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510(k) Data Aggregation

    K Number
    K211830
    Device Name
    LifeSPARC System
    Date Cleared
    2022-11-15

    (519 days)

    Product Code
    Regulation Number
    870.4100
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K202751, K183623

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

    The LifeSPARC System is a centrifygal blood pump system intended to assist in circulation of the patient's blood when part of an extracorporeal circuit including physiologic gas exchange of the patient's blood in adult patients with acute respiratory failure or acute cardiopulmonary failure, where other available treatment options have failed, and continued clinical deterioration is expected or the risk of death is imminent. These may include:

    • Failure to wean from cardiopulmonary bypass following cardiac surgery in adult patients
    • ECMO-assisted cardiopulmonary resuscitation in adults
    Device Description

    The LifeSPARC Pump is a sterile, single-use, low prime volume centrifugal pump with an integrated motor and a single-point, pivot bearing. It is sterilized using ethylene oxide (EO) and sized to fit in the palm of the hand or to secure to the patient.

    The LifeSPARC Controller provides the interface between pump and user, as well as the power and electrical signals to drive the pump. It is a microprocessor-based electromechanical pump drive system designed to operate on standard AC current (100/240 VAC, 50/60 Hz) or on internal, rechargeable batteries for intra-hospital transport.

    AI/ML Overview

    The provided text describes the LifeSPARC System, an extracorporeal blood pump system, and its substantial equivalence determination by the FDA. The submission focuses heavily on non-clinical testing and an animal study, with a clinical evaluation based on retrospective registry data.

    Here's an analysis of the acceptance criteria and the study that proves the device meets them, based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria are derived from the "Special Controls" outlined by the FDA. The "reported device performance" is summarized from the "Summary of Non-clinical Testing," "Animal Study," and "Clinical Evaluation" sections.

    Acceptance Criterion (Special Control)Reported Device Performance
    #1: Technological characteristics of the device must ensure that the geometry and design parameters are consistent with the intended use, and that the devices and accessories in the circuit are compatible."The technological characteristics of the device are consistent and compatible with the use of the device to pump the blood through an extracorporeal circuit." (No specific design parameters or compatibility tests are detailed, but a general statement of compliance is made.)
    #2: The devices and accessories in the circuit must be demonstrated to be biocompatible."The LifeSPARC Pump meets all relevant biological endpoints per ISO 10993-1 for a device in contact with circulating blood for a prolonged duration of use (24 hours to 30 days)."
    #3: Sterility and shelf-life testing must demonstrate the sterility of any patient-contacting devices and accessories in the shelf life of these devices and accessories."Testing demonstrates the sterility of the subject device as provided and that it maintains its sterility, integrity, durability, and reliability over the stated shelf-life of the device."
    #4: Non-clinical performance evaluation of the devices and accessories in the circuit must demonstrate substantial equivalence of the performance characteristics on the bench, mechanical integrity, electromagnetic compatibility (where applicable), software, durability, and reliability."Substantial equivalence of the LifeSPARC System performance characteristics was demonstrated through bench testing, mechanical integrity testing, electrical safety and electromagnetic compatibility testing, and software testing. Results of the reliability testing demonstrate the system achieves 85% reliability at 90% confidence for a 28-day mission." (Specific results for individual tests are not provided, only a summary statement of compliance.)
    #5: In vivo evaluation of the devices and accessories in the circuit must demonstrate their performance over the intended duration of use, including a detailed summary of the clinical evaluation pertinent to the use of the devices and accessories to demonstrate their effectiveness if a specific indication (patient population and/or condition) is identified.Animal Study: 8 out of 9 calves survived the protocol-defined 14-day duration without clinically significant device-related adverse reactions, thromboembolic complications, or end-organ damage. The LifeSPARC Pump performed similarly to the control (TandemHeart Pump).
    Clinical Evaluation: An independent statistical analysis of ELSO Registry data found no statistically significant difference in ten ECMO-related clinical outcomes (including pump failure, hemolysis, thrombosis, and patient death) between the LifeSPARC Pump and other centrifugal pumps/TandemHeart Pump when used off-label for ECMO > 6 hours. "The propensity score analysis provided by the statistical group at ELSO clearly demonstrates the ability of LifeSPARC Pump to provide assisted extracorporeal circulation of the patient's blood in adult patients."
    #6: Labeling must include a detailed summary of the non-clinical and in vivo evaluations pertinent to use of the devices and accessories in the circuit and adequate instructions with respect to anticoagulation, circuit setup, performance characteristics with respect to compatibility among different devices and accessories in the circuit, and maintenance during a procedure."The Directions for Use contain the information detailed in this Special Control." (No specific content is described, but a statement of compliance is made.)

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

    Animal Study (In vivo evaluation):

    • Test Set Sample Size: 9 calves were supported with the LifeSPARC System. A control group of 5 calves were supported with the TandemHeart Pump.
    • Data Provenance: Prospective animal study (bovine model, presumably conducted in a controlled laboratory setting). The specific country of origin is not stated but is implied by the US FDA submission process.

    Clinical Evaluation:

    • Test Set Sample Size: The text states, "The study is an enumerative study where all available ECMO data collected in the ELSO registry database that met the study criteria were analyzed." The exact number of patients for the LifeSPARC Pump group and the comparator group(s) is not explicitly stated in the provided text. However, it's inferred to be a large dataset given it's from the ELSO Registry.
    • Data Provenance: Retrospective observational data from the Extracorporeal Life Support Organization (ELSO) Registry. The ELSO Registry is an international registry, so the data provenance would likely be multi-national, although this is not explicitly stated. The data was "observational data in a real-world setting."

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

    Animal Study:

    • The text describes "close monitoring of the systems identified early problems allowing repairs or pump exchange before becoming clinically significant." This implies veterinary or medical expertise for monitoring and assessing animal health.
    • The assessment of "clinically significant thromboembolic or bleeding complications, vascular or myocardial injuries, adherent thrombus, or end organ damage" would typically fall under the purview of veterinary pathologists and clinicians.
    • Number of experts and qualifications: Not specified.

    Clinical Evaluation:

    • The ground truth for the clinical outcomes (e.g., pump failure, hemolysis, thrombosis, death) would have been established by the clinicians and medical professionals managing the patients and inputting data into the ELSO Registry. The ELSO statistical group performed the analysis.
    • Number of experts and qualifications: Not specified. The ELSO statistical group is mentioned for analysis ("independent statistical analysis," "propensity score analysis was performed by the ELSO group"), but not for establishing the initial ground truth.

    4. Adjudication method for the test set

    Animal Study:

    • The text indicates "close monitoring" and "identified early problems allowing repairs or pump exchange." This suggests continuous assessment by the study team. However, a formal adjudication method for adverse events or outcomes (e.g., blinded review by a panel) is not described.

    Clinical Evaluation:

    • The clinical evaluation is based on existing data from the ELSO Registry. The ground truth (patient outcomes) would have already been established by the reporting institutions.
    • A formal adjudication method for the test set outcomes, beyond the standard data collection and reporting mechanisms of the ELSO Registry, is not described. The analysis by the ELSO statistical group is a statistical comparison, not an adjudication process.

    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, an MRMC comparative effectiveness study was not done.
    • The device is an extracorporeal blood pump system, not an AI-assisted diagnostic or interpretative device that involves "human readers" or "AI assistance" in the sense of image interpretation or similar tasks.
    • The clinical evaluation was a comparison of the device's performance against other similar devices (other centrifugal pumps, including a predicate) using retrospective registry data, not a human-in-the-loop study.

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

    • No, this concept is not directly applicable to the LifeSPARC System. This device is a mechanical pump, not an algorithm. Its performance is inherent to its physical operation and interaction with the patient's blood, not an independent algorithmic output. The "standalone" performance is its performance in the animal study and its outcomes as observed in the clinical registry data.

    7. The type of ground truth used

    Animal Study:

    • Clinical observation and physiological measurements from the calves during the 14-day support period.
    • Post-mortem analysis for "adherent thrombus, or end organ damage."

    Clinical Evaluation:

    • Outcomes data / Real-world patient data from the ELSO Registry. This includes clinically recorded events like "pump failure, hemolysis, thrombosis or clots in circuit component, patient death within 24 hours of stopping ECMO, and patient death at discharge," as well as "use of renal replacement therapy (RRT during ECMO, pulmonary hemorrhage, circuit change, central nervous system (CNS) hemorrhage, and CNS infarction." This data is based on reporting by treating clinicians.

    8. The sample size for the training set

    • The provided text relates to regulatory submission for a medical device (an extracorporeal blood pump system), not a machine learning model. Therefore, the concept of a "training set" in the context of AI/ML is not applicable.
    • If interpreted as "data used to inform the device's design or prior evaluations," the text references a "currently-cleared devices" and "reference devices" (TandemHeart System, LifeSPARC System K183623), implying previous testing and clinical experience would have contributed to the device's development, but no specific "training set" size for this purpose is given.

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

    • As the concept of a "training set" is not applicable in this context (not an AI/ML device), this question is moot.
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