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510(k) Data Aggregation
(210 days)
Entarik NI Feeding Tubes (FTs) are intended for the administration, fluids and medications by the nasoenteric or orogastric route for neonatal patients who have an intact gastrointestinal tract but are physically unable to manage nutritional intake through normal mastication and deglutition.
The Entarik NI Feeding Tube System (Entarik NI System) is designed to aid, in conjunction with institutional protocols, qualified operators in the placement of the Entarik NI Feeding Tube (FT) into the stomach of neonatal patients requiring enteral feeding. The Entarik FTs are equipped with sensors designed to provide information about the tube tip relative to the stomach, thus assisting in reducing the incidence of misplacement during first positioning. The Entarik NI FTs are provided sterile.
The Entarik NI System also monitors the feeding tube position continuously during the course of feeding and automatically and in real time alerts of tube migration.
The Entarik NI System provides continuous monitoring of gastric and esophageal temperature. The Entarik device can be used solely for the purpose of monitoring gastric and esophageal temperature in situations where invasive monitoring is indicated.
The Entarik NI system is intended to record, store, view and analyze impedance in the pharynx and stomach.
The Entarik NI Feeding Tube System (Entarik NI System) consists of the Entarik NI Feeding Tube (disposable) and the Entarik NI Monitor (reusable) with Power Supply. The Entarik NI System is designed for enteral feeding and to aid in the placement of the Entarik NI Enteral Feeding Tube into the stomach of neonatal patients requiring enteral feeding. The Entarik NI System also continuously monitors feeding tube position, gastric and esophageal temperature, and gastrointestinal impedance and reflux. The feeding tubes are single use devices intended for prolonged use (less than 30 days). The Entarik NI Feeding Tubes are provided sterile.
The provided text describes the acceptance criteria and study proving the device meets those criteria for the Entarik NI Feeding Tube System.
1. Table of Acceptance Criteria and Reported Device Performance
The document does not present a formal table of acceptance criteria with corresponding performance metrics in a pass/fail format. Instead, it describes various tests performed and states that the device was found to be "safe and effective". We can infer the "acceptance criteria" from the fact that no issues were raised during these tests, indicating successful outcomes for all mentioned evaluations.
Acceptance Criteria Type | Reported Device Performance |
---|---|
Sterilization | Validation performed per ISO 11135-1 and ISO 10993-7. |
Biocompatibility | Evaluation performed per ISO 10993-1:2018 and FDA guidance. Leveraged existing tests from primary predicate due to identical materials and manufacturing processes (Cytotoxicity, Intracutaneous Irritation, Maximization Sensitization, Acute Systemic Toxicity, Sub-acute Systemic Toxicity, Intramuscular Implantation, Material Mediated Pyrogenicity were successfully demonstrated). |
Software Quality | Verification and validation testing performed per IEC 62304:2015, demonstrating safety and performance. |
Electrical, Mechanical, and Thermal Safety, and EMC | Designed to comply with AAMI/ANSI ES60601-1, IEC 60601-1-6, IEC 60601-1-8, IEC 80601-2-49, ISO 80601-2-56, and IEC 60601-1-2. |
Device Performance (Bench) | Bench tests performed: Dimensional Verification, Impedance and Temperature Accuracy and Sensing Rate, Insertion and Withdrawal, Flow and Pressure, Buckle and Kink, Tensile Integrity, Viscous Feed Testing, Radiopacity, Product and Label Durability. All tests implicitly passed as no failures are indicated. |
Clinical Performance | In the validation study, the system was "safe and effective in all eleven neonatal participants to aid qualified operators in the placement of the Entarik FT into the stomach of patients, and monitor the feeding tube position continuously and automatically and in real-time alert of tube migration." |
2. Sample Sizes and Data Provenance
- Training Set Sample Size: 16 subjects.
- Test Set Sample Size: 11 subjects for the validation study.
- Data Provenance: The document does not explicitly state the country of origin. The studies appear to be prospective clinical studies, as they involved the placement and monitoring of the device in new participates for the purpose of the study.
3. Number of Experts and Qualifications for Ground Truth
The document does not explicitly state the number of experts used or their specific qualifications (e.g., "radiologist with 10 years of experience") for establishing ground truth. It mentions that the validation study's placement confirmation was "per institutional standard of care," which implies reliance on qualified medical professionals within the clinical setting.
4. Adjudication Method
The document does not describe a specific adjudication method (e.g., 2+1, 3+1, none) for the test set. It mentions "placement was confirmed per institutional standard of care," suggesting that the medical institution's standard procedures were followed for verifying tube placement.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
There is no mention of a Multi-Reader Multi-Case (MRMC) comparative effectiveness study or any effect size of how much human readers improve with AI vs. without AI assistance. The study focuses on the device's ability to aid operators and monitor position, not on comparing human reader performance with and without AI.
6. Standalone (Algorithm Only) Performance
The document describes two clinical studies. The first (observational study) collected data silently for algorithm training and optimization without providing placement guidance. This suggests an initial phase where the algorithm was developed and refined, but standalone performance against a ground truth is not explicitly reported in terms of metrics like sensitivity/specificity for tube placement. The second (validation study) involved the device aiding qualified operators, indicating a human-in-the-loop scenario rather than a purely standalone algorithm evaluation of performance directly supporting a diagnostic claim.
7. Type of Ground Truth Used
- For the validation study's tube placement: "placement was confirmed per institutional standard of care." This likely refers to methods such as X-ray confirmation, pH testing of aspirate, or visual confirmation, as standard practice in clinical settings for feeding tube placement. While not explicitly stated, this would be a clinical ground truth established by medical professionals following established protocols.
- For continuous monitoring of tip location: The device itself automatically and in real time alerts of tube migration. The validation study confirmed this functionality was "safe and effective," implying these alerts were indeed accurate relative to actual tube migration conditions (though the specific ground truth for judging "tube migration" during continuous monitoring is not detailed).
8. Sample Size for the Training Set
The training set for the algorithm involved 16 subjects.
9. How the Ground Truth for the Training Set was Established
In the observational study for algorithm training and optimization, the Entarik NI Monitor "did not provide any placement guidance or verification. It collected impedance and temperature data silently that was used to train and optimize the placement and monitoring algorithm." This implies that while the device collected its data, the true tube position (ground truth) during this training phase was independently established by standard clinical methods (e.g., X-ray) by the clinicians or institution, and this independent ground truth was then used to train the algorithm. The document doesn't explicitly state the method for ground truth establishment during the training phase, but it must have been an independent reference standard.
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(266 days)
The Mucosal Impedance Measurement System is indicated for use by medical personnel trained in the usage of enteral feeding tubes for the treatment of adult patients requiring gastric decompression or enteral feeding for the delivery nutrition, fluids, and medications to the patient from an enteral feeding svringe or feedings set designed with ENFit connectors. The measurements of the Mucosal Impedance Measurement System are collected in patients indicated for enteral feeding. This product is single use for no longer than 24 hours.
The Mucosal Impedance Measurement System is equipped with sensors designed to collect and display real time and continuous gastric reactance "XL" measurements. The device is not for use as a sole diagnostic screening tool and is restricted to prescription use in a hospital environment.
The Mucosal Impedance Measurement System senses passive electrical features of the gastric tissue that corelate to of epithelial integrity through a technique known as 'bioimpedance spectroscopy'. Bioimpedance spectroscopy measures the ability of tissue to conduct electricity (resistance) and the ability of tissue to store charged particles (reactance).
The Florence monitor model ISMO 1.0 is an electronic device that delivers electrical current to a small region of the gastric tissue through the Athena Catheter; the device measures the resultant voltage, and then calculates and displays impedance information in numeric and graphic representations. More specifically, to measure the bioimpedance of the gastric mucosa impedance, the device delivers electric current through the Athena Catheter. The resulting voltage developed between the two inner electrodes is sensed, filtered, amplified, and then digitized by the electronic circuits of the monitor. Once the measured voltage from the gastric tissue has been digitized, a proprietary algorithm processes the information and calculates the impedance spectrum and the Central Reactance parameter (XL). The device displays the information as either a function of frequency or as a function of time.
Here's a breakdown of the acceptance criteria and the studies performed for the Mucosal Impedance Measurement System, based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
Test | Methods / Acceptance Criteria | Reported Device Performance |
---|---|---|
Flow rate | "Gravity Flow Rate Testing in Enteral Tubes" as described in the "Catalog of Regulatory Science Tools to Help Assess New Medical Devices" | The Mucosal Impedance Measurement System functioned as intended. |
Tensile strength | EN1615:2000 Enteral Feeding Catheters And Enteral Giving Sets For Single Use And Their Connectors. Design And Testing (Section 4.1.1) AND EN1618:1997 Catheters other than intravascular catheters - Test methods for common properties (Annex B) | The Mucosal Impedance Measurement System functioned as intended. |
Liquid leakage | EN1615:2000 Enteral Feeding Catheters And Enteral Giving Sets For Single Use And Their Connectors. Design And Testing (Sections 4.1.3) AND EN1618:1997 Catheters other than intravascular catheters - Test methods for common properties (Annex C) | The Mucosal Impedance Measurement System functioned as intended. |
Security of connectors | EN1615:2000 Enteral Feeding Catheters And Enteral Giving Sets For Single Use And Their Connectors. Design And Testing (Sections 4.3.1) AND EN1618:1997 Catheters other than intravascular catheters - Test methods for common properties (Annex F) | The Mucosal Impedance Measurement System functioned as intended. |
Flexibility | ASTM F3505-21 Standard Test Method for Stent and Endovascular Prosthesis Kink Resistance | The Mucosal Impedance Measurement System functioned as intended. |
EnFit connector (dimensional verification, rigidity, fluid leakage test, stress cracking, resistance to separation from axial load, resistance to unscrewing, resistance to overriding, and disconnection by unscrewing) | ISO 80369-3:2016 Small-bore connectors for liquids and gases in healthcare applications Part 3: Connectors for enteral applications | The Mucosal Impedance Measurement System functioned as intended. |
Sterilization validation | ISO 11135:2014 Sterilization of health-care products Ethylene oxide - Requirements for the development, validation and routine control of a sterilization process for medical devices | The Mucosal Impedance Measurement System functioned as intended. |
Packaging validation | ISO 11607-1:2019 Packaging for terminally sterilized medical devices - Part 1: Requirements for materials, sterile barrier systems and packaging systems | The Mucosal Impedance Measurement System functioned as intended. |
Dimensional verification | Overall length, working length, catheter outer diameter, catheter inner diameter, sensor dimensions, and spacing of the sensors were measured. | The Mucosal Impedance Measurement System functioned as intended. |
Accuracy - thermal stability | Confirming that the measurements of the central reactance parameter (XL) remain consistent across a temperature range that covers 77-111°F (25-44°C). The PASS criterion was defined as confirming that at least 95% of all measurements are contained within a +/-1Ω tolerance. | Stability of the sensors was confirmed in terms of the dispersion (standard deviation / interquartile range) of a statistically significant number of measurements across the temperature range. The device met the PASS criterion. |
Accuracy - temporal stability | Confirming that the measurements of the central reactance parameter (XL) remain consistent across 24 hours. The PASS criterion was defined as confirming that at least 95% of all measurements are contained within a +/-1Ω tolerance (which corresponds to the accuracy stated in the Instructions for Use). | Stability of the sensors was confirmed in terms of the dispersion (standard deviation / interquartile range) of a statistically significant number of measurements over the 24-hour period. The device met the PASS criterion. |
Biocompatibility | Evaluated according to FDA guidance (2023) "Use of International Standard ISO 10993-1," assessing toxicity, irritation, and sensitization. | Results support the biocompatibility of the Athena Catheter. |
Software | A failure or flaw of the software functions does not present a hazardous situation with a probable risk of death or serious injury. (Basic documentation level identified per FDA Guidance). | The software documentation was found to be at the basic level, implying it met this criterion. |
Electrical Safety and Electromagnetic Compatibility (EMC) | Basic safety evaluation per the FDA consensus standard IEC-60601-1.2005, AMD1.2012. EMC testing per IEC-60601-1-2.2014. | The test reports addressed basic safety and EMC testing, and passed the applicable clauses. |
Human factors | Usability validated in an actual clinical environment for intended users and environment, according to "Applying Human Factors and Usability Engineering to Medical Devices" guidance and EN 60601-1-6:2010, AMD1:2013. | All evaluations have been performed according to the specified standards, supporting the safety and effectiveness of the device. |
Animal Study (Gastric Mucosal Perfusion) | GLP prospective, controlled animal trial with a shock group (MAP ≤ 48 mmHg) compared to a control group, measuring XL and commonly used markers of global perfusion. Target: five continuous impedance measurements per subject/group for 5 hours. | Demonstrated gastric impedance measurements were performed safely and XL measurement was an indirect and consistent marker of gastric mucosal perfusion in the subject animals, showing significant and detectable changes before commonly used markers of global perfusion under hypovolemic shock conditions. There were no adverse events. |
2. Sample Size Used for the Test Set and Data Provenance
- Non-clinical/Bench Studies: The specific sample sizes for each bench test (e.g., flow rate, tensile strength) are not explicitly stated as numerical values in the provided text, but are implied by the use of standards that typically define such sample sizes. The text mentions "a statistically significative number of measurements" for thermal and temporal stability, indicating appropriate methodology.
- Animal Study:
- Control group (CG): N=5
- Shock group (SG): N=16
- Data Provenance: This was a GLP prospective, controlled animal trial. The country of origin of the data is not specified.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
For the non-clinical/bench studies, animal studies, and human factors, the "ground truth" is established by adherence to recognized international and FDA standards/guidances (e.g., ISO, EN, ASTM, FDA guidance documents). There is no mention of specific human experts establishing ground truth for these quantitative technical performance tests in the same way an expert would for an AI diagnostic algorithm.
4. Adjudication Method for the Test Set
Not applicable in the context of these device performance studies, which involve objective measurements against predefined engineering and biological performance criteria, rather than expert-based interpretation.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No. The provided text does not describe an MRMC comparative effectiveness study involving human readers with and without AI assistance. The device is described as measuring and displaying "XL" values, which are direct measurements, not an AI-based interpretation or diagnostic aid for human readers.
6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study
Yes, in essence. The internal performance evaluations (e.g., thermal stability, temporal stability, electrical safety, software validation) and the animal study tested the device's ability to accurately collect and process data and function as intended without human interpretation as the primary endpoint. The device's output (XL measurements) is for human interpretation and clinical decision-making, but the studies described focus on the accuracy and stability of the measurement itself rather than a diagnostic output of an AI algorithm. The device is "not for use as a sole diagnostic screening tool."
7. Type of Ground Truth Used
- Bench Studies: Established by defined physical properties, engineering specifications, and compliance with international standards (e.g., ISO, EN, ASTM).
- Biocompatibility: Established by compliance with ISO 10993-1 and FDA guidance, indicating a lack of toxicity, irritation, and sensitization.
- Software: Established by compliance with FDA guidance for software functions, ensuring no hazardous situations.
- Electrical Safety & EMC: Established by compliance with IEC standards.
- Human Factors: Established by compliance with EN 60601-1-6 and FDA guidance, ensuring usability for safety and effectiveness.
- Animal Study: Established by measuring physiological parameters and comparing the device's XL measurements to established markers of global perfusion under induced hypovolemic shock conditions in a controlled, prospective GLP study.
8. Sample Size for the Training Set
The provided text does not mention a training set, as this device's performance evaluation focuses on the accuracy and stability of direct physiological measurements and its engineering compliance, rather than a machine learning model that requires training data. The "proprietary algorithm" processes measured voltage to calculate the impedance spectrum and Central Reactance parameter (XL), but there's no indication it's a machine learning algorithm requiring a separate training phase with labeled data in the context of this submission.
9. How the Ground Truth for the Training Set Was Established
Not applicable, as no training set for a machine learning model is described.
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