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510(k) Data Aggregation

    Why did this record match?
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The AtriClip LAA Exclusion System is indicated for the exclusion of the heart's left atrial appendage, performed under direct visualization and in conjunction with other cardiac surgical procedures.

    Direct visualization, in this context, requires that the surgeon is able to see the heart directly, with or without assistance from a camera, endoscope, etc., or other appropriate viewing technologies.

    Device Description

    The AtriClip Exclusion System contains a clip for exclusion of the heart's left atrial appendage (LAA). Preclinical animal studies (Kamohara 2005, 2006) demonstrate that complete exclusion with the Clip also results in acute and chronic electrical isolation of the LAA. A human clinical study (Starck 2012) has demonstrated acute electrical isolation. Chronic electrical isolation has not been evaluated in human clinical studies. The Clip is pre-loaded on a disposable Clip applier. The AtriClip Exclusion System does not contain natural rubber latex components.

    AI/ML Overview

    The provided text describes the 510(k) premarket notification for the AtriClip LAA Exclusion System. It focuses on demonstrating substantial equivalence to a predicate device (K181474), primarily based on labeling changes (indications for use and device description in the instructions for use) rather than a new design or device performance study.

    Therefore, many of the requested criteria related to a study proving device performance against acceptance criteria (e.g., sample sizes, expert ground truth, MRMC studies, standalone performance, training sets, etc.) are explicitly stated as not applicable or not performed because the submission is not for a new device design or a change in its intended use or function.

    Here's an analysis based on the provided text:


    1. Table of Acceptance Criteria and Reported Device Performance

    The submission does not detail specific quantitative acceptance criteria or performance metrics for the AtriClip LAA Exclusion System itself, as it's a 510(k) for a modified labeling of an existing, already cleared device. The "performance data" section explicitly states: "The proposed changes do not include any change to design or performance specifications of the AtriClip LAA Exclusion System. Additionally, the proposed changes did not modify the intended use, therefore the previously submitted bench and animal data remain valid for the AtriClip LAA Exclusion System."

    Instead, the "acceptance criteria" here are implicitly about demonstrating that the labeling changes do not negate the device's substantial equivalence to its predicate. The "performance" is therefore the assertion that the device continues to meet the established performance parameters of its predicate.

    FeaturePredicate (K181474) AtriClip™ LAA Exclusion System (Original Labeling)Subject AtriClip™ LAA Exclusion System (Modified Labeling)Equivalence Comparison (Acceptance)
    Proprietary NameAtriClip LAA Exclusion System with Preloaded Gillinov-Cosgrove Clip/V-ClipAtriClip LAA Exclusion System with Preloaded Gillinov-Cosgrove Clip/V-Clipn/a (same)
    Model NumbersLAA, ACH, PRO, ACHV, PROV seriesLAA, ACH, PRO, ACHV, PROV seriesn/a (same)
    Indications for UseOcclusion of LAA, under direct visualization, in conjunction with other cardiac surgical procedures.Exclusion of LAA, under direct visualization, in conjunction with other cardiac surgical procedures.Similar. AtriClip devices have the same intended use. (The term "occlusion" was changed to "exclusion," but the core meaning and clinical application are deemed equivalent.)
    Device Description in IFUDescribes the Clip for occlusion of LAA; pre-loaded on applier; no natural rubber latex.Describes Clip for exclusion of LAA; adds reference to preclinical animal studies (Kamohara 2005, 2006) demonstrating acute and chronic electrical isolation, and human clinical study (Starck 2012) showing acute electrical isolation (with statement that chronic electrical isolation not evaluated in human studies); pre-loaded on applier; no natural rubber latex.Different, but AtriClip devices have the same intended use. (The added descriptive text is considered an update to the IFU, not a change in fundamental device function or safety/effectiveness for the stated intended use.)
    Preloaded ClipGillinov-Cosgrove Clip / V-ClipGillinov-Cosgrove Clip / V-ClipSame
    Shelf Life3 years3 yearsSame
    BiocompatibilityPassed. ISO 10993 assessed.Passed. ISO 10993 assessed.Same
    SterilizationGamma Irradiation.Gamma Irradiation.Same
    Sterility Assurance Level10^-6 SAL10^-6 SALSame

    Study Proving Device Meets Acceptance Criteria:

    The "study" referenced in this submission is the 510(k) premarket notification process itself, which argues for substantial equivalence based on the updated labeling. The core argument is that the device's fundamental design, operating principles, and function have not changed. Therefore, previously submitted preclinical and clinical data from the predicate device (K181474) and referenced literature (Kamohara 2005, 2006; Starck 2012) are considered sufficient to support the device with its updated labeling.

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

    • Test Set: No new "test set" in the context of device performance testing was used for this 510(k) submission, as it relates to labeling changes only.
    • Data Provenance for Referenced Studies (Kamohara, Starck): The document does not specify the country of origin or whether these were retrospective or prospective studies. Kamohara (2005, 2006) are referred to as "preclinical animal studies," and Starck (2012) as a "human clinical study."

    3. Number of Experts Used to Establish Ground Truth and Qualifications

    • Not applicable. This was not a study requiring expert ground truth for performance evaluation of a new or modified device. The "ground truth" here is regulatory compliance and a determination of substantial equivalence by the FDA.

    4. Adjudication Method for the Test Set

    • Not applicable. No new test set for device performance was used.

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

    • Not applicable. No MRMC study was performed or required for this labeling update.

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

    • Not applicable. This device is a mechanical implant, not an algorithm.

    7. The Type of Ground Truth Used

    • The "ground truth" for this submission's approval is the established regulatory framework for 510(k) clearances, specifically demonstrating substantial equivalence to a predicate device. This is based on comparisons of design, materials, manufacturing, indications for use, and a demonstration that any changes (in this case, primarily labeling) do not raise new questions of safety or effectiveness. The supporting data for the claims made in the updated labeling (e.g., electrical isolation) come from previously published preclinical and clinical studies (Kamohara 2005/2006, Starck 2012).

    8. The Sample Size for the Training Set

    • Not applicable. This submission is not for an AI/ML algorithm or a device requiring a training set in that context.

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

    • Not applicable.
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    K Number
    K181474
    Manufacturer
    Date Cleared
    2018-06-28

    (24 days)

    Product Code
    Regulation Number
    878.4300
    Why did this record match?
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The AtriClip LAA Exclusion System is indicated for the occlusion of the heart's left atrial appendage, performed under direct visualization and in conjunction with other cardiac surgical procedures.

    Direct visualization, in this context, requires that the surgeon is able to see the heart directly, with or without assistance from a camera, endoscope, etc., or other appropriate viewing technologies.

    Device Description

    The LAA Exclusion System consists of a single use, sterile, self-closing, implantable Clip preloaded on a Single Use Clip Applier along with a selection quide. When closed, the Clip applies uniform pressure over the length of the Clip to ensure consistent, reproducible, and secure occlusion of the left atrial appendage (LAA). The clip is then deployed and is left as a permanent implant. The Clip is available in the following lengths to accommodate different sizes of LAA: 35 mm, 40 mm, 45 mm, and 50 mm.

    The Clip Appliers are disposable device with a handle, shaft, suture anchors, articulation controls, and deployment loop which contains the Clip. This Special 510(k) contains an alternate to the PET suture supply sourcing used within the AtriClip implant and Clip Appliers of the LAA Exclusion system.

    AI/ML Overview

    This is a 510(k) premarket notification for the AtriClip LAA Exclusion System, a medical device designed for occluding the heart's left atrial appendage during cardiac surgical procedures. This submission is for modifications to an already cleared device (K180010).

    The provided text focuses on demonstrating substantial equivalence to a predicate device, rather than providing a detailed study proving the device meets specific acceptance criteria with quantifiable performance metrics. The submission asserts that the modifications made do not change the intended use, operating principles, or function of the device, and therefore, the prior approval and equivalence still hold.

    However, based on the information provided, we can infer and construct some of the requested details:

    Acceptance Criteria and Reported Device Performance

    The acceptance criteria for substantial equivalence are not presented as numerical targets for performance metrics like sensitivity or specificity. Instead, they are based on demonstrating that the modified device is as safe and effective as the predicate device and that the changes do not raise new questions of safety or effectiveness.

    Acceptance Criteria (Inferred from Substantial Equivalence Determination)Reported Device Performance
    Intended Use: Same as predicate device."The devices have the same intended use."
    Operating Principle: No changes from predicate device."No changes were made in operating principle."
    Specifications of Performance: No changes from predicate device."No changes were made in... specifications of performance."
    Contraindications, Warnings, and Precautions: Remain the same as predicate device."The contraindications, warnings, and precautions remain the same."
    Equivalency in Performance (Bench Testing): Demonstrated for design and performance elements."Demonstrated equivalency in performance." Specifically, conducted: Tensile Testing (Strength, Knotted Strength), Suture Elongation, Friction Comparison Testing.
    Biocompatibility: Remains unchanged and meets ISO 10993-1."Device biocompatibility remains unchanged." Tested for: Material Mediated Pyrogen, Genotoxicity, Cytotoxicity, Implantation, Sensitization, Irritation, Systemic Toxicity.
    Safety Issues: No new issues raised."Did not raise any new issues of safety."

    Study Information (Based on Substantial Equivalence Submission)

    Since this is a 510(k) for modifications to an already cleared device, the "study" proving acceptance is primarily a demonstration of equivalence through bench testing and biocompatibility assessment of the modified components, rather than a clinical trial with patient outcomes.

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

    • Sample Size (Test Set): Not explicitly stated as "sample size" in the context of a clinical test set. The "test set" here refers to the materials and components of the modified device that underwent bench testing and biocompatibility evaluation. The quantity of items tested for Tensile, Elongation, Friction, and Biocompatibility (e.g., number of clips, appliers, or material samples) is not specified.
    • Data Provenance: Not explicitly stated. Given that these are bench tests and biocompatibility tests, the data would originate from the manufacturer's internal testing facilities or contract labs. The country of origin is not mentioned. The data is prospective in the sense that the tests were conducted specifically for this submission on the modified materials.

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

    This question is not directly applicable to a 510(k) based on bench testing and biocompatibility. There is no concept of "ground truth" derived from expert consensus on images or clinical cases in this submission. The "ground truth" in this context is the objective measurement from the specified engineering and biological tests demonstrating that the modified material performs equivalently and is biocompatible. The experts would be the engineers and toxicologists who designed, performed, and interpreted these tests, but their number and specific qualifications are not detailed.

    4. Adjudication Method for the Test Set

    Not applicable. There is no ambiguous data or expert disagreement requiring an adjudication method for the physical and chemical properties tested. The results are objective measurements from the tests performed.

    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 implant, not an AI-powered diagnostic or assistive tool for human readers. Therefore, an MRMC study related to AI assistance is not relevant.

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

    Not applicable. This is a physical medical device, not a standalone algorithm.

    7. The Type of Ground Truth Used

    The "ground truth" for demonstrating equivalence is based on:

    • Engineering Specifications: Testing the physical properties (tensile strength, elongation, friction) of the modified components against established engineering specifications and comparing them to the predicate device's performance.
    • Biological Standards: Testing biocompatibility according to recognized international standards (ISO 10993-1) using established biological assays (Material Mediated Pyrogen, Genotoxicity, Cytotoxicity, Implantation, Sensitization, Irritation, Systemic Toxicity).

    8. The Sample Size for the Training Set

    Not applicable. There is no "training set" in the context of AI or machine learning for this physical device submission.

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

    Not applicable, as there is no training set.

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