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510(k) Data Aggregation
(77 days)
The Administration Sets are intravenous administration sets intended for delivery of medications and fluids from a container into a patient's vascular system.
The EZ™ IV Administration Set is a gravity, single use, disposable, intravenous administration set designed to deliver fluids from a container into a patient's vascular system. The device includes a vented bag spike (air vent 0.1µm) integrated to a drip chamber (not made with DEHP*) featuring a 5-μm particulate filter, a roller clamp, flexible IV tubing (not made with DEHP*), and one (1), two (2) or three (3) needle-free valve (NFV) Y-site connectors. It also features a Luer connector and a priming cap with a 3-μm filter.
The EZ™ IV Administration Set may be used in combination with standard IV therapy devices commonly used throughout the healthcare settings, such as bag spike, Luer lock adaptor, syringe (MLL) (without needle), and IV extension sets. It is configured to achieve the intended use when used with these standard complementary products.
*DEHP – Di (2-ethylhexyl) phthalate (DEHP), a plasticizer to make PVC soft and flexible. It is a substance known to cause cancer or reproductive toxicity.
The provided FDA 510(k) clearance letter and summary for the EZ™ IV Administration Set (K251814) describe the device's acceptance criteria and the studies conducted to demonstrate substantial equivalence to a predicate device. However, this document primarily focuses on demonstrating substantial equivalence rather than proving the device meets specific acceptance criteria for a novel device. It also describes a medical device rather than a software or AI-driven device, so several of the requested categories (e.g., sample size for test set, number of experts, adjudication method, MRMC study, training set details) are not applicable.
Here's an analysis based on the provided text, focusing on the available information:
Acceptance Criteria and Device Performance for EZ™ IV Administration Set (K251814)
1. Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria for the EZ™ IV Administration Set are primarily defined by adherence to recognized international and national standards for intravascular administration sets and specific functional performance metrics derived from these standards. The reported device performance indicates compliance with these standards.
Characteristic Compared | Acceptance Criteria (Standard Reference) | Reported Device Performance (Subject Device) |
---|---|---|
Performance Testing | Conformance with: |
- ISO 8536-4:2019
- ISO 22413:2021
- ISO 10993-1:2018
- ANSI/AAMI CN27:2021
- ISO 80369-7:2021
- ISO 80369-20:2015
- FDA Guidance for Intravascular Administration Sets | Comprehensive performance verification & validation testing performed; met the intended use. |
| Air-inlet device tests | ISO 8536-4:2019 | Conformed to standard. |
| Flow rate test | ISO 8536-4:2019 | Conformed to standard. |
| Piercing device penetration force test | ISO 22413:2021 | Conformed to standard. |
| Protective cap removal test | ISO 8536-4:2019 | Conformed to standard. |
| Drip chamber and drip tube tests | ISO 8536-4:2019 | Conformed to standard. |
| Leak integrity tests | ISO 8536-4:2019 (air leakage under positive pressure, air leakage under negative pressure and fluid leakage) | Conformed to standard. |
| Tensile strength test | ISO 8536-4:2019 | Conformed to standard. |
| Particulate contamination level | ISO 8536-4:2019, Annex A, A.2
USP Particulate Matter in Injections | Met contamination index, N≤90. Conformed to standard. |
| Drops/mL | 20 gtt/mL (as per Predicate) | 20 gtt/mL |
| Tubing transparency | Sufficiently clear to observe air/water interface (normal/corrected vision) | Conformed to standard. |
| Connector type | External Fitting Male Luer Lock (ISO 80369-7:2021) | Conformed to standard. |
| Sterile barrier packaging | Medical grade paper and plastic film, heat sealed | Conformed to standard. |
| Sterilization process | Ethylene Oxide (EO), SAL 10⁻⁶ | Ethylene Oxide (EO), SAL 10⁻⁶. Complies with ISO 11135:2014. |
| Shelf-life validation | 3 years (36 months) via ASTM 1980-21 | 3 years (36 months) validated. |
| Biocompatibility | ISO 10993-1:2018 (Externally Communicating Device, Blood Path Indirect, Prolonged Contact)
(Specific ISO 10993 parts for various tests) | Met biological safety specifications. |
| EO residues limits | ISO 10993-7:2008 & amendments | Conformed to standard. |
| Shipping | ASTM D 4169-16 | Simulated shipping testing performed on K151650/S004. |
| Package integrity | ASTM F1980-21, ASTM F88/F88M-21, ASTM F1929-23, EN 868-5:2009 | Testing performed on K151650. |
| Pyrogen tests | ANSI/AAMI ST72/2019, USP , USP , USP | Testing performed on K151650 and "will be conducted on every lot." |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Sample Size: The document does not specify the exact sample sizes (number of devices/batches) used for each specific performance test mentioned (e.g., flow rate, leak integrity, tensile strength). The studies are focused on product characteristics and compliance with engineering standards, not clinical patient data.
- Data Provenance: Not explicitly stated for each test. The submitter is "Epic Medical Pte. Ltd." based in Singapore, suggesting the testing data likely originated from or was managed by facilities associated with this company. The testing is for a medical device component, not a diagnostic algorithm, so there is no patient data involved in these performance tests.
- Retrospective or Prospective: Not applicable, as these are engineering and materials performance tests conducted on the physical device itself.
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)
This information is not applicable to this type of device submission. The "ground truth" here is defined by objective engineering specifications and international standards, rather than expert consensus on medical images or diagnoses. Qualification involves expertise in medical device testing, engineering, and regulatory compliance.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. Adjudication methods are relevant for subjective assessments, typically in clinical readings or evaluations where human interpretation introduces variability. These are objective physical and chemical tests on a medical device.
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 a physical medical device (IV administration set), not an AI-powered diagnostic tool, and therefore no MRMC studies were conducted or are relevant.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This is a physical medical device, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
The "ground truth" for the performance tests conducted on the EZ™ IV Administration Set is based on established international and national standards and their specific test methods and acceptance criteria. This includes standards like ISO 8536-4 for infusion sets, ISO 10993 for biocompatibility, and USP for particulate matter. These standards provide objective, measurable criteria for device performance and safety.
8. The sample size for the training set
Not applicable. This pertains to the training of an algorithm or AI model. This submission is for a physical medical device.
9. How the ground truth for the training set was established
Not applicable. As above, this is for a physical medical device and does not involve a training set for an algorithm.
Summary of Study that Proves Device Meets Acceptance Criteria:
The study that proves the EZ™ IV Administration Set meets its acceptance criteria is a comprehensive set of performance verification and validation tests conducted on the subject device and, in some cases, leveraging data from the predicate device (K230343/S001) or an existing device (K151650 and K151650/S004).
These tests address:
- Functional Performance: Evaluated against ISO 8536-4:2019, ISO 22413:2021, and FDA guidance documents, covering aspects like flow rate, leak integrity, piercing device penetration force, protective cap removal, drip chamber performance, and tensile strength.
- Connection Integrity: Evaluated against ANSI/AAMI CN27:2021 (for luer-activated valves) and ISO 80369 series (for small-bore connectors like Luer lock).
- Biocompatibility: Evaluated against ISO 10993 series (e.g., -5, -10, -11, -17, -18, -23) to assess cytotoxicity, sensitization, systemic toxicity, hemolysis, pyrogenicity, and chemical characterization. This classification was for "Externally Communicating Device, Blood Path Indirect, Prolonged Contact (>24 hr to 30 d)."
- Sterility and Shelf-Life: Compliance with ISO 11135:2014 for Ethylene Oxide sterilization, ASTM D 4169-16 for shipping, and ASTM F1980-21 for accelerated aging (shelf-life validation of 3 years). Package integrity, pyrogen, and EO residue tests were also part of this.
- Material Composition: Analysis and risk assessment were conducted given differences in materials between the subject and predicate devices, leveraging biocompatibility and chemical characterization data.
The submitter states that "All performance testing demonstrated and confirmed the safety and effectiveness of the Subject device" and that the results "met the intended use." They explicitly noted for material and dimension differences that "analytical and functional testing were conducted" and "the results...demonstrated that the performance of the Subject devices met the intended use. Therefore, the differences were considered not significant." This body of evidence constitutes the study proving the device meets its acceptance criteria, which are primarily compliance with the listed international and national standards.
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(29 days)
The Empty Fluid Container is used to hold an admixture of compatible fluids for intravenous administration to a patient. Medication transfer in and out of the container is done using aseptic technique.
The eZSURE™ Empty Fluid Container (EFC) is a sterile, nonpyrogenic, single-use intravenous (IV) bag constructed from flexible, non-PVC film. It is designed for the preparation and administration of IV fluids and is intended for disposal after a single use.
Two previously cleared subgroups include:
- eZSURE™ EFC with Needle-Free Valve (NFV) Additive Port (K223674)
- eZSURE™ EFC with ProSeal™ Injection Site Additive Port (K241442)
Both subgroups are currently available in 100 mL, 250 mL, and 500 mL capacities. This Submission introduces a new 1,000 mL capacity option for each subgroup.
Each EFC consists of a flexible plastic film bag with two (2) ports:
- Additive (filling) port – for introducing compatible fluids
- Spiking (administration/access) port – for accessing the infusate using a standard IV spike
The NFV model features a self-sealing needle-free valve additive port compatible with male Luer lock syringes. The Injection Site model incorporates a closed-system injection site with a double elastomeric membrane, compatible with the ProSeal™ Injector, which is also compatible with male Luer lock syringes. Both configurations support secure medication addition and maintain a sealed system after device removal.
The provided FDA 510(k) clearance letter describes a medical device, the eZSURE™ Empty Fluid Container, which is an IV bag. The submission primarily focuses on the device's technical characteristics and performance, particularly concerning the introduction of a new 1,000 mL capacity option.
Based on the provided document, the device in question (eZSURE™ Empty Fluid Container) is a Class II medical device (an I.V. container). The validation described heavily relies on bench testing and conformance to established international and national standards rather than clinical studies involving human patients or complex AI algorithms requiring extensive ground truth establishment and multi-reader studies.
Therefore, the acceptance criteria and study that proves the device meets them are focused on these engineering and biocompatibility aspects.
Here's the breakdown as requested, tailored to the information available in the 510(k) letter:
Acceptance Criteria and Device Performance for eZSURE™ Empty Fluid Container
The acceptance criteria for this device are primarily based on meeting the requirements of various recognized national and international standards related to IV containers, fluid transfer, and biocompatibility. The "study" proving acceptance consists of a series of bench tests and evaluations against these standards.
1. Table of Acceptance Criteria and Reported Device Performance
Since this is a physical medical device (an IV container) with an extension of capacity, the performance criteria are primarily related to its physical and material properties, and its ability to safely contain and dispense fluids. The provided document details a comprehensive set of tests performed.
Category | Acceptance Criteria (Standard Reference) | Reported Device Performance |
---|---|---|
I. Functional Performance | ||
Physical Integrity & Durability | - Resistance to temperature, pressure, and fluid leakage (ISO 15747:2018, Annex A.3) |
- Accelerated aging of above tests (ASTM F1980-21)
- Resistance to dropping (ISO 15747:2018, Annex A.4)
- Accelerated aging of above test (ASTM F1980-21)
- Hanger tensile strength (ISO 15747:2018, Annex A.11)
- Accelerated aging of above tests (ASTM F1980-21) | Conformant: All specified tests were performed on the Subject device (1000 mL capacity) and leveraged data from predicate devices. The Submitter's Comment indicates that functional testing was conducted and data summarized, concluding that performance results met intended use, and determined the difference in volume to be insignificant. |
| Additive Port (Common) | - Infusion container transparency (ISO 15747:2018) - Water vapor impermeability (ISO 15747:2018)
- Access port cover test (ISO 15747:2018)
- Access port penetration ability of insertion point (ISO 15747:2018)
- Access port adhesion strength of infusion device and impermeability of insertion point (ISO 15747:2018)
- Access port liquid tightness of insertion point (ISO 15747:2018)
- Identification test (ISO 15747:2018)
- Raw container and test fluids requirements (ISO 15747:2018)
- Impermeability to microorganism and migration (ISO 15747:2018)
- 7-day microbial ingress (FDA guidance and AAMI CN27:2021) | Conformant: These tests were performed with the NFV filling port version (under K223674) or demonstrated to be equivalent. Results implied conformance, as the submission states no substantial differences raised concerns and performance met intended use. |
| Additive Port (ProSeal™ Specific) | - Additive port air and liquid tightness (ISO 15747:2018) - Impermeability to microorganism (ISO 15747:2018)
- Additive port positive pressure fluid leakage (ISO 80369-7:2021)
- Sub-atmospheric pressure air leakage (ISO 80369-7:2021)
- Stress cracking (ISO 80369-7:2021)
- Resistance to separation from axial load (ISO 80369-7:2021)
- Resistance to unscrewing (ISO 80369-7:2021)
- Resistance to overriding (ISO 80369-7:2021)
- Device leakage integrity (ISO 8536-4:2019)
- Vapor containment test (NIOSH 2016 draft protocol)
- Microbial ingress (FDA guidance and AAMI CN27:2021) | Conformant: These tests were performed with the Injection Site filling port version (under K241442 and K240433) or demonstrated to be equivalent. Results implied conformance, as the submission states no substantial differences raised concerns and performance met intended use. |
| II. Biocompatibility | - Cytotoxicity (ISO 10993-5:2009) - Sensitization (ISO 10993-10:2010)
- Intracutaneous reactivity (ISO 10993-23:2021)
- Acute systemic toxicity (ISO 10993-11:2017)
- Subacute/subchronic systemic toxicity (ISO 10993-11:2017)
- In-vitro hemolysis (ISO 10993-4:2017)
- Material mediated pyrogenicity (ISO 10993-11:2017)
- Chemical characterization and toxicological risk assessment (ISO 10993-18:2020 & ISO 10993-17:2002)
- Particulate matter testing (ISO 15747:2018 & USP )
- EO residues limits (ISO 10993-7:2008, Amd.1:2019) | Acceptable Biological Risks Established: Testing was conducted under predicate devices (K223674/S001, K241442, K240433) and the Subject device. The Submitter's Comment explicitly states: "The biocompatibility testing and chemical characterization as well as risk analysis data on cleared device were evaluated for the Subject device... The difference was determined to be insignificant as results were determined to have met the device's biological safety specifications." Testing also confirmed compliance with EO residue limits for special patient populations. |
| III. Sterility, Shipping, and Shelf-Life | - Sterilization validation (ISO 11135:2014) - Simulated shipping testing (ASTM D 4169-16)
- Package integrity (ASTM F1980-21, ASTM F88/F88M-21, ASTM F1929-23, EN 868-5:2009)
- Pyrogen tests (ANSI/AAMI ST72/2019, USP 42-NF 37 , , )
- Shelf-life validation (3 years, ASTM 1980-21) | Conformant: The Subject device complies with ISO 11135:2014. Shipping and package integrity tests leveraged data from prior submissions (K151650/S004, K223674/S001, K151650). Pyrogen tests performed under K151650 will be conducted on every lot. A 3-year shelf-life was validated on the Subject device. |
2. Sample Size Used for the Test Set and the Data Provenance
- Sample Size for Test Set: The document does not explicitly state the numerical sample size (e.g., "n=X units") for each specific test conducted on the 1000 mL subject device. It lists the types of tests performed and the standards they adhere to. For physical device testing, sample sizes are typically defined by the standards themselves (e.g., a certain number of units per lot, or a statistical sampling plan to achieve confidence). The statement "functional testing have been conducted and their data are summarized in section VII.A" implies sufficient samples were used to meet the standards' requirements.
- Data Provenance: The data provenance is primarily from bench testing conducted by the manufacturer or authorized test labs. The document mentions leveraging "relevant testing data from the Predicate devices and the existing device: K223674/S001, K241442 and K230343/S001" for many of the functional and biocompatibility tests, with specific tests performed "On Subject device" (the new 1000 mL version). The country of origin of the data is not specified beyond the company being in Singapore. All data is retrospective in the sense that it's historical data generated for the submission, but the tests themselves were designed to prospectively evaluate the device's performance against defined criteria.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts
This type of device (an IV container) does not typically involve expert "ground truth" establishment in the way AI/radiology devices do. The "ground truth" is established by adherence to pre-defined, internationally recognized engineering and scientific standards (e.g., ISO, ASTM, USP) and their associated test methods. Experts involved would be engineers, material scientists, and quality assurance professionals responsible for designing, executing, and interpreting these standardized tests. Their qualifications would be in engineering, chemistry, biology, or related fields, with experience in medical device testing and regulatory compliance. The document does not specify the number or specific qualifications of these individuals.
4. Adjudication Method for the Test Set
Not applicable. As described above, the "ground truth" is based on established technical standards, not on subjective human interpretation requiring adjudication. Performance is measured against quantitative or qualitative acceptance criteria defined by these standards.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. This type of study is relevant for diagnostic devices, especially those involving image interpretation (e.g., AI in radiology), where human performance (with and without AI assistance) needs to be assessed. This device is a physical IV container and does not involve human readers for diagnostic interpretation.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
No, a standalone algorithm performance study was not done. This device is a physical medical device, not an AI algorithm.
7. The Type of Ground Truth Used
The ground truth used is primarily based on:
- Engineering and Performance Standards: The device's ability to meet specified physical, mechanical, and chemical properties as defined by ISO, AAMI, ASTM, and USP standards.
- Biocompatibility Standards: The device's materials and their extracts demonstrating acceptable biological compatibility as per ISO 10993 series.
- Sterility Assurance: Validation of the sterilization process and maintenance of sterility as per ISO 11135.
This is fundamentally different from ground truth for AI algorithms which might use expert consensus or pathology results.
8. The Sample Size for the Training Set
Not applicable. This is a physical medical device, not an AI algorithm that requires a "training set" of data.
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there is no training set for this type of device.
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(107 days)
The ProSeal™ Closed System drug Transfer Device (CSTD) mechanically prohibits environmental contaminants from entering the system and the escape of drug or vapor concentrations from thereby minimizing individual and environmental exposure to drug vapor, aerosols, and spills. The ProSeal™ system also prevents the introduction of microbial contaminations into the drug or fluid path for up to 7 days when used as intended.
The ProSeal™ CSTD is a sterile, single-use, pyrogen-free CSTD for the preparation, reconstitution, compounding, and administration of antineoplastic and hazardous drugs, intended for use in clinical settings by trained health care professionals and/or pharmacists.
The ProSeal™ Closed System Bag Access is a component of the ProSeal™ CSTD system which is intended for connection to a standard I.V. bag and appropriate ProSeal™ CSTD component devices for the injection and infusion of I.V. infusion fluids. It is an adaptor between IV bags and ProSeal™ CSTD components for closed system fluid transfer into and out of the I.V. bag. The Subject bag access is compatible with the ProSeal™ Injector or the ProSeal™ Injector Plus (cleared K240171) and other ProSeal™ component devices, e.g. ProSeal™ Closed System Administration Set (for infusion from the I.V. bag). The ProSeal™ Closed System Bag Access and all its corresponding interface membranes exhibit a dry connection with the communicating surfaces in a fluid transfer. The use of this component device and its appropriate ProSeal CSTD connecting component device reduces the risk of microbial ingress for up to 168 hours or 7 days, when used as intended.
The closed transfer of liquid that takes place with the use of the ProSeal™ CSTD system as follows:
- A double membrane septum design utilizing self-sealing elastomeric membranes tightly fits . together when the system components engage. A cannula within the ProSeal™ Injector Plus housing perforates the double membranes for the transfer of liquid. When the cannula is retracted, the membranes seal off the transfer of environmental contaminants into the system and/or escape of drug or vapor concentrations outside the system, thereby minimizing the individual and environmental exposure to drug vapor, aerosols, and spills, and also minimizing the risk of microbial contamination, when used as intended.
Based on the provided FDA 510(k) summary for the ProSeal™ Closed System Bag Access (K241988), here's a breakdown of the acceptance criteria and the study that proves the device meets them:
Disclaimer: This document is a 510(k) summary, which provides an overview of the substantial equivalence determination. It does not contain the full details of all the studies performed. Therefore, specific quantitative performance metrics beyond what is explicitly stated for acceptance and observed results are not available in this summary.
1. Table of Acceptance Criteria and Reported Device Performance
The provided document describes functional performance, biocompatibility, sterility, shipping, and shelf-life testing. While specific quantitative acceptance criteria are not explicitly listed in a single table with corresponding numerical results, the document states conformance to various ISO and FDA recognized standards. The "Comment/Discussion" column in the comparison table indicates "Same" or "Similar" for many characteristics, implying that the acceptance criteria are met by demonstrating equivalence to the predicate device and adherence to standards.
For functional performance, the document lists the following tests and their corresponding standards, implying that meeting these standards constitutes the acceptance criteria. The performance data "supporting substantial equivalence" suggests that the device met these criteria.
Acceptance Criteria (Implied by Standard Conformance) | Reported Device Performance (Implied) |
---|---|
Functional Performance | |
Leak integrity (per ISO 8536-4:2019, 7.2 & A.3) | Bench performance verifications and validations performed, indicating conformance. |
Tensile strength (per ISO 8536-4:2019, 7.3 & A.4) | Bench performance verifications and validations performed, indicating conformance. |
Penetration force (per ISO 22413:2021, 6.6 & A.7) | Bench performance verifications and validations performed, indicating conformance. |
Protective caps (per ISO 8536-4:2019, 7.13) | Bench performance verifications and validations performed, indicating conformance. |
Vapor containment (per NIOSH CSTD 2016 draft protocol) | "from testing data on devices cleared under K222929" (implying met, as K222929 was cleared) |
Microbial ingress (per FDA guidance & ANSI AAMI CN27:2021) | "from testing data on devices cleared under K222929" (implying met, as K222929 was cleared and previous devices established "up to 7 days" prevention) |
Biocompatibility (Classified: Externally Communicating Device, Blood Path Indirect, Prolonged Contact) | |
Cytotoxicity (per ISO 10993-5) | Performed on referred-to cleared devices (K222929), implying met. |
Sensitization (per ISO 10993-10) | Performed on referred-to cleared devices (K222929), implying met. |
Intracutaneous Reactivity (per ISO 10993-10) | Performed on referred-to cleared devices (K222929), implying met. |
Acute Systemic Toxicity (per ISO 10993-11) | Performed on referred-to cleared devices (K222929), implying met. |
14-day Subacute/Subchronic Acute Systemic Toxicity (per ISO 10993-11) | Performed on referred-to cleared devices (K222929), implying met. |
In-vitro Hemolysis Assessment (per ISO 10993-4) | Performed on referred-to cleared devices (K222929), implying met. |
Material Mediated Pyrogenicity (per ISO 10993-11) | Performed on referred-to cleared devices (K222929), implying met. |
Particulate matter (per ISO 8536-4:2019 and USP ) | Testing conducted on Subject device, implying met. |
Sterility & Shelf-Life | |
Sterilization (per ISO 11135:2014, SAL 10-6) | Complies with standard, testing/evaluations conducted on K222929, implying met. |
Simulated shipping (per ASTM D 4169-16) | Testing conducted, implying met. |
Package integrity (per ASTM F1980-21, F88/F88M-21, F1929-23, EN 868-5:2009) | Testing performed, implying met. |
Pyrogen Tests (per ANSI/AAMI ST72/2019, USP , , ) | Testing conducted "on every lot", implying met. |
Shelf-life (3 years) | Validated using ASTM 1980-21, implying met. |
2. Sample Sizes Used for the Test Set and Data Provenance
The document does not explicitly state the specific sample sizes used for each of the functional performance, biocompatibility, or sterility tests. It refers to various ISO and ASTM standards, which typically prescribe minimum sample sizes for such tests.
- Data Provenance: The document states "Bench performance verifications and validations referred-to and performed" and "testing data on devices cleared under K222929." This indicates that the testing was primarily benchtop testing (laboratory-based) and retrospective, leveraging data from previously cleared devices within the ProSeal™ CSTD system (specifically K222929). There is no mention of data provenance by country of origin or specific patient data since the studies are physical/chemical rather than clinical.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
This section is Not Applicable to this 510(k) submission. The device is a physical medical device (intravascular administration set component), not an AI/ML diagnostic or image analysis device that requires expert human interpretation to establish ground truth from medical images or clinical data. Its performance is evaluated through physical, mechanical, and biological testing against established standards.
4. Adjudication Method for the Test Set
This section is Not Applicable. Adjudication methods (like 2+1, 3+1 consensus) are typically used in clinical studies involving human interpretation or subjective assessments, especially for AI/ML devices where ground truth might be derived from multiple expert opinions. For a physical device undergoing performance and safety testing against objective engineering and biological standards, such adjudication is not relevant.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done, Effect Size of how much Human Readers Improve with AI vs. without AI Assistance
This section is Not Applicable. An MRMC study is relevant for diagnostic or AI-assisted diagnostic devices that evaluate human reader performance. The ProSeal™ Closed System Bag Access is a hardware component for drug transfer and does not involve human readers interpreting medical cases.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done
This section is Not Applicable. This concept applies to AI/ML software. The ProSeal™ Closed System Bag Access is a physical device component.
7. The Type of Ground Truth Used
The "ground truth" for this device's performance is established by conformance to internationally recognized performance standards (e.g., ISO, ASTM, USP, ANSI/AAMI) for medical devices, specifically for intravascular administration sets and closed system transfer devices. This includes:
- Engineering/Physical Standards: Defining acceptable ranges for leak integrity, tensile strength, penetration force, package integrity, etc.
- Biological Standards: Defining acceptable levels for biocompatibility (cytotoxicity, sensitization, systemic toxicity, hemolysis, pyrogenicity) and sterility.
- Functional Claim Validation: Demonstration of preventing microbial ingress and vapor containment as defined by specific test protocols (e.g., microbial ingress test, vapor containment test).
8. The Sample Size for the Training Set
This section is Not Applicable. The product is a physical medical device, not an AI/ML algorithm. Therefore, there is no "training set" in the machine learning sense. The design and manufacturing processes are validated through engineering principles and compliance with quality systems (e.g., 21 CFR Part 820).
9. How the Ground Truth for the Training Set Was Established
This section is Not Applicable for the same reason as point 8.
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(67 days)
The ToxiSeal™ Vial Adaptor mechanically prohibits environments from entering the system and the escape of drug or vapor concentrations from the system, thereby minimizing individual and environmental exposure to drug vapor, aerosols, and spills. The device also prevents the introduction of microbial contaminations into the drug or fluid path for up to 168 hours (or 7 days) when used as intended.
The ToxiSeal™ Vial Adaptor devices are single-use, sterile, non-pyrogenic CSTD drug vial adaptors that are fitted to the drug vials and are sealed against the closures of the vials. They are used as sterile interfaces between the drug vials and the ProSeal™ Injector or the ProSeal™ Injector Plus (both are syringe adaptors) for the injection of diluents into the drug vials and/or withdrawal of liquids from the vials. Changes proposed in this Special 510(k) Submission are as follow: Removed external balloon and added activated carbon filter.
The provided document is a 510(k) summary for the ToxiSeal™ Vial Adaptor (K241823). It describes the device, its intended use, a comparison to a predicate device, and performance data supporting its substantial equivalence. However, the document does not contain information about an AI/software device or a comparative effectiveness study involving human readers with and without AI assistance.
Therefore, I cannot provide information for points 5, 8, and 9 of your request as they are not present in the document.
Based on the available information regarding the medical device itself (ToxiSeal™ Vial Adaptor), here's the information related to acceptance criteria and the studies conducted:
The ToxiSeal™ Vial Adaptor is a physical medical device, not an AI/software product. Therefore, the "acceptance criteria" and "study that proves the device meets acceptance criteria" are related to its functional performance, biocompatibility, and sterility, rather than AI performance metrics.
Acceptance Criteria and Device Performance (for a physical device)
The document outlines the various tests performed to demonstrate the device's conformance to recognized standards. The "acceptance criteria" are implied by the conformance to these standards and the findings that the device "met the acceptance criteria therein" or "did not raise any new or different questions of safety or effectiveness."
Here's a table summarizing the acceptance criteria (standards/tests) and the reported device performance.
Category | Acceptance Criteria (Standards/Tests) | Reported Device Performance |
---|---|---|
Functional Performance | - ISO 8536-2:2010 (Infusion equipment for medical use – Part 2: Closures for infusion bottles) - Evaluated to be in conformance. | |
- ISO 8536-4:2019 (Infusion equipment for medical use Part 4: Infusion sets for single use, gravity feed) - Evaluated to be in conformance. | ||
- ISO 8871-5:2016 (Elastomeric parts for parenterals and for devices for pharmaceutical use Part 5: Functional requirements and testing) - Evaluated to be in conformance. | ||
- ISO 22413:2021 (Transfer sets for pharmaceutical preparations – Requirements and test methods) - Evaluated to be in conformance. | ||
- Leak integrity testing (air- and liquid-tightness) per ISO 8536-4:2019, paragraph 7.2 and Annex A.3 - Performed successfully on both Subject and predicate devices; differences in design (activated carbon filter, no external balloon) "did not raise any new or different questions of safety or effectiveness." | ||
- Fragmentation study to ISO 22413 & ISO 8871-5 - Performed successfully on predicate device (K241476), implying substantial equivalence for the subject device. | ||
- Vial Adaptor penetration force testing to ISO 22413 - Performed successfully on predicate device (K241476), implying substantial equivalence for the subject device. | ||
- Tests for leakages to ISO 8536-4:2019, Annex A.3.3 - Performed successfully on the Subject device; differences in design "did not raise any new or different questions of safety or effectiveness." | ||
- Testing to (draft) NIOSH CSTD Test Protocol and NIOSH 2016, Performance Test Protocol for Closed System Transfer Devices Used During Pharmacy Compounding and Administration of Hazardous Drugs - Performed successfully on the Subject device and a previously cleared device (K222929); differences in design "did not raise any new or different questions of safety or effectiveness." | ||
- Microbial ingress/ microbiological integrity testing - Conducted successfully on a previously cleared device (K222929), indicating prevention of microbial contamination for up to 168 hours (7 days). | ||
Biocompatibility | - ISO 10993-1: 2018 (Biological evaluation of medical devices – Part 1: Evaluation and testing within a risk management process) - Classified as: Externally Communicating Device, Blood Path Indirect, Prolonged Contact (>24hr to 30d). - Referencing previous successful testing on existing devices of the ProSeal™ CSTD system (K192075, K192075/S001, K222929) for: Cytotoxicity (ISO 10993-5), Sensitization (ISO 10993-10), Intracutaneous Reactivity (ISO 10993-10), Acute Systemic Toxicity (ISO 10993-11), 14-day Subacute/ Subchronic Acute Systemic Toxicity (ISO 10993-11), In-vitro Hemolysis Assessment (ISO 10993-4), Material Mediated Pyrogenicity (ISO 10993-11), Chemical Characterization and Toxicological Risk Management (ISO 10993-18 and ISO 10993-17). The subject device is deemed biocompatible based on these references. | |
- USP Particulate Matter in Injections - Testing conducted on devices under K192075 and K222929, and "found to have met the acceptance criteria therein." This performance is leveraged for the subject device. | ||
Sterility & Shelf-Life | - ISO 11135:2014 (Sterilization of Health Care Products – Ethylene Oxide – Part 1: Requirements for Development, Validation and Routine Control of a Sterilization Process for Medical Devices) - "Comply with sterilization requirements." | |
- Package Integrity Tests per ASTM F1980-21 (Standard guide for accelerated aging of sterile barrier systems for medical devices), ASTM F88/F88M-21 (Seal strength), ASTM F1929-23 (Dye Penetration), EN 868-5:2009 (Heat and self-sealable pouches and reels) - Performed on the proposed device (referencing K222929) and ensure package integrity. | ||
- Pyrogen Tests per ANSI/AAMI ST72/2019, USP 40, USP-NF , USP-NF - Conducted under K222929, with testing to be conducted on every lot. | ||
- Validated shelf-life using ASTM 1980-21 - A shelf-life of 3 years (36 months) has been validated. |
Now addressing the specific points of your request based on the provided document:
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A table of acceptance criteria and the reported device performance
- See the table above. Note that for a physical medical device, "acceptance criteria" are typically defined by conformance to established performance standards and successful completion of specified tests.
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Sample sizes used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective)
- Sample Sizes: The document does not specify the exact sample sizes used for each performance test (e.g., number of devices tested for leak integrity, biocompatibility, etc.). It mentions that tests were "performed on the Subject devices," "on devices under K241476," or "on device under K222929," implying samples were used from these device types.
- Data Provenance: The document does not explicitly state the country of origin of the data or whether the studies were retrospective or prospective. Given it's a 510(k) submission to the FDA, the data would typically be generated by the manufacturer or contract labs following international and US standards. The studies, being part of device verification and validation prior to market clearance, are generally prospective in nature for the tests conducted on the subject device.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- This question is not applicable to this type of medical device submission. Ground truth established by experts (like radiologists for imaging AI) is relevant for diagnostic accuracy studies of software/AI. For a physical device like a vial adaptor, the "ground truth" is based on objective measurements against established engineering and biological standards. There are no human "experts" establishing a diagnostic ground truth here.
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Adjudication method (e.g., 2+1, 3+1, none) for the test set
- This question is not applicable as there is no diagnostic test set or human interpretation being adjudicated. The tests are quantitative and involve laboratory measurements.
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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 document describes a physical medical device, not an AI software. No MRMC study was conducted or is relevant for this device.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not applicable. This is not an algorithm/AI device. The device's performance is standalone in the sense that its mechanical and biological properties are tested independently.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- The "ground truth" for this medical device is the objective measurement of physical properties, chemical properties, and biological safety against predefined engineering, material, and biocompatibility standards. Examples include:
- Meeting specific leakage rates.
- Absence of fragmentation.
- Demonstrating specified penetration force.
- Absence of microbial ingress.
- Absence of cytotoxicity, sensitization, systemic toxicity, pyrogenicity, and meeting particulate matter limits.
- Maintaining sterility over shelf-life.
- It's based on quantitative laboratory testing results compared to acceptance criteria defined by recognized standards (ISO, ASTM, USP, NIOSH).
- The "ground truth" for this medical device is the objective measurement of physical properties, chemical properties, and biological safety against predefined engineering, material, and biocompatibility standards. Examples include:
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The sample size for the training set
- Not applicable. This is not an AI/machine learning device; there is no "training set."
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How the ground truth for the training set was established
- Not applicable. As there is no training set for an AI model, this question does not apply.
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