    This question is not directly applicable as the TruDi™ NAV Wire is a physical medical device, not an algorithm, and its performance relies on interaction with a navigation system. The "Location Accuracy (Sensor Sensitivity)" test implicitly assesses the standalone performance of the guidewire's electromagnetic tracking capability, but it's not an algorithm in the typical sense of AI.

    7. The Type of Ground Truth Used

    For the bench tests, the "ground truth" would be established by engineering specifications, industry standards (e.g., ISO, ASTM), and design requirements. For example, a specified durability threshold or a precise dimensional measurement.

    8. The Sample Size for the Training Set

    This information is not applicable as the device is a physical guidewire and the studies described are bench tests, not machine learning studies that require a training set.

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

    This information is not applicable as there is no training set for a machine learning model.

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