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510(k) Data Aggregation
(192 days)
The Di-Chem, Inc. Citryte Acid Concentrate for bicarbonate dialysis is indicated for use in the treatment of acute and chronic hemodialysis. It is to be used with the appropriate hemodialysis machine and sodium bicarbonate.
The Di-Chem, Inc. proposed Citryte hemodialysis acid concentrate is provided in dry form and is for use in sodium bicarbonate dialysis. Citryte is comprised of sodium chloride (100.0mEq/L), potassium chloride (1.0-3.0mEq/L), calcium chloride (2.0-3.0mEq/L), magnesium chloride ( 1.0 mEq/L), dextrose ( 100 mg%), and citric acid (2.4mEq/L). All of the chemical constituents meet USP grade or equivalent. The proposed device will be manufactured, tested and labeled in accordance to ANSI/AAMI 13958:2014 guidelines. Each of the proposed formulations will be offered in three different mix volumes, 16.5 gallon, 20 gallon and 25 gallon to meet the three mix volume sizes of the current commercially available hemodialysis mixing machines. Each case of product contains the measured amount of each chemical component corresponding to the labeled product formula and listed final solution volume. The product packaging consists of two equal weight bags of sodium chloride, one bag of dextrose and one bag containing the citric acid, potassium chloride, calcium chloride and magnesium chloride. Each product bag is labeled indicating its contents, lot number, use by date, and product formula. The product bags are comprised of polyethylene and are 18"x24"x0.004". The four bags are then packaged into one corrugate box. Each box will contain all of the chemical components to make one of the three available volumes of the labeled formulation. The product is intended to be mixed into solution using water meeting or exceeding ANSI/AAMI Hemodialysis Water Quality Standards utilizing commercially available hemodialysis concentrate mixers in accordance with the mixer manufacturer's directions. These chemicals when in solution are intended to be used as the acid portion of a three part hemodialysis treatment in conventional commercially available hemodialysis machines or monitors in providing a hemodialysis treatment. The hemodialysis formulations presented in this 510(k) notification are intended to be used in a three-stream hemodialysis machine in which an acid concentrate (Citryte) is proportioned into one stream, a sodium bicarbonate concentrate solution is proportioned into another stream and a specified volume of water is proportioned into the remaining stream of the hemodialysis machines proportioning system. These three streams are then mixed by the hemodialysis machine to prepare a final proportioned hemodialysis solution. These proportioned hemodialysis solutions are then heated to body temperature and pumped through the hemodialysis compartment of a hemodialyzer (artificial kidney). These hemodialysis solutions are separated from the patient's blood by a semi-permeable cellulosic or non-cellulosic membrane which functions as a molecular weight selective barrier to the passage of molecules above a certain molecular weight. The semi-permeable membrane in the hemodialyzer permits the passage of both ionized and non-ionized molecules, waste products and toxins including blood urea, nitrogen, creatinine and potassium contained in the patient's blood circulating through the hemodialyzer to pass through the semi-permeable membrane into the hemodialysis solution then circulating back to the hemodialysis machine where the solution is ultimately discarded. The ionic and molecular composition of the hemodialysis solution establishes the concentration gradient between the patient's blood and the hemodialysis solution passing through the hemodialyzer which permits the effective removal of waste products and toxins found in excess in the patient's blood during acute and end-stage renal failure. Since different patients have different requirements for the removal rates and quantities of the various molecules and toxins in acute and end-stage renal failure it is necessary to have a variety of different hemodialysis solution formulations to satisfy the needs of all renal failure patients. For this reason the Citryte is offered in multiple formulations containing varying amounts of potassium chloride and calcium chloride.
The document provided is a 510(k) premarket notification for a medical device called Citryte™ Acid Concentrate. This type of submission is for demonstrating substantial equivalence to a legally marketed predicate device rather than proving safety and effectiveness through clinical trials. Therefore, the information requested, particularly regarding clinical study design, ground truth establishment, expert adjudication, and sample sizes for training/test sets in the context of an AI/ML device, is not applicable to this submission.
However, I can extract the acceptance criteria and the (non-clinical) study details that demonstrate the device meets these criteria.
1. Table of Acceptance Criteria and Reported Device Performance
Criteria | Specification (Acceptance Criteria) | Reported Device Performance |
---|---|---|
Formulary Ingredient Range | Sodium: 100.0 mEq/L | 100.0 mEq/L |
Calcium: 2.0 - 3.0 mEq/L | Provided in various formulations within this range (2.0, 2.25, 2.5, 3.0 mEq/L) | |
Potassium: 1.0 - 3.0 mEq/L | Provided in various formulations within this range (1.0, 2.0, 3.0 mEq/L) | |
Magnesium: 1.0 mEq/L | 1.0 mEq/L | |
Dextrose: 100 mg/dl (or 100 mg%) | 100 mg% | |
Citric Acid: 2.4 mEq/L | 2.4 mEq/L | |
Acetate: 0 - 0.3 mEq/L | 0 (The proposed Citryte device does not contain sodium acetate, while a reference predicate has 0.3mEq/L) | |
Chemical Composition Accuracy | All electrolytes identified on the device label shall be present within ±5% or ±0.1mEq/L (expressed as dialysis fluid concentrations), whichever is greater, except sodium, which shall be present within ±2.5% of the labeled concentration. Glucose shall be present within ±5% or ±0.05g/L (expressed as dialysis fluid concentrations), whichever is greater. (In accordance with ANSI/AAMI 13958:2014) | The results of in vitro testing confirmed the proposed Citryte device met the listed range requirements stated in ANSI/AAMI 13958:2014 and is chemically equivalent to the predicate devices for all the listed chemical formulations. |
Packaging Materials | Identical with primary predicate devices and reference predicate (Hemo-Lyte Sodium Bicarbonate). Similar to DRYalysate. Polyethylene bags, 18"x24"x0.004". | Exact same packaging materials (polyethylene bags, 18"x24"x0.004") sourced from the same suppliers were used. |
Manufacturing Standards | Manufactured, tested, and labeled in accordance with ANSI/AAMI 13958:2014 guidelines. | Device will be manufactured, tested, and labeled in accordance to ANSI/AAMI 13958:2014 guidelines. Testing results confirmed compliance. |
Intended Use | Indicated for use in the treatment of acute and chronic hemodialysis with the appropriate hemodialysis machine and sodium bicarbonate. | Identical to the predicate devices: "The Di-Chem, Inc. Citryte™ Acid Concentrate for bicarbonate dialysis is indicated for use in the treatment of acute and chronic hemodialysis. It is to be used with the appropriate hemodialysis machine and sodium bicarbonate." |
The study that proves the device meets the acceptance criteria is an in vitro non-clinical test.
2. Sample size used for the test set and the data provenance:
- Test Set Sample Size: Not explicitly stated as a number of distinct "samples" in the traditional sense of a clinical or imaging study. The testing was done on the chemical composition of the manufactured device.
- Data Provenance: The testing was "in vitro" and performed by Di-Chem, Inc. ("utilizing our standard operating procedures"). This is a manufacturer's internal testing. Not specified if retrospective or prospective, but typically such verification testing would be prospective for new product batches or formulations.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
This is Not Applicable (N/A). The ground truth for the chemical composition is based on the ANSI/AAMI 13958:2014 standard specifications for concentrates for hemodialysis and analytical chemistry methods. It does not involve expert readers or interpretations in the medical sense.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:
N/A. Adjudication methods are relevant for subjective interpretations (e.g., image reading). Here, the assessment is objective chemical analysis against a standard.
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:
N/A. This is a chemical concentrate for hemodialysis, not an AI/ML-driven diagnostic or assistive device that would involve human readers.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
N/A. Not an AI/ML device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
The ground truth used for evaluating the chemical composition of the Citryte™ Acid Concentrate is based on established chemical analytical methods and adherence to the ANSI/AAMI 13958:2014 standard. The standard specifies the acceptable ranges for electrolytes and glucose in hemodialysis concentrates.
8. The sample size for the training set:
N/A. This is not an AI/ML device; therefore, there is no "training set."
9. How the ground truth for the training set was established:
N/A.
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(156 days)
The Fresenius 2008T is indicated for acute and chronic dialysis therapy.
The optional CDX modification incorporates a standard Windows/Linux capable computer (PC board) into the 2008T giving clinics the option to load data management software into the machine. With data management software on the machine the user may then interface with the program, using the machines preexisting alphanumeric keyboard, then transfer treatment data directly from the 2008T machine to their In-center medical information system. Additionally, the selection of Citrasate® (K000792) and DRYalvsate® (K980659) acid concentrates have been added to the selection of acid concentrates available to our customers on the 2008T hemodialysis machine. The user interface has been changed to allow the user to select Citrasate/DRYalysate from the dialysis screen of the 2008T hemodialysis machine and to display the proper constituents of the concentrate.
The provided text describes modifications to the Fresenius 2008T Hemodialysis Machine, not a diagnostic AI device. Therefore, the requested information categories (acceptance criteria, sample sizes, expert ground truth, MRMC study, standalone performance, training set details) are largely not applicable in the context of this medical device (a hemodialysis machine) and the information available in this 510(k) summary.
However, I can extract information related to acceptance criteria and "studies" as presented in the document, interpreting them in the context of a non-AI medical device submission.
Here's an attempt to answer based on the provided text, noting where the requested AI-specific information is not available:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria Category | Reported Device Performance |
---|---|
Software Functionality | Acceptance Criteria: Modifications to the 2008T hemodialysis functions as intended and modifications did not negatively impact the overall 2008T hemodialysis machine system. |
Reported Performance: Full system validation and software regression testing were performed. "The results from the testing demonstrated that all modifications functioned as intended and met pre-determined acceptance criteria." (Specific details of acceptance criteria for software were not provided beyond successful functioning and no negative impact). | |
Electromagnetic Compatibility (EMC) | Acceptance Criteria: Compliance with IEC 60601-1-2 (2007) Class A. |
Reported Performance: EMC testing was conducted according to IEC 60601-1-2 (2007) Class A. "The modified 2008T hemodialysis machine... met the requirements for IEC 60601-1-2 devices." | |
Electrical Safety | Acceptance Criteria: Compliance with UL 60601-1, 1st Edition, 2006-04-26, and CAN/CSA-C22.2 No. 601.1-M90, 2005. |
Reported Performance: Electrical safety testing was conducted according to the specified standards. "The modified 2008T hemodialysis machine was found to comply with the above standards." | |
System Performance (with Citrasate®) | Acceptance Criteria: Function as intended when using Citrasate® acid concentrate and meet pre-determined acceptance criteria (specific criteria not detailed). |
Reported Performance: "System performance testing using Citrasate® acid concentrate" was performed. "The results from the testing demonstrated that all modifications functioned as intended and met pre-determined acceptance criteria." (Specific details of acceptance criteria for system performance were not provided beyond successful functioning). |
2. Sample Size Used for the Test Set and Data Provenance
The document does not specify a "test set" in the context of data for an AI algorithm. The testing described (software validation, EMC, electrical safety, system performance) would typically involve physical units of the device and simulation/testing environments rather than a "data set." Therefore, information on sample size for an AI test set or data provenance (country, retrospective/prospective) is not applicable/not provided.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
This information is not applicable/not provided as the submission is for a physical medical device (hemodialysis machine) with minor modifications, not an AI algorithm requiring expert-established ground truth on data.
4. Adjudication Method for the Test Set
This information is not applicable/not provided as the submission is for a physical 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
This information is not applicable/not provided. This is not an AI-assisted diagnostic or decision support device.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
This information is not applicable/not provided. This is not an AI algorithm.
7. The Type of Ground Truth Used
The concept of "ground truth" as it relates to expert consensus, pathology, or outcomes data for an AI algorithm is not applicable here. The "truth" in this context is the successful and compliant operation of the physical device according to engineering standards and regulatory requirements.
8. The Sample Size for the Training Set
This information is not applicable/not provided. This is not an AI algorithm, so there is no "training set."
9. How the Ground Truth for the Training Set Was Established
This information is not applicable/not provided. There is no "training set" or corresponding ground truth establishment for an AI algorithm in this submission.
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