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510(k) Data Aggregation

    K Number
    K250357
    Date Cleared
    2025-03-11

    (32 days)

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

    K991759, K162812, K042172, K192647

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

    The RemunityPRO™ Pump for Remodulin® (treprostinil) Injection (the RemunityPRO System) is intended for continuous subcutaneous delivery of Remodulin (treprostinil) Injection for use in patients, ages 17 and older.

    Device Description

    The RemunityPRO™ Pump for Remodulin® (treprostinil) Injection is a wearable infusion pump designed to deliver Remodulin® (treprostinil) subcutaneously for the treatment of pulmonary arterial hypertension (PAH). Remodulin® was FDA-approved under NDA 021272. The system consists of several components: a wearable pump assembly, a remote interface, and accessories (e.g., rechargeable batteries, battery charger, charging cable, power adapter). A commercially available subcutaneous infusion set is connected to the pump assembly via a standard luer connector for the delivery of Remodulin® from the system to the patient. The RemunityPRO™ Pump for Remodulin® (treprostinil) Injection is prescription use only. The pump assembly is composed of a durable pump and a disposable, single-use cassette with a userfilled drug reservoir. The pump infuses Remodulin® subcutaneously into the patient based on an individualized programmed rate. Each disposable cassette may be used for up to 72 hours after attachment to the pump. The subject system utilizes a micro-dosing pump mechanism supplemented with acoustic volume sensor feedback to ensure delivery accuracy. The subject device has updated branding and also modifies the predicate device to be used with an additional infusion set.

    AI/ML Overview

    The provided text describes a 510(k) summary for the RemunityPRO™ Pump for Remodulin® (treprostinil) Injection. This is a submission to demonstrate substantial equivalence to a legally marketed predicate device, rather than a study designed to establish acceptance criteria for an entirely new device or an AI algorithm. Therefore, many of the requested categories related to medical AI studies (like expert involvement, MRMC studies, or training sets) are not applicable.

    The core of this submission is to show that the minor changes to an existing device (the RemunityPRO™ Pump compared to the Remunity® 2.0 Pump) do not raise new questions of safety or effectiveness. The primary change highlighted is the addition of compatibility with an additional infusion set.

    Here's an attempt to fill in the requested information based on the provided text, noting where information is not applicable to this type of regulatory submission:

    Acceptance Criteria and Device Performance

    The provided document details a comparison between the subject device (RemunityPRO™ Pump) and its predicate (Remunity® 2.0 Pump). The "acceptance criteria" can be inferred from the performance characteristics of the predicate device, which the subject device is shown to match or be equivalent to.

    Acceptance Criteria (Based on Predicate Performance)Reported Device Performance (Subject Device)
    Device Classification: Class II Infusion Pump, 21 CFR 880.5725, Product Code: FRNNo change (Equivalent)
    Indications for Use: Continuous subcutaneous delivery of Remodulin (treprostinil) Injection for patients, ages 17 and older.No change (Equivalent)
    Prescription Use or OTC: PrescriptionNo change (Equivalent)
    Intended Patient Population: Age 17 years and olderNo change (Equivalent)
    Patient Environment: On-body wearable ambulatory pumpNo change (Equivalent)
    Delivery Method: Microprocessor controlled micro-dosing pump mechanism supplemented with acoustic volume sensor (AVS) feedback for monitoring delivery accuracyNo change (Equivalent)
    Delivery type: Subcutaneous infusionNo change (Equivalent)
    Dimensions: 6 cm x 6 cm x 2 cm (2.4 in x 2.4 in x 0.4 in)No change (Equivalent)
    Weight: 50 g (1.76 oz.)No change (Equivalent)
    Basal Delivery Rate Range: 8 µL/hr – 225 µL/hr, with increments of 1 µL/hrNo change (Equivalent)
    Basal Accuracy: ±6%±6% (No change/Equivalent)
    Bolus Volume after Occlusion Release: < 8 µL at all rates< 8 µL at all rates (No change/Equivalent)
    Time to Occlusion Alarm: Maximum time to occlusion alarm: • ≥ 100 µL/hr: 12 minutes • < 100 µL/hr: 8 hoursMaximum time to occlusion alarm: • ≥ 100 µL/hr: 12 minutes • < 100 µL/hr: 8 hours (No change/Equivalent)
    Material Biocompatibility: Fluid contacting: Polycarbonate (PC), COP, Bromobutyl, SEBS, Polyurethane. Patient contacting: PC, Acrylic, Polyurethane, ABS, Aluminum.No change (Equivalent)
    Cassette Shelf Life: 2 years2 years (No change/Equivalent)
    Service Life: 3 years3 years (No change/Equivalent)
    Applicable Safety Standards: IEC 60601-1, IEC 60601-1-2, IEC 60601-1-8, IEC 60601-1-11, IEC 60601-2-24, ISO 11137-1, ISO 10993-1, ISO 14971, IEC 60601-4-2, ANSI C63.27, AIM 7351731No change (Equivalent)
    Power Source: Rechargeable Lithium Ion BatteryNo change (Equivalent)
    Pump Storage Conditions: Temperature: -25 °C to 70 °C (-13 °F to 158 °F), Non-condensing humidity: up to 90%, Pressure: 50 kPa to 106 kPaNo change (Equivalent)
    Operating Conditions: Temperature: 5 °C to 40 °C (41 °F to 104 °F), Non-condensing humidity: up to 90%, Pressure: 70 kPa to 106 kPaNo change (Equivalent)
    Remote Interface System User Feedback: Touchscreen Device, Visual, audible, vibratoryNo change (Equivalent)
    Battery Operating Time: 72 hours72 hours (No change/Equivalent)
    Infusion Set Compatibility: Medtronic Quick-set, Medtronic Silhouette, Smiths Medical Cleo 90 Infusion SetsEquivalent - The subject device adds compatibility with the Neria Guard Infusion Set. Performance testing with Neria Guard demonstrated equivalent performance to the predicate device with established methods and acceptance criteria.
    Cassette: Unity 2.0 Cassettes, 3 mL, user-filledNo change (Equivalent)
    Priming Method: Primed by Pump after Cassette attachment to the PumpNo change (Equivalent)

    Study Details

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

      • The document states: "Bench performance testing was conducted in order to qualify the additional infusion set for use with the subject device, and to establish substantial equivalence to the predicate device in terms of safety and effectiveness."
      • Specific sample sizes for these bench tests are not provided in the summary.
      • Data provenance is not specified, but it would typically be internal laboratory testing by DEKA Research & Development Corp.
    2. 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):

      • Not Applicable. This is a bench performance study for a physical medical device (infusion pump), not a study involving interpretation of medical data by experts to establish ground truth for an AI algorithm. The performance metrics are objective and measurable (e.g., flow rate accuracy, occlusion alarm time).
    3. Adjudication method (e.g. 2+1, 3+1, none) for the test set:

      • Not Applicable. As this is a bench performance study of a physical device, there is no "adjudication" in the sense of resolving discrepancies between human readers or AI outputs. The tests involve direct measurement against established physical standards.
    4. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:

      • No. This is not an AI-assisted diagnostic or interpretative device; it's an infusion pump. Therefore, an MRMC study is not relevant.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

      • Not Applicable. While the pump contains a microprocessor and control algorithms, the "standalone" context typically refers to the performance of an AI algorithm in isolation for diagnostic tasks. This device is a complete system with mechanical, electronic, and software components, and its performance is evaluated as a whole in bench testing.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc):

      • The "ground truth" for this type of device performance would be established physical and electrical measurement standards, regulatory standards (e.g., IEC 60601-2-24 for infusion pumps), and the known performance characteristics of the predicate device. These are objective engineering and regulatory requirements, not medical "ground truth" derived from patient data or expert consensus.
    7. The sample size for the training set:

      • Not Applicable. This device, while containing software, is not an AI/ML-driven device that undergoes a "training" phase in the context of machine learning. Its operation is based on programmed control logic and physical components.
    8. How the ground truth for the training set was established:

      • Not Applicable. As there is no AI/ML training set, this question is not relevant.
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    K Number
    K243354
    Device Name
    Remunity System
    Date Cleared
    2024-11-27

    (29 days)

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

    K991759, K162812, K042172, K192647

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

    The Remunity® Pump for Remodulin® (treprosimil) Injection (the Remunity System) is intended for continuous subcutaneous delivery of Remodulin (treprostinil) Injection for use in adults (greater than 22 years old).

    Device Description

    The Remunity Subcutaneous Delivery System for Remodulin® (Remunity System) is a wearable infusion pump designed to deliver Remodulin® for the treatment of pulmonary arterial hypertension (PAH). It is intended for continuous subcutaneous delivery of FDA-approved Remodulin® (treprostinil) (hereinafter referred to as 'Remodulin®' or 'Remodulin® (treprostinil)'), NDA 021272. The Remunity System consists of several components: a wearable pump assembly, a remote interface, a filling and priming aid, and accessories (e.g., rechargeable batteries, battery charger, charging cable, power adapter). A commercially available subcutaneous infusion set is connected to the pump assembly via a standard luer connector for the delivery of Remodulin® from the Remunity System to the patient.

    The pump assembly is composed of a reusable pump and a disposable single-use cassette with a pharmacy-filled or user-filled drug reservoir, which infuses Remodulin® subcutaneously into the patient based on an individualized programmed rate. Each disposable cassette may be used for up to 72 hours after attachment to the pump. The Remunity System utilizes a micro-dosing pump mechanism supplemented with acoustic volume sensor feedback to ensure delivery accuracy.

    The device is prescription use only.

    The modified device can be used with an additional infusion set.

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for a medical device called the "Remunity System," which is an infusion pump. The submission is for a modified version of an already cleared device, and the primary modification discussed is the addition of a compatible infusion set.

    Here's an analysis of the requested information based on the provided text:

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

    The document does not explicitly state acceptance criteria in a quantitative manner for specific performance characteristics of the new infusion set. Instead, it states that "Performance testing with the Neria Guard demonstrates that subject device performance is equivalent to the predicate device. The methods and acceptance criteria used in this testing are well established in previous clearances."

    However, the table comparing the predicate device and the subject device does list several performance characteristics and their values, which implicitly serve as the performance requirements that the modified device must meet to be considered equivalent. Since the subject device is stated to have "No change" in all these characteristics except the infusion set, it implies that the modified device performs identically to the predicate device for these parameters.

    Acceptance Criteria (Implicit from Predicate Device Performance)

    CharacteristicAcceptance Criteria (Predicate Device Performance)Reported Device Performance (Subject Device)
    Basal Delivery Rate Range16 µL/hr – 225 µL/hr, increments of 1 µL/hrNo change (implies 16 µL/hr – 225 µL/hr, increments of 1 µL/hr)
    Basal Accuracy±6%No change (implies ±6%)
    Bolus Volume after Occlusion Release< 40 µL at all ratesNo change (implies < 40 µL at all rates)
    Time to Occlusion Alarm (≥ 100 µL/hr)Maximum 12 minutesNo change (implies Maximum 12 minutes)
    Time to Occlusion Alarm (< 100 µL/hr)Maximum 8 hoursNo change (implies Maximum 8 hours)
    Pump Service Life3 yearsNo change (implies 3 years)
    Ingress ProtectionIP58 when connected to the CassetteNo change (implies IP58)
    Battery Operating Time72 hoursNo change (implies 72 hours)

    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 discusses "bench performance testing." It does not specify the sample size for this testing. It also does not mention the country of origin of the data or whether the data was retrospective or prospective. Given that it is bench testing, it would inherently be prospective data collected in a laboratory setting.

    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 in the document. The testing described is "bench performance testing" which typically does not involve human experts establishing "ground truth" in the same way clinical or diagnostic studies do. The "ground truth" in this context would be physical measurements of pump performance against engineering specifications.

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

    This information is not provided and is not applicable for bench performance testing of an infusion pump. Adjudication methods are typically used in clinical studies, especially those involving human interpretation of medical images or outcomes.

    5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

    No MRMC study was done. The device in question is an infusion pump, which is a hardware device for delivering medication, not an AI-powered diagnostic tool requiring human reader interpretation. Therefore, questions about human readers and AI assistance are not relevant to this device and its clearance.

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

    The device is an infusion pump; therefore, the concept of "standalone algorithm performance" as typically applied to AI/ML devices is not directly applicable. The device's performance, as measured in bench testing, is inherently its "standalone" performance without "human-in-the-loop" assistance in terms of its core function (drug delivery accuracy, occlusion detection, etc.).

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

    For the bench performance testing of the infusion pump, the "ground truth" would be engineering specifications and metrology measurements. This isn't based on expert consensus, pathology, or outcomes data. It's about measuring physical phenomena (e.g., fluid volume delivered, time to alarm) against predefined design requirements.

    8. The sample size for the training set

    This information is not provided and is not applicable. This device is an infusion pump, which is a physical medical device, not a machine learning or AI algorithm that requires a "training set" of data in the conventional sense. Its function is based on mechanical and electronic engineering principles.

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

    This information is not provided and is not applicable as explained in point 8.

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    K Number
    K160860
    Manufacturer
    Date Cleared
    2016-09-22

    (177 days)

    Product Code
    Regulation Number
    880.6920
    Reference & Predicate Devices
    Predicate For
    N/A
    Why did this record match?
    Reference Devices :

    K991759, K011071, K160651

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

    The MiniMed Quick-serter is indicated to use as an aid for inserting compatible devices. It is for use by a single patient. It is not for use by multiple patients.

    Device Description

    The modified MiniMed Quick-serter (MMT-305) is a non-sterile, single patient, multi-use, hand held accessory product designed to be used as an insertion aid for compatible devices, including specific infusion sets. It is used to insert the introducer needle and cannula through the skin and into the subcutaneous tissue. The MiniMed Quick-serter is intended to be used by a patient or clinician as a means to insert an infusion set with minimum discomfort and technique dependency.

    The MiniMed Quick-serter consists of a plastic barrel containing a stainless steel spring and a handle. The device user places and securely seats the infusion set into the MiniMed Quick-serter is loaded and locked by pulling the handle (compressing the spring) until it clicks/locks into place. The serter is placed in contact with the insertion site and fired to release the infusion set. This is done by depressing the green side buttons to release the spring, which drives the infusion set forward and the insertion needle and cannula are inserted into the user's subcutaneous tissue. The release button on the top of the device is then pressed to ease the release of the infusion set from the serter.

    AI/ML Overview

    The provided text describes a 510(k) submission for the "MiniMed Quick-serter" (MMT-305) and compares it to a predicate device (MMT-395). This device is a syringe needle introducer, and the submission is focused on demonstrating substantial equivalence, not necessarily on detailing a study proving the device meets acceptance criteria in the way one would for a novel AI/software medical device.

    Therefore, the information I can extract will be specific to the type of device and submission, which involves engineering and biocompatibility testing rather than clinical study protocols for diagnostic accuracy or comparative effectiveness with human readers.

    Here's the breakdown based on the provided text:

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

    The document lists performance testing that was conducted to verify the device's mechanical properties and functions. The "acceptance criteria" are implied by the statement "Results from performance testing indicate that the product meets the established performance requirements." Specific numerical acceptance criteria are not explicitly detailed for each test in this summary, but the reported device performance for some characteristics is given in the comparison table.

    DescriptionAcceptance Criteria (Implied)Reported Device Performance (Modified MMT-305)
    ClassificationClass IIClass II
    Product CodeKZHKZH
    Type of UseOver the CounterOver the Counter
    CompatibilityMiniMed Quick-set Infusion Set, MiniMed Pro-set Infusion SetMiniMed Quick-set Infusion Set, MiniMed Pro-set Infusion Set
    Condition of useSingle patient, multi-useSingle patient, multi-use
    Energy SourceSpring DrivenSpring Driven
    Mode of actionManual operationManual operation
    Cocking Force<5 lbfIdentical (to predicate, which is <5 lbf)
    Trigger/release Force<7 lbf0.67 lbf - 7lbf
    Diameter(Comparison to predicate)1.96 inches
    Width of Pull Handle(Comparison to predicate)1.59 inches
    Set release buttonMade distinct from pull handleSet release button and pull handle are made distinct
    SterilityNon-sterileNon-sterile
    Validated Cleaning MethodManualManual
    Service Life3 years3 years
    BiocompatibilityAcceptable for intended useAcceptable for its intended use by Biological Evaluation (based on ISO 10993-1, -5, -10, -18)
    Verification TestingMeets "established performance requirements"All listed tests completed and met internal standards/requirements.

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

    The document does not specify the sample size for individual tests. The tests performed are engineering/mechanical verification, biocompatibility, and usability evaluations, not clinical studies with a "test set" in the context of patient data. The data provenance is internal to Medtronic MiniMed, and the tests are prospective, conducted on the 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 is not applicable to the type of device and testing described. "Ground truth" in this context would refer to established engineering standards, material science properties, and biocompatibility guidelines. The "experts" involved would be engineers, material scientists, and toxicologists conducting and evaluating the tests. No specific number or qualifications are mentioned for this section of the submission. A "Usability Evaluation" was performed, which would involve users, but details on "experts" for ground truth are not provided.

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

    This is not applicable. Adjudication methods are typically for clinical trials or diagnostic studies where there might be disagreement in expert opinions on patient data. The tests described are objective engineering and biocompatibility evaluations.

    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 is not applicable. The device is a mechanical introducer, not AI software or a diagnostic tool.

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

    This is not applicable. The device is a mechanical device with a human user performing the insertion.

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

    The "ground truth" for the performance data in this submission aligns with:

    • Established engineering standards: For tests like Cocking Force, Trigger Force, Life Cycle testing, Drop Test, etc., the ground truth is based on predefined engineering specifications and internal standards.
    • International standards and regulatory guidance: For biocompatibility testing, the ground truth is based on standards such as ISO 10993-1, -5, -10, -18 and FDA #G95-1 guidance.
    • Industry standards: For tasks like Ship Test (ASTM D4169) and Cleaning studies (AAMI TIR12, TIR30).

    8. The sample size for the training set

    This is not applicable. The device is a mechanical product, not a machine learning model that requires a training set.

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

    This is not applicable for the reasons stated above.

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    K Number
    K132142
    Manufacturer
    Date Cleared
    2013-10-08

    (89 days)

    Product Code
    Regulation Number
    880.5440
    Reference & Predicate Devices
    Predicate For
    N/A
    Why did this record match?
    Reference Devices :

    K032854, K991759

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

    The neria™ soft 90 infusion set is Indicated for subcutaneous infusion of medication administered by an external pump.

    Device Description

    The neria™ soft 90 subcutaneous infusion set is a new product designed by Unomedical based on the Unomedical Inset™ Subcutaneous Infusion Set and Unomedical Quick-Set® Subcutaneous Infusion Set.

    The neria™ soft 90 is a 90 degree soft cannula infusion set with a standard luer-lock connection. The neria™ soft 90 subcutaneous infusion set consists of an introducer needle/insertion handle that inserts the soft cannula into the skin and is removed immediately after insertion, a cannula housing that rests upon the skin with adhesive tape, securing the soft cannula in place under the skin, tubing with disconnect option and a reservoir connector (standard luer lock) and disconnect cover for the tubing and cannula housing.

    The proposed configurations are:

    • includes tubing and cannula . Infusion Set
    • Tubing Only ●
    • . Cannula only
    AI/ML Overview

    Acceptance Criteria and Device Performance for neria™ soft 90 Infusion Set

    This document details the acceptance criteria and study information for the neria™ soft 90 Infusion Set, based on the provided 510(k) summary.

    1. Table of Acceptance Criteria and Reported Device Performance

    The provided document describes the device as being substantially equivalent to its predicate devices based on non-clinical performance data. Therefore, the "acceptance criteria" are implied by the successful execution of these tests and compliance with relevant standards. The "reported device performance" is that the device passed all tests.

    Acceptance Criteria CategorySpecific Tests ConductedReported Device Performance (Target/Outcome)
    Functional PerformanceLeak/Tightness TestPassed (Meets requirements)
    Flow (Occlusion) TestPassed (Meets requirements)
    Tensile Test (introducer needle, tubing connections, soft cannula, adhesive tape, connector from cannula housing, connector needle)Passed (Meets requirements for overall design)
    Packaging IntegrityDynamic Peel TestPassed (Meets requirements)
    Visual Peel TestPassed (Meets requirements)
    Print on Packaging and Labeling InspectionPassed (Meets requirements)
    Transportation DurabilityTransportation Tests (General)Passed (Meets requirements)
    Drop TestPassed (Meets requirements)
    Dimensional AccuracyDistance soft cannula to setPassed (Meets requirements)
    Distance of introducer needle bevel to soft cannulaPassed (Meets requirements)
    Length of tubesPassed (Meets requirements)
    BiocompatibilityBiocompatibility Testing (in accordance with ISO 10993-1)Passed (Complies with ISO 10993-1)
    Sterilization & ResidualsEO/ECH residuals TestingPassed (Meets requirements)
    Pyrogen/Endotoxin TestingPassed (Meets requirements)
    Sterilization TestingPassed (Complies with applicable standards)
    Shelf LifeShelf Life TestingPassed (Results demonstrate 3 years shelf life)

    2. Sample Size Used for the Test Set and Data Provenance

    The document does not explicitly state the sample sizes used for each of the non-clinical tests. It only indicates that "a number of tests" were completed. Given that this is a 510(k) submission for substantial equivalence based on non-clinical data, it is highly likely that standard testing protocols and sample sizes specified by relevant national and international standards (e.g., ISO, ASTM) were followed.

    The data provenance is from Unomedical A/S (the manufacturer) and is retrospective in the sense that these tests were performed on the device prototypes and finalized designs prior to submission. The country of origin of the data is Denmark (where Unomedical A/S is located), as well as any external testing facilities used for specific tests.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications

    This information is not applicable as the evaluation relies on non-clinical performance data (functional, mechanical, material, and sterilization tests) rather than human interpretation of medical images or clinical outcomes requiring clinical ground truth establishment. These tests are assessed against predefined specifications and industry standards by qualified laboratory personnel and engineers.

    4. Adjudication Method for the Test Set

    This information is not applicable for the non-clinical performance data presented. Adjudication methods like "2+1" or "3+1" are typically used in clinical studies or studies involving human readers/interpreters where there is an element of subjective judgment, and discrepancies need to be resolved. The non-clinical tests involve objective measurements and pass/fail criteria based on established standards.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and the Effect Size

    No, a multi-reader multi-case (MRMC) comparative effectiveness study was not done. The submission explicitly states: "There was no clinical testing required to support the medical device as the indications for use is equivalent to the predicate device." Therefore, there is no effect size related to human reader improvement with or without AI assistance.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

    No, there was no standalone algorithm performance study conducted. The neria™ soft 90 Infusion Set is a physical medical device, not an AI/software-as-a-medical-device (SaMD) or an algorithm.

    7. The Type of Ground Truth Used

    The "ground truth" for this device's evaluation is based on pre-established physical, chemical, and biological specifications and standards. For example:

    • Engineering specifications: Tensile strength limits, flow rates, dimensional tolerances.
    • Material standards: Biocompatibility according to ISO 10993 standards.
    • Sterilization standards: Assurance of sterility.
    • Packaging standards: Peel strength, integrity.

    These standards and specifications serve as the "ground truth" against which the device's performance is measured.

    8. The Sample Size for the Training Set

    This information is not applicable. The neria™ soft 90 Infusion Set is a physical medical device. It does not employ machine learning or AI algorithms that require a "training set."

    9. How the Ground Truth for the Training Set Was Established

    This information is not applicable as there is no training set for this device.

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    K Number
    K021487
    Date Cleared
    2002-05-17

    (9 days)

    Product Code
    Regulation Number
    880.5440
    Reference & Predicate Devices
    Predicate For
    N/A
    Why did this record match?
    Reference Devices :

    K020990, K991759

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

    The intended use of the Simplicity Easy Access P Infusion Set is to provide a means for infusion and/or injection of fluids into the body below the surface of the skin when attached to a MiniMed Paradigm pump or syringe.

    Device Description

    Sterling Medivations Inc.'s ("SMI") Simplicity Easy Access P designed for use by people with diabetes for the infusion and/or injection of fluids into the body below the surface of the skin when attached to a MiniMed Paradigm pump or syringe. It is inserted into thssue of a patient and the catheter is attached to the infusion device. It is substantially equivalent to the Simplicity ™ Easy Access Infusion Set, K014062 and Soft YP Infusion Set, FDA 510 (k) K011187.

    The Simplicity Easy Access P Infusion Set proposed for commercial distribution is similar in all significant respects to the existing Simplicity Easy Access Infusion Set, FDA 510 (k) K014062 and it has the same intended use.

    The device consists of four main parts: (1) infusion catheters made from AISI 304 stainless steel, (2) an infusion hub that provides the patient the capability of disconnecting tube from the infusion catheter, (3) a connecting tube and (4) a threaded YP connector.

    The Simplicity Easy Access P Infusion Set is an infusion administration set, connecting to a medicine reservoir or syringe that is placed in an external infusion device and inserted below the surface of the skin of a patient. The SMI Simplicity Easy Access Infusion Set may be used with any Paradigm infusion device that delivers continuous or intermittent flow.

    The administration set attaches to the reservoir/syringe by means of a threaded YP connector, and under the surface of the skin in the patient through an indwelling needles formed from AISI 304 stainless steel. The connecting tubing is made from a polyethylene tube.

    The indwelling needles formed from AISI 304 stainless steel are introduced below the surface of the skin. The connector needle is attached to the indwelling catheter. This seal on the connector needle mates with the indwelling catheter hub that forms a seal that permits the infusion of medication without leakage. The connector needle is made from AISI 304 stainless steel and it is connecting tubing. The connector tubing proximal end is attached to a threaded YP connector for attachment to the Paradigm medicine reservoir.

    AI/ML Overview

    The provided document is a 510(k) premarket notification for a medical device called the "Simplicity™ Easy Access P Infusion Set." This type of submission focuses on demonstrating substantial equivalence to a legally marketed predicate device rather than presenting a formal study with detailed acceptance criteria and performance data as might be found for a new and novel device.

    Therefore, much of the requested information (acceptance criteria in terms of performance metrics, sample sizes for test/training sets, expert qualifications, adjudication methods, MRMC studies, standalone performance, and ground truth types) is not applicable or not present in this type of regulatory document.

    However, based on the information provided, here's what can be inferred:


    1. Table of Acceptance Criteria and Reported Device Performance

    Not explicitly presented in the typical format of performance metrics and thresholds. Instead, the "acceptance criteria" are compliance with established medical device standards and the "reported device performance" is the demonstration that the device meets these standards, thus proving substantial equivalence.

    Acceptance Criteria (Compliance with Standards/Regulations)Reported Device Performance (Demonstrated Equivalence)
    CDRH 21 C.F.R. Section 880.5440 (Intravascular administration set)Device meets these requirements for an intravascular administration set.
    ISO 10555 Part 1: General Requirements (Sterile, single use intravascular catheters)Device meets these requirements for sterile, single-use catheters.
    ISO 10555 Part 5: Peripheral Catheters (Sterile, single use intravascular catheters)Device meets these requirements for peripheral catheters.
    ISO 11135:1994 (Validation and routine control of ethylene oxide sterilization)Device sterilization process validated according to this standard.
    ISO 11138-2:1994 (Biological indicators for ethylene oxide sterilization)Biological indicators for sterilization comply with this standard.
    ISO 9626: 1991 (Stainless Steel needle tubing for medical devices)Stainless steel needle tubing complies with this standard.
    ISO 11607: 1997 (Packaging for terminally sterilized medical devices)Device packaging complies with this standard.
    ISO 8535: 1991 (Sterile single use syringes, with or without needle, for insulin)Device is compatible with sterile single-use insulin syringes as per this standard.
    FDA Guidelines on LAL Test validationEndotoxin testing complies with FDA guidelines.
    ODE Blue Book Memorandum #K90-1Device testing followed guidelines from this memorandum.
    ISO 10993-1 (Biological evaluation of medical devices Part 1: Evaluation and testing)Device biocompatibility evaluated according to this standard.
    Center for Devices and Radiological Health. DESIGN CONTROL GUIDANCE FOR MEDICAL DEVICE MANUFACTURERS (21 CFR 820.30 and ISO 9001 Sub-clause 4.4)Device design process adhered to these guidance documents.
    Substantial Equivalence to Predicate Device (Simplicity™ Easy Access Infusion Set, K014062)Device is substantially equivalent in materials, manufacturing, labeling, and intended use.

    2. Sample size used for the test set and the data provenance

    • Sample Size: Not specified. The document states that the device "meets the catheter requirements of" various ISO standards and FDA guidelines, implying that relevant tests were conducted. However, the specific sample sizes for these tests are not provided in this summary.
    • Data Provenance: Not specified, but implied to be from internal testing conducted by Sterling Medivations, Inc. to ensure compliance with the listed standards. This would be prospective testing for regulatory submission.

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

    • This type of information is not relevant for a 510(k) submission concerning an infusion set. Ground truth, in the context of diagnostic or AI devices, refers to a definitive correct answer for a medical condition. For an infusion set, compliance is demonstrated through engineering and biocompatibility testing against established standards, not expert clinical assessment of "ground truth."

    4. Adjudication method for the test set

    • Not applicable/not specified. Adjudication methods are typically employed in clinical trials or studies where there's subjectivity in outcome assessment, often involving multiple expert readers. This is not reported for the testing of an infusion set.

    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 device is an infusion set, not an AI-powered diagnostic or decision support tool. Therefore, MRMC studies and AI assistance metrics are irrelevant.

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

    • Not applicable. This device is an infusion set, not an algorithm.

    7. The type of ground truth used

    • Not applicable in the conventional sense of clinical ground truth (e.g., pathology for a diagnosis). The "ground truth" for this device's performance is adherence to established engineering specifications, material standards (e.g., AISI 304 stainless steel), biocompatibility criteria (ISO 10993-1), sterility standards (ISO 11135), and regulatory requirements. The tests verify that the device physically functions and is manufactured safely according to these pre-defined standards.

    8. The sample size for the training set

    • Not applicable. This device is not an AI/ML algorithm that requires a training set.

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

    • Not applicable.
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