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510(k) Data Aggregation
(190 days)
The Maximus™ System provides features of both the Synclara™ System and the Volara™ System.
The Maximus™ System, when used as a Synclara™ Cough System is intended for use on patients who are unable to cough or clear secretions effectively due to reduced peak cough expiratory flow or respiratory muscle weakness.
The Maximus™ System, when used as a Volara™ System is intended for the mobilization of secretions, lung expansion therapy, the treatment and prevention of pulmonary atelectasis, and has the ability to provide supplemental oxygen when used with oxygen supply.
The Maximus™ System is a 2 in 1 device which is a combination of two (2) already cleared devices. The Maximus™ System provides the individual therapies of the predicates: Vital Cough and MetaNeb®. The Maximus™ can be programmed to allow the user to provide both therapies or one only. The 2 main types of therapies are referred to as:
- . MIE (Mechanical Insufflation-Exsufflation)
- OLE (Oscillation and Lung Expansion) ●
The provided text is a 510(k) premarket notification for the Maximus™ System, a medical device for respiratory therapy. It outlines the device's indications for use and compares it to predicate devices to establish substantial equivalence with respect to safety and effectiveness.
Here's an analysis of the acceptance criteria and the study that proves the device meets them, based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance:
The document doesn't explicitly present a formal "acceptance criteria" table with numerical targets, as is common for diagnostic accuracy studies. Instead, it argues for substantial equivalence to predicate devices. This means the primary acceptance criterion is that the Maximus™ System performs functionally and safely similar to its predicates (MetaNeb® and Vital Cough) and does not raise new or different questions of safety or effectiveness.
The comparison tables (Table 1, Table 2, Table 3 – although some are presented partially) serve as the 'reported device performance' against the implicit acceptance criterion of equivalence to the predicates.
Feature / Performance Metric | Acceptance Criteria (Implicit - Equivalence to Predicates) | Reported Maximus™ System Performance |
---|---|---|
Indications for Use | Identical to predicates (MetaNeb® K124032, K151689; Vital Cough K132988) | Identical for mobilization of secretions, lung expansion therapy, treatment and prevention of pulmonary atelectasis, ability to provide supplemental oxygen. The Maximus™ System combines features of Synclara™ (MIE) and Volara™ (OLE). |
Patient Population | Identical to predicates | Volara™ mode: Adult, Child > 2 years old (acute); >5 years old (home care). Synclara™ mode: Adult and pediatric. (Identical to respective predicates). |
Environment of Use | Identical to predicates | Hospital, sub-acute facilities, nursing care, homecare. (Identical to respective predicates). |
OLE: Peak Positive Pressures | ≤ 30 cmH2O (Predicate MetaNeb®) | Up to 70 cmH2O (Supported by reference device Bird IPV K895425 with 80 cmH2O) |
OLE: Patient Circuit - Adjustable Resistance | Present (Predicate MetaNeb®) | No resistance adjustment feature; therapy settings done at control unit. |
MIE: Max Positive and Negative Pressures | +50 cmH2O / -50 cmH2O (Predicate Vital Cough) | +70 cmH2O / -70 cmH2O (Supported by reference device Philips Respironics Cough Assist T70 K121955 with same pressures). Max pre-set of +50 cmH2O in home setting. |
Nebulizer Performance | Substantially equivalent to predicate | Comparative nebulizer performance across all therapy modes and pressure ranges demonstrated substantial equivalence with the Philips SideStream nebulizer. Mouthpiece vs. face mask performance also equivalent. |
Software Control / User Interface | Manual (Predicates) | Software-controlled, GUI screen. Performance and usability evaluated. |
Pulse Oximeter Connection | Not offered (Predicates) | Can connect via Bluetooth to cleared Beijing Choice Electronic Technology Co., Ltd. Fingertip Pulse Oximeter (K142888). Displays heart rate and SpO2. (This is an added feature, not a comparative one, but is deemed not to raise new safety/effectiveness questions). |
Biocompatibility | Meet applicable requirements (ISO 10993, ISO 18562) | Materials in gas and fluid pathway tested per ISO 10993-1 and ISO 18562 and found to meet applicable requirements. |
Bench Testing Performance | Substantially equivalent to predicates | Demonstrated equivalence through: Simulated Life Cycle, Biocompatibility, Software V&V, Electrical safety/EMC, Comparative Performance in CHFO, CPEP, Aerosol and MIE modes, Comparative Nebulizer Performance, Inter-/Intra-sample variability, pre-/post-cleaning nebulizer performance, Usability. |
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 primarily describes bench testing and comparative performance testing against predicate devices and reference devices. It does not refer to clinical studies with patient test sets in the context of diagnostic accuracy. Therefore, details regarding "sample size for the test set" or "data provenance (country of origin, retrospective/prospective)" for patient data are not applicable to this 510(k) submission, which focuses on substantial equivalence based on performance and safety characteristics compared to existing devices.
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 provided. As this is a medical device submitting for substantial equivalence based on engineering and performance criteria rather than diagnostic accuracy with a ground truth established by experts, this type of detail is not expected or relevant in this context. The "ground truth" here is the established safe and effective operation of the predicate devices.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. There is no human adjudication of a "test set" in the context of diagnostic performance as described in the document.
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. The Maximus™ System is a therapeutic device (noncontinuous ventilator), not a diagnostic AI system that "assists human readers." Therefore, an MRMC comparative effectiveness study is not relevant to this submission.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
Not applicable. The Maximus™ System is a physical electro-mechanical device that delivers therapy, not a standalone algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
The "ground truth" in this 510(k) submission for substantial equivalence is the established safe and effective performance of the predicate devices (Hill-Rom MetaNeb® and Vital Cough), as well as reference devices (Bird IPV and Philips Respironics Cough Assist T70) for specific performance parameters. The device's performance is compared against these established benchmarks through various bench tests.
8. The sample size for the training set
Not applicable. The document describes a physical medical device, not a machine learning model that requires a "training set."
9. How the ground truth for the training set was established
Not applicable. As there is no machine learning model or "training set," this question is not relevant.
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(268 days)
The MetaNeb® 4 System is indicated for mobilization of secretions, lung expansion therapy, the treatment and prevention of pulmonary atelectasis, and also has the ability to provide supplemental oxygen when used with compressed oxygen.
The MetaNeb® 4 System is a therapeutic device that uses a systematic approach to enhance normal mucus clearance and resolve or prevent patchy atelectasis. The system has three modes: Aerosol, CHFO (Continuous High Frequency Oscillation), and CPEP (Continuous Positive Expiratory Pressure). There are three major components: Circuit, Controller, and Stand.
Here's an analysis of the provided text regarding acceptance criteria and the study that proves the device meets those criteria, structured according to your request:
Device Name: MetaNeb® 4 System
1. Table of Acceptance Criteria and Reported Device Performance
The submission primarily focuses on demonstrating substantial equivalence to predicate devices, particularly the MetaNeb® (K124032), rather than establishing new, specific performance acceptance criteria for the MetaNeb® 4 System itself. The acceptance criteria are implicitly met by showing the MetaNeb® 4 System performs equivalently or better than the identified predicates in key performance parameters.
The key performance comparisons are related to peak pressure in different therapy modes.
Acceptance Criteria (Implicitly, equivalence to predicate performance) | Reported Device Performance (MetaNeb® 4 System) | Predicate Performance (MetaNeb® K124032) |
---|---|---|
CPEP Mode @ High Flow Peak Pressure (cmH2O): Equivalent to predicate. | 10.7 to 29.9 | 10.7 to 29.9 |
CPEP Mode @ Medium Flow Peak Pressure (cmH2O): Equivalent to predicate. | 7.7 to 14.6 | 7.7 to 14.6 |
CPEP Mode @ Low Flow Peak Pressure (cmH2O): Equivalent to predicate. | 0.2 to 2.0 | 0.2 to 2.0 |
CHFO Mode @ High Flow Peak Pressure (cmH2O): Equivalent to predicate. | 11.2 to 25.4 | 11.2 to 25.4 |
CHFO Mode @ Low Flow Peak Pressure (cmH2O): Equivalent to predicate, specifically referencing K124032 data. | 8.7 to 20.3 | 8.7 to 20.3 |
Usability (Home Environment): All critical tasks completed successfully without use errors leading to unacceptable harm. | 100% of participants (caregivers and lay users) completed all tasks successfully without use errors that could lead to unacceptable risk of harm. | Not directly comparable, as the predicate did not include home use. |
2. Sample Size Used for the Test Set and Data Provenance
- Performance Comparison (Peak Pressure): The sample size for the bench tests is not explicitly stated as a numerical value (i.e., 'n'). The testing involved comparing the MetaNeb® 4 System to the MetaNeb® (K124032), PowerNeb (K051964), and IPV (K895485). The data provenance is generally "bench testing" performed by the manufacturer (Hill-Rom Services Pte Ltd). It's a prospective study of the device's physical performance characteristics.
- Usability Study: The sample size is referred to as "2 user groups: caregivers and lay users." The specific number of participants within each group is not provided in this summary. The data provenance is a usability study conducted to evaluate the device's use in the home environment, likely a prospective study. The country of origin of the data is not specified.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of Those Experts
This type of information is not applicable to this submission. The "ground truth" for the performance tests (peak pressure) is the physical measurement of the device's output, compared against its own specifications and the previously cleared predicate devices' performance. For the usability study, the "ground truth" is the observation of user performance, not expert consensus on medical images or diagnoses.
4. Adjudication Method for the Test Set
This information is not applicable as it typically refers to methods for resolving discrepancies in expert interpretations (e.g., in medical image analysis). For bench testing, direct measurement and data collection are used. For the usability study, observations of user performance were recorded, often with predefined criteria for success/failure, but an adjudication method for conflicting expert opinions is not mentioned because experts (in the sense of adjudicators) are not setting the "ground truth."
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and the Effect Size of How Much Human Readers Improve with AI vs. Without AI Assistance
This information is not applicable. The MetaNeb® 4 System is a therapeutic medical device (non-continuous ventilator), not an AI/CAD (Computer-Aided Detection/Diagnosis) system. Therefore, MRMC studies and AI-assisted improvements for human readers are not relevant.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
This information is not applicable. The MetaNeb® 4 System is a physical device, not an algorithm.
7. The Type of Ground Truth Used
- Performance Comparison (Peak Pressure): The ground truth is established through physical measurements and engineering specifications of the device's output in various modes, compared to the previously established performance of predicate devices. This falls under bench testing data.
- Usability Study: The ground truth is established through direct observation of user performance in conducting critical tasks with the device in a simulated environment. This is a form of empirical user performance data.
8. The Sample Size for the Training Set
This information is not applicable. Since this is a physical medical device (MetaNeb® 4 System) and its development involved engineering design and validation against performance specifications and predicate devices, there isn't a "training set" in the context of machine learning or AI.
9. How the Ground Truth for the Training Set Was Established
This information is not applicable for the reasons stated above (not an AI/ML device). Engineering validation and design controls are used during device development, which are different from establishing ground truth for a "training set" in AI.
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