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510(k) Data Aggregation

    K Number
    K200083
    Date Cleared
    2020-02-14

    (30 days)

    Product Code
    Regulation Number
    870.3300
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K171845

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

    The EMBA Hourglass® Peripheral Embolization Device (PED) is indicated to obstruct or reduce the rate of blood flow in the peripheral vasculature in 6-8mm blood vessels. The device is not indicated for use in blood vessels subject to repetitive motion, such as extremity or pulmonary vessels.

    Device Description

    The Hourglass® Peripheral Embolization Device (PED) consists of a covered, implantable, self-expanding hourglass-shaped structure (Embolic Device) preloaded in a catheter-based Delivery System. The Embolic Device is intended to be deployed to the target site in the vasculature under fluoroscopic guidance. The product is shipped sterile and labeled for single use only.

    AI/ML Overview

    This FDA 510(k) summary (K200083) indicates that the device, EMBA Hourglass® Peripheral Embolization Device (PED), is substantially equivalent to a predicate device (K171845). The submission explicitly states that "no additional testing is required" for the current device because it is considered substantially equivalent to its predicate.

    Therefore, based on the provided document, there are no specific acceptance criteria or details of a study performed specifically for this device (K200083). Instead, the justification for substantial equivalence relies on the testing of the predicate device.

    However, I can extract the information regarding the comparison between the subject device and the predicate device, and the general statement about performance testing.

    Here's a breakdown of the requested information, where applicable:

    1. A table of acceptance criteria and the reported device performance:

    Since the document states that "no additional testing is required" for the subject device (K200083), there are no new acceptance criteria or reported performance unique to this submission. The substantial equivalence is based on the predicate device's performance.

    Acceptance Criteria (for Predicate Device)Reported Device Performance (for Predicate Device)
    Not explicitly stated in this document (refers to predicate's testing)Not explicitly stated for the subject device (relies on predicate's performance)
    Implied Acceptance (for K200083 based on K171845)
    Device functions as intended to obstruct or reduce blood flow in 6-8mm peripheral vessels.Maintains functionality for obstructing/reducing blood flow in 6-8mm peripheral vessels.
    Material and manufacturing process consistency with predicate.Same materials and manufacturing processes as predicate.
    BiocompatibilityPassed biocompatibility testing (of predicate device per ISO 10993-1).

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

    • Sample Size: Not applicable. No new test set for K200083. The document states that "bench, animal, and clinical testing performed for the predicate device are adequate."
    • Data Provenance: Not applicable for K200083. The origin of data for the predicate device's testing is not mentioned in this document.

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

    • Not applicable. No new test set and no ground truth establishment for K200083.

    4. Adjudication method for the test set:

    • Not applicable. No new test set for K200083.

    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 a physical embolization device, not an AI-assisted diagnostic tool.

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

    • Not applicable. This device is a physical embolization device, not an algorithm.

    7. The type of ground truth used:

    • Not applicable for K200083. The "ground truth" for the predicate device's performance would likely have involved direct observation of embolization effectiveness in animal models, and clinical outcomes if clinical studies were part of its submission.

    8. The sample size for the training set:

    • Not applicable. This is not an AI/machine learning device.

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

    • Not applicable. This is not an AI/machine learning device.

    Key takeaway from the document:

    The regulatory strategy for K200083 is based on substantial equivalence to a predicate device (K171845). The primary difference noted is the Delivery System length (80cm vs. 120cm). All other design and material characteristics, as well as manufacturing processes, are stated to be identical. Due to these similarities and a risk analysis concluding no new or modified risks, the prior performance testing (bench, animal, clinical) and biocompatibility testing of the predicate device are deemed sufficient for this new submission.

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