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510(k) Data Aggregation

    K Number
    K233881
    Manufacturer
    Date Cleared
    2024-03-15

    (98 days)

    Product Code
    Regulation Number
    880.5725
    Reference & Predicate Devices
    Predicate For
    N/A
    Why did this record match?
    Reference Devices :

    K192385

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

    The ivWatch Model 400 is indicated for the detection of subcutaneous infiltrations and extravasations of 10 cc or less of optically clear and iron sucrose infusates, as an adjunctive device to the clinical evaluation in the healthcare setting of adults and pediatrics with peripherally-inserted catheters (PIVs). The device is indicated to assess patients for the subcutaneous infiltrations and extravasations but should not serve as a substitute for regular clinician assessment of the PIV site. The ivWatch Model 400 is intended for use by healthcare practitioners who have been trained in the use of the device.

    Device Description

    The ivWatch Model 400 is a medical device that provides continuous, non-invasive monitoring of human tissue adjacent to peripheral intravenous (PIV) insertion sites to aid in the early detection of infiltration and extravasation events. The predicate device includes a Patient Monitor, a Fiber Optic Sensor Cable, and a disposable Sensor Receptacle. Under K192385 the system was expanded to add three Device Accessories including an Extension Module, a Patient Cable and SmartTouch Sensor. The Device Accessories expand system's functionality to support two sensor technologies (fiber optic and electronic).

    The ivWatch Model 400 is a medical device that provides continuous, non-invasive monitoring of human tissue adjacent to peripheral intravenous (PIV) insertion sites to aid in the early detection of infiltration and extravasation events.

    The ivWatch Model 400 uses visible and near-infrared light to measure changes in the optical properties of the tissue near a PIV insertion site. The ivWatch Patient Monitor (IPM) contains an optical system that generates visible and near-infrared light signals that are sent through the sensor cable to the patient's skin. Simultaneously, the IPM measures the light reflected back through the sensor cable from the patient's skin. Measured changes between the emitted and reflected signal are processed by ivWatch signal processing algorithms to determine if an infiltration event may have occurred. If changes in the optical properties of the tissue near the peripheral IV insertion site are consistent with an infusate pooling in the subcutaneous tissue, the IPM emits audible and visual notifications intended to prompt the clinician to inspect the peripheral IV site for a possible infiltration event.

    AI/ML Overview

    The provided document (K233881) is a 510(k) summary for the ivWatch® Model 400. This document primarily focuses on demonstrating substantial equivalence to a previously cleared predicate device (K192385) rather than detailing a specific de novo study for a novel device. The key change in the subject device is the addition of iron sucrose as an indicated infusate.

    Therefore, the information typically found in a de novo study report regarding acceptance criteria and performance (especially for AI/ML validation) is not extensively detailed. However, I can extract the relevant information pertaining to the acceptance criteria and the study that supports the expanded indications for use.

    Here's an analysis based on the provided text:

    Acceptance Criteria and Reported Device Performance

    The document states that the primary change to the device is the expansion of its Indications for Use to include iron sucrose infusates. The performance evaluation for this expansion is presented as bench testing results, indicating the device's ability to detect iron sucrose.

    Table of Acceptance Criteria and Reported Device Performance (as implied for the new indication):

    Acceptance Criterion (Implied for new indication: Iron Sucrose)Reported Device Performance
    Ability of the device to detect signal changes consistent with infiltration of iron sucrose infusates.Mean signal drops: - Saline: 23.7% (std: 6.79%) - Iron: 47.1% (std: 7.97%) Comparison: - Iron injection signals not weaker than saline signals (p≈1.000) - Diluted iron signal (1mg/ml) is stronger signal than saline. - Signal strength increases with higher concentration of iron (tested from 1mg/ml to 20mg/ml).
    Device performance with iron sucrose infusates does not negatively impact device safety or effectiveness (compared to optically clear infusates).Bench testing results support device detection of iron sucrose; iron infusates do not impact device safety or effectiveness.

    Note: The document states, "Test results show that the ivWatch® Model 400 subject device meets all pre-defined acceptance criteria." However, it does not explicitly list these criteria for the iron sucrose detection beyond the signal strength metrics provided. The overarching acceptance criterion is likely demonstrating that the device functions equivalently or better for iron sucrose as it does for optically clear infusates, upholding its safety and effectiveness.

    Study Details for the Expanded Indication (Iron Sucrose)

    The information provided does not describe an AI/ML model or a complex clinical trial for performance evaluation. Instead, it refers to bench testing for the new indication.

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

      • The document mentions "Iron concentrations from 1mg/ml to 20mg/ml were tested." It does not specify the number of individual tests, samples, or the in vivo or in vitro nature of this "bench testing."
      • Data Provenance: Not explicitly stated, but "bench testing" typically implies laboratory-controlled experiments. There is no indication of country of origin or whether it was retrospective or prospective in a clinical setting for this specific iron sucrose data. The clinical studies mentioned for the predicate device were conducted in the United States and were prospective.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

      • Not applicable as this was "bench testing" focusing on optical signal changes, not human interpretation or a clinical diagnostic setting requiring expert ground truth in the traditional sense. The ground truth for this test set would be the controlled infusion of known concentrations of iron sucrose and saline.
    3. Adjudication method (e.g. 2+1, 3+1, none) for the test set:

      • Not applicable. As this was bench testing measuring signal properties, there would be no human adjudication process involved.
    4. 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. The device is a "Peripheral Intravenous (PIV) Infiltration Monitor." It provides audible and visual notifications to clinicians, but it's not described as an AI-powered image analysis tool that a human would interpret. Therefore, an MRMC study or an AI-assisted human reader improvement study is not relevant to this device's function or the claims being made for this 510(k). The device acts as an adjunct to clinical evaluation.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

      • The "bench testing results" for iron sucrose detection represent the standalone performance of the device's optical properties and signal processing algorithms in a controlled environment. The reported percentage signal drops and comparisons represent algorithm-only performance against known infusates.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

      • For the iron sucrose bench testing, the ground truth was controlled, known volumes and concentrations of infusates (iron sucrose and saline) instilled/tested in a controlled environment. The 'truth' was the physical presence of the infusate and its expected optical properties.
    7. The sample size for the training set:

      • The document implies that the device's core algorithm was developed and validated with the predicate device (K192385). It states that for the predicate, "A series of IRB-approved clinical studies were performed for the verification and validation of the ivWatch Model 400 with Device Accessories." However, it does not specify a separate "training set" in the context of an AI/ML model for this specific 510(k). The current submission focuses on demonstrating the device's existing technology's capability with a new infusate through bench testing, rather than a re-training or significant algorithm modification.
    8. How the ground truth for the training set was established:

      • For the original predicate device (K192385), the ground truth for its clinical validation was established through "IRB-approved clinical studies." This likely involved direct clinical observation and diagnosis of infiltrations by healthcare professionals, serving as the ground truth for the device's ability to detect these events. Specific details of how clinical ground truth was established (e.g., direct visualization, palpation, aspiration, etc.) are not provided in this summary.
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    K Number
    K222212
    Manufacturer
    Date Cleared
    2022-08-24

    (30 days)

    Product Code
    Regulation Number
    880.5725
    Reference & Predicate Devices
    Predicate For
    N/A
    Why did this record match?
    Reference Devices :

    K192385

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

    The ivWatch Model 400 is indicated for the detection of subcutaneous infiltrations and extravasations of 10 cc or less of optically clear infusates, as an adjunctive device to the clinical evaluation in the healthcare setting of adults and pediatrics with peripherally-inserted catheters (PIVs). The device is indicated to assess patients for subcutaneous infiltrations and extravasations, but should not serve as a substitute for regular clinician assessment of the PIV site. The ivWatch Model 400 is intended for use by healthcare practitioners who have been trained in the use of the device.

    Device Description

    The ivWatch Model 400 is a medical device that provides continuous, non-invasive monitoring of human tissue adjacent to peripheral intravenous (PIV) insertion sites to aid in the early detection of infiltration and extravasation events. The ivWatch Model 400 consists of the ivWatch Patient Monitor (IPM), a reusable optical sensor cable and a single-use Sensor Receptacle. The ivWatch Model 400 uses visible and near-infrared light to measure changes in the optical properties of the tissue near a PIV insertion site. The IPM contains an optical system that generates visible and near-infrared light signals that are sent through the optical sensor cable to the patient's skin. Simultaneously, the IPM measures the light reflected back through the optical sensor cable from the patient's skin. Measured changes between the emitted and reflected signal are processed by ivWatch signal processing algorithms to determine if an infiltration event may have occurred. If changes in the optical properties of the tissue near the peripheral IV insertion site are consistent with an infusate pooling in the subcutaneous tissue, the IPM emits audible and visual notifications intended to prompt the clinician to inspect the peripheral IV site for a possible infiltration event.

    AI/ML Overview

    Based on the provided FDA 510(k) summary for the ivWatch Model 400 (K222212), this submission primarily concerns a change in the sterilization method for the Sensor Receptacle component of the device. Therefore, the "study" proving the device meets acceptance criteria is specifically focused on demonstrating the equivalence of the new sterilization method to the previous one and showing that the device, with this new sterilization, still meets relevant standards for sterility and biocompatibility.

    Here's an breakdown of the information requested, drawing from the provided text:

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

    Acceptance Criteria (from ISO Standard)Reported Device Performance (Subject Device)
    Sterilization SAL (Sterility Assurance Level) of 10⁻⁶ (ISO 14937:2009)Pass (<10⁻⁶)
    EO (Ethylene Oxide) Residuals (< 4 mg) (ISO 10993-7:2008)Pass
    ECH (Ethylene Chlorohydrin) Residuals (< 9 mg) (ISO 10993-7:2008)Pass
    Overall device performance after sterilization (implied "performs as intended")Device meets all pre-defined acceptance criteria, performs as intended.

    2. Sample size used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective)

    The document does not explicitly state the sample size for the sterilization validation test set. Sterilization validation typically involves a statistically determined number of units. However, it mentions "half-cycle overkill approach" which is a common method for EO sterilization validation, implying a robust testing protocol.

    The data provenance is not specified beyond being generated for this 510(k) submission, likely from ivWatch, LLC (Newport News, Virginia, USA). The study is prospective in the sense that it was conducted for regulatory submission for a change to an existing device.

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

    This type of submission (focused on sterilization) does not typically involve expert review for "ground truth" in the way a clinical study for diagnostic accuracy would. The "ground truth" here is the adherence to established international standards for sterilization and biocompatibility. The "experts" would be the metrology and microbiology professionals who conducted and validated the sterilization process and testing, though their specific number and qualifications are not detailed in this summary.

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

    Adjudication methods like 2+1 or 3+1 are used in clinical image interpretation studies. This document concerns a physical device modification and sterilization validation, not diagnostic accuracy requiring human interpretation. Therefore, none is applicable in this context. The results are based on quantitative measurements against established chemical and biological limits.

    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 is not relevant to this 510(k) submission. The ivWatch Model 400 is hardware with signal processing algorithms to detect infiltrations. It is an "adjunctive device" to clinical evaluation, not an AI intended to improve human interpretation of images or data in a comparative reading study. The submission focuses on the safety and performance of the device itself, particularly after a manufacturing change (sterilization method).

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

    The ivWatch Model 400 functions as a standalone device in its detection capability. It continuously monitors tissue optical properties and autonomously signals an alert if an infiltration is detected. The "study" mentioned here is about the sterilization of a component, not the performance of its detection algorithm. However, the device's core functionality (the algorithm processing optical signals) is designed to operate autonomously to detect changes. The overall summary states: "Measured changes between the emitted and reflected signal are processed by ivWatch signal processing algorithms to determine if an infiltration event may have occurred." This implies standalone performance of the algorithm for detection. The current submission proves that this device, with a modified sterilization, maintains its performance.

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

    For this particular 510(k) which is focused on sterilization, the "ground truth" is adherence to validated international standards for sterilization (ISO 14937:2009 for sterility assurance, ISO 10993-7:2008 for EO/ECH residuals). The acceptance criteria are scientifically established limits defined by these standards.

    8. The sample size for the training set

    This is not applicable. The ivWatch Model 400 is not described as an AI/ML device that requires a "training set" in the context of this 510(k) summary. While it uses "signal processing algorithms," these are likely deterministic or rule-based, or if they involve ML, the training data for the original algorithm would have been part of the predicate device's (K162478) submission, not detailed here for a sterilization change.

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

    Not applicable, as this submission does not describe an AI/ML model that requires a training set. The "ground truth" for the device's functional performance (detection of infiltration) would have been established through clinical studies for the original device, likely involving induced infiltrations in human subjects or animal models, confirmed by visual inspection or other clinical signs. However, this information is not part of the provided 510(k) summary for this submission (K222212), which is focused on a change in manufacturing process for a component.

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