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510(k) Data Aggregation

    Why did this record match?
    Reference Devices :

    F&P Optiflow 3S Nasal Cannula (K191818)

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

    Hudson RCI® Comfort Flo Nasal Cannulas Premature, Infant:
    Hudson RCI® Comfort Flo Nasal Cannulas Premature, Infant are intended to be used in conjunction with the Comfort Flo Humidification System to provide a continuous flow of heated and humidified air/oxygen mixtures to spontaneously breathing patients.

    It is indicated for single use by premature and infant (birth to 2 years) patients in professional healthcare environments.

    Hudson RCI® Comfort Flo® Plus Cannulas and Comfort Flo® Soft Plus Cannulas Extra Small:
    Hudson RCI® Comfort Flo® Plus Cannulas and Comfort Flo® Soft Plus Cannulas Extra Small are intended to be used in conjunction with the Humidification System to provide a continuous flow of heated and humidified air/oxygen mixtures to spontaneously breathing patients.

    It is indicated for single use by adult and pediatric (12 years and above) patients in professional healthcare environments.

    Device Description

    Hudson RCI® Comfort Flo Nasal Cannulas Premature, Infant
    Hudson RCI® Comfort Flo Plus Cannulas Extra Small
    Hudson RCI® Comfort Flo Soft Plus Cannulas Extra Small

    AI/ML Overview

    This is a 510(k) clearance letter for a medical device (nasal cannula), not an AI/ML-driven device. Therefore, the information typically requested for AI/ML device validation (such as expert consensus, MRMC studies, or training/test set details) is not applicable.

    The document describes the device, its intended use, and a summary of non-clinical testing performed to demonstrate substantial equivalence to predicate devices. It clearly states that no clinical testing was performed.

    Here's a breakdown of the requested information based on the provided document, highlighting why many points are not applicable for this type of device clearance:

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

      • The document lists various non-clinical performance tests but does not provide a table of specific acceptance criteria with corresponding reported device performance values. Instead, it generally states that testing was conducted "to demonstrate substantial equivalence." For example, it lists "Relevant Humidity Output testing" but doesn't state the specific humidity output range considered acceptable or the measured output. This is typical for a 510(k) submission where broad equivalence is the goal rather than meeting precise performance thresholds for novel functionality.
    2. Sample sizes used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

      • Not applicable. This is a physical medical device. Testing involved bench tests on manufactured units, not data sets in the AI/ML sense. Data provenance, retrospective/prospective, and sample sizes for test sets (in the context of patient data) are not relevant as no human or clinical data was used for validation.
    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

      • Not applicable. No "ground truth" was established by experts in the context of diagnostic performance, image interpretation, or similar AI/ML applications, as this is a physical medical device.
    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

      • Not applicable. There was no test set requiring expert adjudication for performance evaluation.
    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 is not an AI-assisted device, and no MRMC study was conducted. The document explicitly states "No clinical testing was performed."
    6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done

      • Not applicable. This is not an algorithm-based device.
    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

      • Not applicable. The concept of "ground truth" as it applies to AI/ML model validation is not relevant here. The device's performance was evaluated against engineering specifications and industry standards for physical device functionality (e.g., flow rates, material compatibility, strength).
    8. The sample size for the training set

      • Not applicable. There is no AI/ML model, and thus no training set.
    9. How the ground truth for the training set was established

      • Not applicable. There is no AI/ML model, and thus no training set or ground truth establishment for it.

    In summary, the provided document is a 510(k) clearance for a physical medical device, not an AI/ML-driven product. Therefore, most of the requested information related to AI/ML validation (ground truth, expert studies, training/test sets) is irrelevant to this submission.

    The acceptance criteria for this device focus on:

    • Biocompatibility: Meeting ISO standards (e.g., ISO 10993 series, ISO 18562 series) to ensure the materials are safe for patient contact and breathing gas pathways. The document lists the specific ISO standards used.
    • Performance Bench Testing: Covering aspects like visual inspection, humidity output, thermal overshoot, connection strength, leak testing, headgear testing, shelf life, and useful life. While the specific numerical acceptance criteria for each test (e.g., "humidity output must be within X amount") are not explicitly listed in this summary, the document indicates these tests were performed and implicitly met the company's internal acceptance criteria for demonstrating substantial equivalence.
    • Substantial Equivalence: The overarching acceptance criterion for a 510(k) is demonstrating that the device is "as safe and as effective" as a legally marketed predicate device, based on the non-clinical testing performed.

    The "Study that proves the device meets the acceptance criteria" for this product consists of the various Non-Clinical Testing described on pages 16-17, primarily Biocompatibility Testing and Performance Testing (Bench), which were conducted to support the claim of substantial equivalence to the predicate devices.

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    K Number
    K240163
    Date Cleared
    2024-09-27

    (249 days)

    Product Code
    Regulation Number
    868.5450
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K191818

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

    Hudson RCI® Comfort Flo nasal cannulas are intended to be used in conjunction with the Comfort Flo Humidification System to provide a continuous flow of heated and humidified air/oxygen mixtures to spontaneously breathing patients.

    It is indicated for single use by adult and pediatic (2 years and above) patients in professional healthcare environments.

    Hudson RCI® Comfort Flo® Plus cannulas are intended to be used in conjunction with the Humidification System to provide a continuous flow of heated and humidified air/oxygen mixtures to spontaneously breathing patients.

    It is indicated for single use by adult and pediative (12 years and above) patients in professional healthcare environments.

    Device Description

    Hudson RCI® Comfort Flo Nasal Cannulas:
    Comfort Flo nasal cannulas are intended to be used in conjunction with the Comfort Flo Humidification System to provide a continuous flow of heated humidified air to spontaneously breathing patients. Sizes available include adult and pediatric.

    Hudson RCI® Comfort Flo Plus Cannulas:
    Cannula tube is assembled with other components to create a product named Comfort Flo® Plus Cannula with/ without Chin Strap. The Comfort Flo Plus cannulas are intended to be used in conjunction with the Humidification system intended to provide a continuous flow of heated and humidified air/oxygen mixtures to spontaneously breathing patients. It allows for the safe and effective delivery of heated, humidified oxygen therapy to the patients.

    The Comfort Flo Plus Cannulas are available in small, medium and large configurations. The chin strap is also offered individually.

    Hudson RCI® Comfort Flo Plus Cannulas:
    Comfort Flo Soft Plus cannulas are the same as Comfort Flo Plus cannulas except for head strap. These have a soft/cushioned head strap for patient comfort.

    It is used as an alternative to oxygen face mask and allows the patient to continue to talk, eat and drink while receiving the therapy.

    Hudson RCI® Tracheostomy Adaptor:
    The Hudson RCI® Tracheostomy Adapters are intended to be used in conjunction with tracheostomies in order to provide a secure connection to spontaneously breathing tracheostomy patients for oxygen therapy. It allows for the safe and effective delivery of oxygen therapy to the patient's trachea.

    The Tracheostomy Adaptor consists of 15mm (female) connector with cap deflector which enables it to be attached to 15M conical connector of tracheostomy tube/ patient connector port and swivel connector (15F/22M) at another end in order to connect with breathing circuit/ humidification system.

    It is indicated for single use by adult and pediatric (12 years and above) patients in professional healthcare environments.

    AI/ML Overview

    The provided text is related to a 510(k) premarket notification for a medical device (nasal cannulas) and does NOT contain information about acceptance criteria or a study proving that the device meets specific performance criteria, especially not in the context of an AI/ML-driven medical device.

    The document describes the device, its intended use, comparison to predicate devices, and a summary of non-clinical (bench) performance testing and biocompatibility testing. However, it explicitly states "This section does not apply. No animal testing was performed" and "This section does not apply. No clinical testing was performed" under "Performance Testing (Animal)" and "Performance Testing (Clinical)" respectively.

    Therefore, I cannot extract the requested information regarding acceptance criteria, device performance from a test set, sample sizes for test/training sets, data provenance, expert numbers/qualifications, adjudication methods, MRMC studies, standalone performance, or ground truth establishment relevant to an AI/ML device.

    The document discusses tests like:

    • Post aging Visual Inspection
    • Relevant Humidity Output testing
    • Thermal Overshoot testing
    • Gas path and headgear joint and connection strength testing
    • Flow Leak Test/ Gas path leak testing
    • Head Gear Testing
    • Shelf Life Testing
    • Useful Life Testing
    • Transportation simulation
    • ISO gauging

    These are all bench tests for a mechanical/physical device (nasal cannula), not studies that would involve AI/ML performance metrics like sensitivity, specificity, AUC, or the involvement of human readers/experts for ground truth.

    In summary, the provided document does not contain the information required to answer your request about acceptance criteria and study details for an AI/ML medical device.

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