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510(k) Data Aggregation

    K Number
    K191195
    Device Name
    PiccGuard
    Manufacturer
    Date Cleared
    2020-01-03

    (245 days)

    Product Code
    Regulation Number
    880.5970
    Reference & Predicate Devices
    Predicate For
    Why did this record match?
    Reference Devices :

    K182545

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

    The PICCGuard device is indicated for use as a tamper evident enclosure for the catheter and Luer hub with needleless connector attached on medical devices such as PICC lines and other central line catheter ports.

    Device Description

    The PICCGuard is a two-piece plastic housing with locking barb that inserts through a hole in the bottom housing. After inserting the shaft of the catheter and Luer hub with needleless connector attached, the two halves slide together, and the barb is pushed through the hole in the bottom housing. Once the barb is inserted, the housing is locked. When a healthcare provider needs intravenous access, medical scissors can be used to disconnect the lid from the locked portion. The PICCGuard is then removed giving access to the needleless connector, and the health care provider can administer medications per normal routine.

    AI/ML Overview

    The provided text is a 510(k) summary for the PICCGuard device. It describes the device, its intended use, and compares it to predicate devices. However, this document primarily discusses nonclinical performance testing related to biocompatibility and basic functional tests. It does not describe a study that proves the device meets acceptance criteria related to its primary indication as a tamper-evident enclosure in the context of improving human reader performance or a standalone algorithm performance.

    Specifically, there is no mention of a device that uses an AI algorithm or requires human "readers" or experts to establish ground truth in the way described in the prompt's questions (e.g., related to image interpretation). The PICCGuard is a physical device intended to demonstrate tampering, not an AI-powered diagnostic or interpretive tool.

    Therefore, many of the requested details about acceptance criteria and studies (e.g., sample size for test/training sets, data provenance, number of experts, adjudication methods, MRMC studies, standalone performance, type of ground truth for AI models) are not applicable to the information provided in this 510(k) summary.

    Based on the provided text, here's what can be extracted and what cannot:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document includes a "Functional Testing Results Summary Table" that aligns with this request for specific functional aspects of the physical device.

    TestAcceptance CriteriaReported Device PerformancePass/Fail
    Removal of Device to Confirm Tamper EvidentThe device shall show signs of being tamper with and shall break near the locking tab."All samples Passed" (implies all samples showed signs of tampering and broke near the locking tab)Pass
    Repeated Removal of PICCGuard from PICC linesThe catheter shows no sign of leakage after assemble / disassemble / flush cycles."All samples Passed" (implies no leakage was observed)Pass
    Removable of Wings by Medical ScissorsThe tabs of the device shall easily be cut by medical scissors"All samples Passed" (implies the tabs were easily cut)Pass

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

    • Sample Size for Functional Tests: The document states "All samples Passed" for the functional tests. However, the number of samples tested is not explicitly stated.
    • Data Provenance: Not specified, but given the nature of a physical device functional test, it would likely be laboratory-based and not involve patient data or geographical provenance in the typical sense for AI/diagnostic devices.

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

    • Not Applicable. This device is a physical tamper-evident enclosure, not a diagnostic tool requiring expert interpretation or ground truth establishment in a clinical sense. The "ground truth" for its functional performance is based on direct observation of physical characteristics (breaking, no leakage, ease of cutting).

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

    • None. Not applicable, as there's no subjective interpretation or complex data requiring adjudication.

    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:

    • No. This is not an AI device or a diagnostic device. No MRMC study was conducted.

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

    • No. This is not an algorithm.

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

    • For the functional tests, the "ground truth" was the direct physical demonstration of the device's characteristics:
      • Tamper evidence: Visual confirmation of breaking near the locking tab.
      • No leakage: Visual confirmation after assembly/disassembly/flush cycles.
      • Ease of cutting: Confirmation that medical scissors can easily cut the tabs.

    8. The sample size for the training set:

    • Not Applicable. This device is not an AI model, so there is no "training set."

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

    • Not Applicable. As there is no AI model or training set, this question is irrelevant.

    Additional Information from the Document:

    • Clinical Studies: "No clinical studies were conducted."
    • Biocompatibility Testing: The document lists several ISO 10993 standards and provides a summary table for biocompatibility tests (cytotoxicity, irritation, skin sensitization), all concluding that the Test Article meets acceptance criteria. These are standard tests for medical devices that contact the body.
    • Intended Use/Indications: The device is "indicated for use as a tamper evident enclosure for the catheter and Luer hub with needleless connector attached on medical devices such as PICC lines and other central line catheter ports."
    • Comparison to Predicate Devices: The document focuses on comparing the PICCGuard's regulatory class, classification name, product code, review panel division, intended use, use environment, and patient population to predicate devices. The key difference highlighted is the PICCGuard's role as an accessory providing a tamper-evident feature, which is not the primary function of the direct predicate (a PICC catheter). A reference predicate (a tamper-evident cap) is mentioned for its similar tamper-evident claim.
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