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510(k) Data Aggregation
(113 days)
Texas 78501
Re: K243898
Trade/Device Name: Chlorine Sentinel II
Regulation Number: 21 CFR 876.5665
Purification System for Hemodialysis
Classification: Class II
Regulation Number: 21 CFR 876.5665
Environmental Technologies, Inc. |
| 510(k) Number | K193169/S001 |
| Regulation Number | 21 CFR 876.5665
The Chlorine Sentinel II is intended for use by hemodialysis professionals as a secondary chlorine device to provide continuous monitoring of Combined Chlorine. It is not intended to replace the primary method of monitoring chlorine as part of the hemodialysis water treatment system. It functions completely independent of the water treatment system does not come into direct contact with feed water used to prepare dialysate.
Chlorine Sentinel II is a complete system that attaches to the drain of a hemodialysis water treatment system sample port. It detects dissolved combined chlorine in concentrations at or above 10 PPB by primary detection technology. It self-monitors for maintenance-required conditions and loss of electrical power.
The Chlorine Sentinel II is self-testing. It uses chlorinated city water to automatically test the chlorine detecting functionality of the device once a day and records if the test passed, failed to detect chlorine, or didn't rinse out after detecting chlorine.
The device is designed to use as little water as possible. The sampling water is only used for the length of time that it takes for the chlorine test to be completed. The customer determines how frequently the test needs to be taken from every 5 minutes to every 20 minutes. The user also sets the start time and end time for each day of the week.
The Chlorine Sentinel II has two combined chlorine concentration set points. The user can set a warning set-point at a value of 0.01 PPM to 0.09 PPM. Once the chlorine concentration exceeds this value, the device will alarm at 2-HZ to warn the user of chlorine present at that set-point. The second set-point is factory set at 0.10 PPM.
A chlorine concentration equal to or above the 0.10 PPM set-point will activate the buzzers and the red chlorine alarm indicators at 5 HZ for as long as the condition exists. The buzzers can only be muted for 3 minutes (then automatically reset) for as long as the condition exists. The alarms can be by-passed. When by-passed the pulsing lights will turn solid and the buzzer will double click over 15 minutes.
The front cover of the device has two screens. The screen of the chlorine monitor indicates the presence of combined chlorine when the value is not 0.000. The touch screen is used to enter user data and show the statuses of the device.
This FDA 510(k) clearance letter for the Chlorine Sentinel II provides limited specific details on acceptance criteria and study methodologies, particularly concerning clinical performance. The focus is on demonstrating substantial equivalence to a predicate device through technological comparison and bench testing.
Here's an analysis based on the provided document:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly state numerical acceptance criteria for clinical performance that can be directly compared to reported device performance metrics like sensitivity, specificity, or accuracy. Instead, the substantial equivalence is drawn based on similar intended use, technological characteristics, and performance verified through bench testing.
Based on the "Detailed Comparison of the Subject and Predicate Devices" (Page 8-10) and "Testing" (Page 14), here's a synthesis of what can be inferred about performance:
Feature/Metric | Acceptance Criteria (Implied) | Reported Device Performance |
---|---|---|
Intended Use | Same as Predicate: Secondary chlorine monitor for combined chlorine in hemodialysis feed water. | Stated as identical to Predicate for "Chlorine Sentinel II." |
Chlorine Detection Range | Similar to Predicate: 0.05 mg/L to 0.15 mg/L Cl₂ | > 0.01 mg/L (subject device's detection range, which is broader than the predicate's stated 0.05-0.15 mg/L, but still within a functional range) |
Chlorine Level Alarm | 0.1 mg/L Cl₂ | Sets alarm at 0.1 mg/L Cl₂ (factory set). |
Warning Chlorine Set-point | Ability to set a custom warning (0.01 PPM – 0.09 PPM). | User can set a warning set-point (0.01 PPM – 0.09 PPM). |
Linearity | Conformance to CLSI standard EP06-A. | "Linearity Study to CLSI standard EP06-A" performed, implying conformance. |
Limit of Blank, Quantitation, Detection | Conformance to CLSI standard EP17-A2. | "Limit of Blank, Limit of Quantitation, Limit of Detection Study to CLSI standard EP17-A2" performed, implying conformance. |
Electrical Safety / EMC | Conformance to IEC 61010-1 and IEC 60601-1-2:2020. | Testing performed in accordance with these standards, implying conformance. |
Shelf-Life | Reagent shelf-life maintained. | "Shelf-life testing has been performed for the ammonium sulfate reagent used in the predicate device," implying maintenance if applicable for the current device. |
Software Validation | Software validated as safe and effective. | "Software validation has been performed for the software component of the Chlorine Sentinel II," implying validation. |
Self-Testing | Automatic daily testing with pass/fail notification. | Automatic daily testing with notifications. |
Note: The document primarily focuses on technological equivalence and adherence to safety/testing standards rather than presenting quantitative performance metrics against specific clinical acceptance criteria for sensitivity, specificity, or accuracy in a diagnostic context. This device is a water purification system component, not a diagnostic tool.
2. Sample Size for Test Set and Data Provenance
The document describes "Performance – Bench" testing but does not specify a "test set" in the context of clinical data, nor does it provide a sample size in terms of number of cases or data provenance (country, retrospective/prospective). The studies are bench-level evaluations of the device's technical specifications and linearity.
3. Number of Experts and Qualifications for Ground Truth
The document does not mention the use of experts to establish ground truth for a test set. The validation appears to be against established analytical standards (CLSI EP06-A, EP17-A2) for linearity and detection limits, and engineering standards for safety and electromagnetic compatibility.
4. Adjudication Method
As there is no mention of human expert review or a "test set" in a clinical sense, there is no adjudication method described.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No MRMC study was done, as this device is a water purification system component and not a diagnostic device involving human interpretation of medical images or data. Therefore, there is no effect size reported for human readers improving with AI assistance.
6. Standalone (i.e., algorithm only without human-in-the-loop performance) Study
The device operates standalone in its function of monitoring chlorine. The "Performance – Bench" testing described would fall under a standalone performance evaluation, but not in the sense of a medical AI algorithm. It's a measurement device whose performance is assessed against technical specifications and analytical standards.
7. Type of Ground Truth Used
The ground truth used for performance validation appears to be:
- Analytical Standards: CLSI standard EP06-A for linearity and CLSI standard EP17-A2 for limit of blank, limit of quantitation, and limit of detection.
- Functional Specifications: The device's ability to detect chlorine at specified concentrations (e.g., 0.10 PPM alarm, 0.01 PPM warning) and perform self-tests.
- Engineering Standards: IEC 61010-1 for electrical safety and IEC 60601-1-2:2020 for electromagnetic compatibility.
This is not "expert consensus, pathology, or outcomes data" as typically seen in diagnostic device clearances.
8. Sample Size for the Training Set
The document does not mention a "training set" as it would be understood for machine learning or AI algorithms. The device's operation is based on a polarographic sensor and PLC control, not a learned model from a dataset.
9. How Ground Truth for the Training Set Was Established
Not applicable, as there is no training set in the context of machine learning or AI for this device.
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(24 days)
Trade/Device Name: UPT Series Medical RO Water Treatment System Regulation Number: 21 CFR§ 876.5665
hemodialysis |
| | Regulation: 21 CFR §876.5665
UPT Series Medical Reverse Osmosis Water Treatment System is intended to be used to remove organic and inorganic contaminants from a tap water supply to dilute a dialysate concentrate for hemodialysis treatments, as well as for use for dialyzer reprocessing and dialysis equipment disinfecting and rinsing.
This System is for multi patient use, such as for a dialysis clinic or hospital serving multiple patients with a Central Water Purification System.
The UPT Series Medical Reverse Osmosis Water Treatment System and its components consisting of; pretreatment, reverse osmosis, post-treatment, and the product water distribution components, are designed to remove microbiological, organic, and inorganic contaminants from the tap water to supply dialysis machines for the preparation of dialysate solutions for hemodialysis treatments.
Pretreatment components can include a tap water boosting system, blending valve, sediment filtration, carbon removal filters, water softeners, and all the necessary interconnecting plumbing. The purpose of this part of the system is to ensure that properly conditioned water is supplied to the reverse osmosis machine to ensure its safe and trouble-free operation.
After the tap water has been pre-treated, it then enters the R.O. (reverse osmosis), where total dissolved solids are removed to pertinent water quality standards. This is accomplished by utilizing a membrane separation process, whereby the incoming water is separated into a product stream, and a concentrate stream. The molecular weight cut-off determines what and how many contaminants are passed through into the product stream. R.O.s used for this application typically remove 95-99% of all total dissolved solids and bacteria.
The post treatment and product water distribution part of the system is in place to store, provide additional purification if needed, and deliver the purified water to wherever needed. These components can include items such as a storage tank, final filters (for bacteria and endotoxins), and delivery pumps and controls. Some systems can also utilize an ultraviolet light for additional disinfection properties if needed.
Here's an analysis of the provided text regarding acceptance criteria and study information for the UPT Series Medical RO Water Treatment System:
Summary of Acceptance Criteria and Study Details from the Provided Document K250514
Based on the provided document, the K250514 submission is for a modification to an existing device (UPT Series Medical Reverse Osmosis Water Treatment System, primary predicate K151637), specifically a clarification to its Indications for Use. Therefore, the document explicitly states that no new verification or validation performance testing was required or conducted for this update.
The conclusion section states: "Inclusive of this labeling update, the UPT Series Medical Reverse Osmosis Water Treatment System continues to meet all of its established acceptance criteria that were based upon performance of the primary predicate device." This means that the acceptance criteria and the studies proving the device meets them were originally established and performed for the primary predicate device (K151637). This current submission is a reaffirmation that the existing device still meets those established criteria despite the minor labeling change.
Therefore, the requested information cannot be fully populated from this document for the K250514 submission itself, as it refers back to the original predicate device's evaluation.
Detailed Response based on the provided K250514 document:
-
Table of Acceptance Criteria and Reported Device Performance:
Acceptance Criterion Reported Device Performance (for K250514) Water purification standards for hemodialysis (e.g., removal of microbiological, organic, and inorganic contaminants) "The UPT Series Medical Reverse Osmosis Water Treatment System continues to meet all of its established acceptance criteria that were based upon performance of the primary predicate device." Safe and effective operation for hemodialysis treatments. "This demonstrates that the device function is as safe, as effective, and performs as well as the primary predicate device." Explanation: The document does not list specific numerical or qualitative acceptance criteria beyond general statements that the system meets established standards for hemodialysis water purification. It refers to the performance established for its primary predicate device (K151637).
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Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective):
-
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 as no new performance testing was conducted for K250514.
-
Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Not applicable as no new performance testing was conducted for K250514.
-
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 a water treatment system, not an AI-assisted diagnostic tool for human readers.
-
If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. This device is a water treatment system, not an algorithm. However, the system itself operates in a standalone capacity to purify water (without human cognitive input in its core function). The functional performance evaluation related to water quality would constitute its "standalone performance." The current submission states this performance was previously established for the predicate device.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- For the original predicate device (K151637), the ground truth for its performance would likely have involved chemical and microbiological analytical testing of the treated water to ensure it met relevant AAMI standards (e.g., ANSI/AAMI RD52, ANSI/AAMI EQ82) for hemodialysis water quality. The document does not provide details on the specific "ground truth" methods used for the predicate.
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The sample size for the training set:
- Not applicable. This device is a water treatment system, not an AI/machine learning algorithm that requires a training set.
-
How the ground truth for the training set was established:
- Not applicable. This device is a water treatment system, not an AI/machine learning algorithm.
In conclusion, K250514 is a submission for a minor labeling change to an already cleared device. It explicitly states that no new performance testing was required or conducted. All acceptance criteria and proof of meeting those criteria refer back to the studies performed for the original primary predicate device (K151637). To get detailed information about the original acceptance criteria and validation studies, one would need to consult the 510(k) submission for K151637.
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(247 days)
|
| | Water purification system for hemodialysis (21 CFR § 876.5665
The Moda-flx Hemodialysis System™ is indicated for use in patients with acute and/or chronic renal failure, with or without ultrafiltration, in an acute, post-acute, or chronic care facility. Treatments must be administered under a physician's prescription, by a trained person who is considered competent in the use of the device.
Treatment types available include: Intermittent Hemodialysis (IHD), Sustained Low Efficiency Dialysis (SLED/ SLEDD), and Prolonged Intermittent Renal Replacement Therapy (PIRRT).
The Moda-flx Hemodialysis System™ Cartridge is a single use, disposable arterial and venous bloodline set, with dialysate tubing, intended to provide extracorporeal access during hemodialysis. The Moda-flx Hemodialysis System™ Cartridge is compatible only with the Moda-flx Hemodialysis System TM.
The Moda-flx Hemodialysis System™ is a transportable hemodialysis system that consists of three parts: Hemodialysis Delivery (HD) Device. Dialysate Generator (DG) Device, and a single use Moda-flx Hemodialysis System™ Cartridge that provides extracorporeal access during hemodialysis. The Moda-flx Hemodialysis System™ Cartridge is only compatible with the Modaflx Hemodialysis System™. The system creates purified water from tap water; from this purified water and chemical concentrates, the system creates dialysate in real time. The chemicals used to create the dialysate are standard 45X concentrates.
Ultrafiltration is achieved by controlling the dialysate going in and coming out of the dialyzer independently, using pumps on the HD Device to control fluid flow from both the inlet and outlet of the dialyzer. An external bag of saline is used to provide solution infusions to combat hypotensive episodes. Saline is also used to prime the Moda-flx Hemodialysis System™ Cartridge prior to use.
Prescribed blood flow rate is generated by a peristaltic pump, while heparin is administered to prevent blood coagulation. All fluid pathways are disposable and easily installed and replaced. Once installed, the device will check the connections of the fluid pathways and the system will automatically prepare itself for treatment.
This document is a 510(k) summary for the Moda-flx Hemodialysis System and Cartridge. It outlines the device's indications for use, its description, and a comparison to predicate devices, but does not provide the acceptance criteria or results of a study designed to prove the device meets specific acceptance criteria related to its clinical performance.
The "Performance Data" section lists various tests conducted, such as biocompatibility, electrical safety, software verification, and bench performance (including clearance, transport, and dialyzer integrity testing). It explicitly states that "no clinical studies were required to support this submission." This indicates that the FDA's substantial equivalence determination for this device was based on non-clinical performance data and comparison to predicate devices, rather than a clinical study demonstrating specific efficacy or clinical performance acceptance criteria.
Therefore, I cannot provide the requested information about acceptance criteria and a study proving the device meets them, as such a study (specifically a clinical one with performance metrics) is stated as not being required and thus not provided in this document.
However, based on the information provided, here's what can be inferred about the types of performance criteria and tests performed, even if specific numerical acceptance values aren't given:
Inferred Information from the Document:
While specific clinical acceptance criteria are not detailed (as no clinical study was required for this submission), the document does list various performance data provided in support of substantial equivalence. These imply underlying performance criteria for safety and technical functionality.
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Table of Acceptance Criteria and Reported Device Performance: This information is not provided in the document for clinical performance. The document only lists categories of tests performed.
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Sample size used for the test set and the data provenance: This information is not provided in the document for any of the listed performance tests. The provenance (e.g., country of origin, retrospective/prospective) is also not provided.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts: This information is not applicable/provided, as no clinical study with "ground truth" established by experts is mentioned. For the non-clinical tests (e.g., bench testing, software V&V), the "ground truth" would be the engineering specifications and regulatory standards.
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Adjudication method (e.g., 2+1, 3+1, none) for the test set: This information is not applicable/provided, as no clinical study requiring adjudication is described.
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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: This information is not applicable/provided. The device is a hemodialysis system, not an AI-assisted diagnostic tool involving human readers.
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If a standalone (i.e., algorithm only without human-in-the-loop performance) was done: This information is not applicable/provided. The device is a medical system, not an AI algorithm in the typical sense of "standalone performance" for diagnostic or predictive tasks. Performance was likely evaluated for the integrated system.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.): For the non-clinical tests mentioned (biocompatibility, electrical safety, software V&V, bench performance, etc.), the "ground truth" would be established by relevant engineering standards, regulatory requirements, and internal specifications for the device's functional performance. No clinical ground truth (like pathology or outcomes data) was used or required for this submission according to the document.
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The sample size for the training set: This information is not applicable/provided. As no clinical study requiring "training data" for an AI model is described, this question is not relevant to the provided text.
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How the ground truth for the training set was established: This information is not applicable/provided for the same reasons as point 8.
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(249 days)
Hemodialysis delivery system
21 CFR § 876.5860 - High Permeability Hemodialysis
System
21 CFR § 876.5665
The HemoCare® Hemodialysis System is indicated for hemodialysis treatment, including short daily and nocturnal hemodialysis, of renal failure patients. The HemoCare Hemodialysis System is indicated for use in chronic dialysis facilities, self-care dialysis facilities, and the home setting. All treatments must be prescribed by a physician and administered by a trained operator. Treatments must be performed with the assistance or observation of an individual who has been trained and is considered competent in the use of the device. The HemoCare Hemodialysis System is not indicated for solo hemodialysis in the home setting.
The HemoCare® Hemodialysis System is a self-contained, software-controlled device that provides hemodialysis treatments, including short daily and nocturnal hemodialysis, for patients with renal failure. The device is intended for use by a single patient in chronic dialysis facilities, self-care dialysis facilities, and the home setting. The HemoCare® Hemodialysis System is composed of the following components:
- The HemoCare® Treatment Device is a hemodialysis delivery system. When provided a source of water for dialysis, it produces infusion grade dialysate using liquid acid and powder bicarbonate concentrates. The Treatment Device provides secure, 2-way communication with the cloud for transmitting patient registration, physician-prescribed dialysis treatments, patient monitoring, and device status information.
- The HemoCare® Water Device is a water purification system that produces water for dialysis through distillation of EPA drinking water. The Water Device interfaces with the Treatment Device.
- The Blood Treatment Set connects to the patient access site and interfaces with the Treatment Device to provide extracorporeal blood flow through a dialyzer for dialysis treatment. The Blood Treatment Set is terminally sterilized and includes displacement blood pumps, a heparin delivery system, and an access disconnect sensor. The Blood Treatment set can be used for up to 16 treatments.
The provided text describes the HemoCare® Hemodialysis System, a medical device. However, it does not contain the specific information required to complete the detailed table about acceptance criteria and device performance results as requested, nor does it detail a study proving the device meets acceptance criteria in the context of an AI/ML algorithm.
The document is a 510(k) summary for a hemodialysis system, focusing on its substantial equivalence to predicate devices. It outlines performance data categories like Biocompatibility, Electrical Safety, Software Verification and Validation, Bench Performance Testing, Sterilization and Shelf Life, Human Factors, and Clinical Testing.
Importantly, the document does not describe an AI/ML algorithm that would have "acceptance criteria," "test sets," "ground truth," "expert readers," or "MRMC studies" in the context typically associated with an AI/ML medical device submission. The "Software Verification and Validation Testing" section states that "Testing results demonstrate that the device meets all software performance requirements," but it does not specify what those requirements are, nor does it indicate these requirements relate to an AI/ML diagnostic or predictive function.
Therefore, I cannot fulfill the request as the type of information sought (related to AI/ML algorithm performance) is not present in the provided text. The document is about a physical medical device (hemodialysis system) and its regulatory clearance as substantially equivalent to existing devices, not about a software-as-medical-device (SaMD) or AI-enabled medical device performance study with the detailed metrics requested.
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(266 days)
Waltham, MA 02451
Re: K232953 Trade/Device Name: AquaBplus; AquaB LITE Regulation Number: 21 CFR§ 876.5665
Regulation Name: | Water purification system for hemodialysis |
| Regulatory Class: | Class II per CFR § 876.5665
AquaBplus: The AquaBplus is a modular reverse osmosis unit intended for use with hemodialysis systems to remove organic and inorganic substances and microbial contaminants from the water used for treating hemodialysis patients or related therapies. This device is intended to be a component in a complete water purification system and is not a complete water treatment system. The reverse osmosis unit must be preceded by pre-treatment devices, and may need to be followed by post-treatment devices as well, to meet current AAMI /ANSI/ISO and Federal (U.S.) standards.
AquaB LITE: The AquaB LITE is a modular reverse osmosis unit intended for use with hemodialysis systems to remove organic and inorganic substances and microbial contaminants from the water used for treating hemodialysis patients or related therapies. This device is intended to be a component in a complete water purification system and is not a complete water treatment system. The reverse osmosis unit must be preceded by pre-treatment devices, and mav need to be followed by posttreatment devices as well, to meet current AAMI/ANSI/ISO and Federal (U.S.) standards.
The AquaBplus and AquaB LITE are reverse osmosis (RO) water purification systems that use pretreated soft water to produce dialysis water for hemodialysis (HD) devices and for the preparation of dialysis concentrates.
The AquaBplus system is a modular system consisting of a base module that can be used on its own or in conjunction with other modules. AquaBplus is the base module. AquaBplus B2 is a second RO unit that can be added to increase the quality of dialysis water. AquaBplus HF is a flow heater unit that can be added to provide heat disinfection for the RingMain. The AquaBplus HF module can also supply hot product water to connected HD devices.
The AquaB LITE system is a basic version of the AquaBplus system. Like the AquaBplus, it is a modular system consisting of a base module that can be used on its own or in conjunction with other modules. AquaB LITE is the base module and B2 LITE is a second RO unit that can be added to increase the quality of dialysis water. AquaBplus HF is a flow heater unit that can be added to provide heat disinfection for the RingMain. The AquaBplus HF module can also supply hot product water to connected HD devices.
This document is a 510(k) Premarket Notification letter for the AquaBplus and AquaB LITE water purification systems, which are used for hemodialysis. The document summarizes the device, its intended use, and the performance data that supports its substantial equivalence to a predicate device.
Here's an analysis of the acceptance criteria and the study that proves the device meets the acceptance criteria, based on the provided text:
Important Note: The provided document is an FDA 510(k) clearance letter and its associated summary. This type of document focuses on demonstrating substantial equivalence to a predicate device, rather than providing detailed results from a clinical or AI-driven study with specific acceptance criteria in the manner an AI/ML medical device might. The "performance data" sections focus on safety, general functionality, and adherence to relevant standards rather than a comparative effectiveness study with human readers or standalone AI performance. Therefore, many of the requested points regarding AI/ML study design (e.g., sample size for test/training sets, expert ground truth, MRMC studies) are not applicable or detailed in this type of submission.
The "device" in this context is a water purification system, not an AI/ML algorithm for image analysis or diagnosis.
1. A table of acceptance criteria and the reported device performance
The document does not present a formal table of "acceptance criteria" and "reported device performance" in the way one might for an AI/ML diagnostic device (e.g., sensitivity, specificity, AUC thresholds). Instead, the performance data section outlines the types of tests conducted to demonstrate that the device functions as intended and meets relevant standards to be deemed substantially equivalent. The acceptance criteria are implicitly meeting the specified standards and ensuring safety and effectiveness compared to the predicate.
Test Conducted | Test Method Description & Implicit Acceptance Criteria | Reported Device Performance |
---|---|---|
Essential Performance | Demonstrating that the device meets the following standards: |
- ISO 23500-1 (Preparation and quality management of fluids for haemodialysis and related therapies – Part 1: General requirements)
- ISO 23500-2 (Preparation and quality management of fluids for haemodialysis and related therapies – Part 2: Water treatment equipment for haemodialysis applications and related therapies)
- ISO 23500-3 (Preparation and quality management of fluids for haemodialysis and related therapies – Part 3: Water for haemodialysis and related therapies) | "Testing to demonstrate that the device meets the... standards." (Implicitly, the device did meet them to receive clearance.) |
| Software | Conformance with IEC 62304 Edition 1.1 (Medical device software – Software life cycle processes) | "Software verification within this submission is provided in accordance with IEC 62304..." (Implicitly met requirements). |
| Disinfection Validation| Validation of chemical and heat disinfection labeling in accordance with FDA guidance document "Reprocessing Medical Devices in Health Care Settings: Validation Methods and Labeling Guidance for Industry and Food and Drug Administration Staff" (17 March 2015). (Acceptance: Disinfection processes are effective as labeled.) | "Validation of chemical and heat disinfection labeling..." (Implicitly, the validation was successful). |
| Functional Verification| Complete system testing to verify the performance (e.g., conductivity and temperature) and functional (e.g., operating modes and generated alarms) requirements of the device. (Acceptance: Device operates as per design specifications for various parameters and modes.) | "Complete system testing to verify the performance... and functional... requirements of the device." (Implicitly, the device performed as required.) |
| Packaging | Packaging and transport verification according to ASTM D4169-16. (Acceptance: Packaging adequately protects the device during transport.) | "Packaging and transport verification according to ASTM D4169-16." (Implicitly, the packaging was found adequate.) |
| Biocompatibility | Testing conducted in accordance with ISO 10993-1:2020 and FDA guidance. Endpoints evaluated: Chemical Characterization, Toxicological Risk Assessment, Cytotoxicity, Sensitization, Irritation, Material-Mediated Pyrogenicity, Hemocompatibility. (Acceptance: Materials in contact with dialysis water are biologically safe.) | "Biocompatibility testing was conducted... The following endpoints were evaluated to support the biological safety..." (Implicitly, the testing supported biological safety.) |
| Electrical Safety & EMC| Electrical safety testing in accordance with ANSI/AAMI ES 60601-1:2005. Electromagnetic compatibility (EMC) in accordance with IEC 60601-1-2 Edition 4.0. (Acceptance: Device meets electrical safety and EMC requirements.) | "Electrical safety testing was conducted... EMC was conducted..." (Implicitly, the testing demonstrated compliance.) |
| Software V&V | System software verification testing to demonstrate effectiveness and confirm operation, in accordance with IEC 62304 and various FDA guidance documents on software functions, OTS software, and cybersecurity. (Acceptance: Software performs effectively and reliably, and meets regulatory guidelines for medical device software.) | "System software verification testing was performed to demonstrate the effectiveness of the software and to confirm the operation of the device." (Implicitly, positive results, leading to clearance.) |
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: Not applicable in the context of this device's testing. There is no "test set" of patient data or images as would be seen for an AI diagnostic algorithm. The testing described is hardware and software functional testing, validation against standards, and biocompatibility testing. These are typically performed on a limited number of physical units or material samples.
- Data Provenance: Not applicable. The "data" here refers to test results from engineering and laboratory evaluations, not patient data.
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)
- Not applicable. The ground truth for a water purification system is defined by engineering specifications, international standards (e.g., AAMI/ANSI/ISO), and validated chemical/microbiological testing methods, not by expert medical interpretation of images or patient outcomes.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable. This concept pertains to resolving discrepancies in expert labeling of data for AI/ML models.
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, an MRMC comparative effectiveness study was not done. This type of study is specifically relevant for AI-assisted diagnostic tools that interact with human readers (e.g., radiologists interpreting images). The AquaBplus/AquaB LITE are water purification systems; they do not involve human diagnostic interpretation.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not applicable. This device is not an AI algorithm. Its "performance" is its ability to purify water according to specified parameters and standards, which is assessed through direct measurement and functional testing, not an isolated algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- The "ground truth" for this device's performance is established by:
- International and Federal Standards: ISO 23500 series, AAMI/ANSI. These define the acceptable parameters for water quality for hemodialysis.
- Engineering Specifications: Designed conductivity, temperature, flow rates, and failure modes.
- Validated Test Methods: Biocompatibility tests (e.g., ISO 10993), disinfection validation protocols, electrical safety, and EMC standards.
- Predicate Device Performance: The predicate device serves as a benchmark for substantial equivalence.
8. The sample size for the training set
- Not applicable. There is no "training set" as this device does not use machine learning.
9. How the ground truth for the training set was established
- Not applicable. As there is no training set for an AI/ML model, there is no ground truth established for one.
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(235 days)
Classification Regulations: | 21 CFR § 876.5860 – High permeability hemodialysis system
21 CFR § 876.5665
Regulation
Number | 21 CFR § 876.5860 High Permeability
Hemodialysis System
21 CFR § 876.5665
| 21 CFR § 876.5860 High Permeability
Hemodialysis System
21 CFR § 876.5665
The Tablo® Hemodialysis System and TabloCart™ is indicated for use in patients with acute and/or chronic renal failure, with or without ultration, in an acute or chronic care facility. Treatments must be administered under physician's prescription and observed by a trained individual who is considered competent in the use of the Tablo Hemodialysis System is also indicated for use in the home. Treatment types available include Intermittent Hemodialysis (IHD), Sustained Low Efficiency Dialysis (SLED/ SLEDD), Prolonged Intermittent Renal Replacement Therapy (PIRRT), and Isolated Ultrafiltration.
The Tablo® Hemodialysis System is a self-contained hemodialysis system intended for acute and chronic dialysis therapy, with or without ultrafiltration, in an acute, chronic care facility or in the home. The Tablo Hemodialysis System consists of: Tablo Console and Software, Tablo Cartridge. The TabloCart™ is an optional accessory to the Tablo Hemodialysis System that raises the height of the Tablo console and includes larger wheels that rotate and lock in more functional directions than the Tablo console without a cart, aiding in overall system mobility. When configured with a Prefiltration Drawer, the cart has replaceable, large-capacity cartridge filters (sediment and/or carbon) that serve as "prefilters" to help remove major sediment and chlorine/chloramines from supply water before it enters the Tablo console's water purification system. The cart with prefiltration also includes backflow prevention and a booster pump to transport water from the incoming water supply to the Tablo console. The TabloCart with Prefiltration Drawer consists of: Tablo Cart Wheeled Platform, Fluidics Drawer and Software.
The provided document is an FDA 510(k) Premarket Notification review letter for the Tablo® Hemodialysis System; TabloCart™ with Prefiltration Drawer (K232776). This document primarily focuses on demonstrating substantial equivalence to a predicate device (Tablo Hemodialysis System, K223248) rather than detailing specific acceptance criteria and a study proving the device meets those criteria in the context of device performance metrics (e.g., accuracy, sensitivity, specificity for an AI/algorithm-based device).
The "acceptance criteria" and "study that proves the device meets the acceptance criteria" as requested in the prompt typically refer to a device's performance against predefined metrics (e.g., clinical accuracy, diagnostic performance, or a specific functional output) which are common for AI/algorithm-based devices. However, the Tablo Hemodialysis System and its accessory cart are not an AI/algorithm-based device in the common sense (e.g., for image analysis or disease diagnosis). Instead, it's a medical device for renal replacement therapy, and the 510(k) submission focuses on demonstrating that the new accessory (the cart with prefiltration) does not alter the fundamental safety and effectiveness of the existing, cleared hemodialysis system.
Therefore, many of the specific questions in the prompt (e.g., sample size for test/training sets, number/qualifications of experts, adjudication methods, MRMC studies, standalone performance, type of ground truth) are not applicable to this type of device and submission. The "study" proving acceptance criteria here is primarily a series of bench performance tests, biocompatibility testing, electromagnetic compatibility (EMC) and electrical safety testing, and software verification and validation testing to confirm that the addition of the cart does not negatively impact the established safety and performance of the base hemodialysis system.
Here's an attempt to address the prompt based on the available information, highlighting what is applicable and what is not:
Acceptance Criteria and Study Proving Device Meets Acceptance Criteria for the Tablo® Hemodialysis System with TabloCart™ with Prefiltration Drawer (K232776)
Given that this 510(k) submission is for an accessory cart to an already cleared hemodialysis system, the "acceptance criteria" revolve around demonstrating that the modified device (system with cart) maintains the same safety and effectiveness as the predicate device (system without cart). The "study" is a compilation of various engineering and performance tests rather than a single clinical trial or AI validation study.
1. Table of Acceptance Criteria and Reported Device Performance
For this type of device and submission, the acceptance criteria are largely implied by demonstrating substantial equivalence to the predicate device. They are not typically laid out as quantitative performance metrics (like accuracy or sensitivity) as would be for an AI diagnostic device. Instead, they relate to maintaining fundamental safety, performance, and functionality.
Acceptance Criteria (Implied) | Reported Device Performance (as demonstrated by testing) |
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Maintenance of Predicate Indications for Use | The Tablo® Hemodialysis System and TabloCart retains the same Indications for Use as the predicate Tablo Hemodialysis System (K223248), with the addition of "and TabloCart" to the statement. This indicates that the addition of the cart does not change the medical conditions for which the device is intended. |
Maintenance of Predicate Intended Use | The primary intended use of the Tablo Hemodialysis System (treatment of ESRD patients needing hemodialysis) remains unchanged. The TabloCart has its own specific intended use as an accessory (increased height, improved mobility, additional prefiltration), which complements, rather than alters, the console's existing intended use. |
Biocompatibility | Materials used for the Tablo Hemodialysis System and the TabloCart with Prefiltration Drawer are considered equivalent to the predicate. Biocompatibility evidence was provided in the submission. |
Electromagnetic Compatibility (EMC) and Electrical Safety | No difference in EMC and electrical safety from the predicate device was found. Existing evidence from K223248, which included the Tablo Hemodialysis System and TabloCart with Prefiltration (implying this configuration was already considered in the predicate's testing), was deemed sufficient. No additional testing was needed. |
Software Functionality and Safety | The cart's software functions independently of the console's software. If the cart's software fails, it enters bypass mode without interrupting the console's operation. Software verification and validation (V&V) testing was conducted and passed at the system level (console with cart). The cart's software was assessed as a Minor Level of Concern according to FDA guidance. Cybersecurity risks were evaluated. This demonstrates that the addition of the cart does not introduce new software-related safety- or effectiveness issues. |
Sterilization & Shelf Life (Cleaning, Disinfection) | The TabloCart is a reusable, non-sterile accessory. Cleaning and disinfection methods for the cart are the same as for the predicate Tablo Hemodialysis System and are described in the device labeling. The addition of the cart does not modify the console's existing cleaning/disinfection protocols. |
Bench Performance (Physical/Mechanical Functionality, Water Filtration) | Additional bench testing was conducted to support the accessory TabloCart with Prefiltration, focused on its new functionalities (e.g., mobility, physical dimensions, prefiltration capabilities). While specific metrics are not detailed in the summary, the "performance characterization of the subject device is the predicate Tablo Hemodialysis System" indicating that the core hemodialysis function is maintained, and the cart's new features perform as intended without compromising the primary device. This includes the cart's ability to "help remove major sediment and chlorine/chloramines from supply water" before it enters the console's purification system, implying successful filtration performance. Specific configurations of filters (2S, 2C, SC) are noted, suggesting testing for these variants. |
No New Human Factors Issues | No new Human Factors validation study was deemed necessary. This implies that the usability and user interaction with the system, even with the added cart, are not negatively impacted or present new risks, maintaining consistency with the predicate device's established usability. |
2. Sample size used for the test set and the data provenance:
- Not applicable in the context of typical AI/algorithm test sets. The "test set" here refers to the physical device and its components undergoing engineering and functional verification.
- Data Provenance: The testing was conducted by the manufacturer, Outset Medical, Inc., presumably in their facilities (San Jose, CA, USA). The studies are prospective in the sense that they were designed and executed specifically to support this 510(k) submission for the modified device.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable. This is not an AI/diagnostic device where expert consensus defines a "ground truth" for disease states in a dataset. "Ground truth" for this device is based on engineering specifications, physical measurements, chemical analysis (for water purity), and functional performance verification against design requirements. The "experts" involved would be engineers, quality control personnel, and regulatory specialists within Outset Medical, Inc.
4. Adjudication method for the test set:
- Not applicable. Adjudication methods (like 2+1, 3+1) are for resolving discrepancies in expert interpretations of data (e.g., medical images). For engineering tests, results are typically objective measurements or pass/fail criteria based on predefined specifications.
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 not an AI-assisted diagnostic device, so MRMC studies are irrelevant.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. This device is a physical hemodialysis system with an accessory, not a standalone algorithm.
7. The type of ground truth used:
- Engineering Specifications and Physical/Chemical Standards: For example, the ground truth for water quality would be established by relevant water quality standards for hemodialysis (e.g., AAMI standards). For mechanical aspects, it would be the design specifications (dimensions, mobility, filter capacity). For software, it would be the functional requirements and safety standards.
8. The sample size for the training set:
- Not applicable. This refers to machine learning models, which is not what this device is.
9. How the ground truth for the training set was established:
- Not applicable. See point 8.
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(271 days)
Pennsylvania 18109
Re: K223479
Trade/Device Name: AQUAbase nX, AQUAbase nX HT Regulation Number: 21 CFR 876.5665
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| Classification name: | Water Purification System for Hemodialysis (21 CFR 876.5665
The AQUAbase nX is intended for use with hemodialysis systems to remove organic and inorganic substances and microbial contaminants from the water used for treating hemodialysis patients. The AQUAbase nX is to be used at dialysis clinics or hospitals.
The AQUAbase nX is a reverse osmosis unit intended to be a component in a complete water purification system, and is not a complete water treatment system. This reverse osmosis unit must be preceded by pre-treatment devices. Whether a particular device is included in an individual water treatment system will be dictated by local conditions. The reverse osmosis unit may need to be followed by post-treatment devices as well.
The AQUAbase nX is designed to meet current AAMI/ISO and Federal (U.S.) standards.
The AQUAbase nX is a single stage reverse osmosis system. A graphical touchscreen allows access and monitoring of all operating parameters at any time. Customized parameters make a high water vield possible, even under poor raw water conditions. Raw water consumption is based solely on the end user's permeate needs. The touchscreen makes it possible for the user to monitor all production parameters as well as design every system function, including disinfection mode, individually and reproducibly.
The AQUAbase nX works on the reverse osmosis principle. Reverse osmosis describes the process of pressure-operated cross-filtration. Water flows at high pressure tangentially over a semipermeable membrane. As is the case with normal filtration, the system is cleaned by allowing one component (water) of the mixture to be separated to pass through the membrane with almost no hindrance, while other components (dissolved and undissolved water contents) are held back to a greater or lesser extent and leave the filtration unit in the concentrate flow. This is a purely physical separation process in the molecular range which does not change the components being separated either chemically, biologically or thermally.
The provided document is a 510(k) summary for the AQUAbase nX, a water purification system for hemodialysis. It details the device's characteristics, intended use, and comparison to a predicate device, along with performance data.
However, the information provided does not contain the details required to describe the acceptance criteria and study that proves the device meets the acceptance criteria in the context of an AI-powered medical device.
The document discusses "performance data" which includes:
- Biocompatibility testing (ISO 10993-1)
- Electrical safety and electromagnetic compatibility (EMC) testing (IEC 60601-1, IEC 60601-1-2)
- Software verification and validation testing (FDA Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices" as well as the draft FDA guidance recently issued)
- Additional performance bench testing (ISO 23500-3 for performance, chemical and heat disinfection testing, bacterial count and endotoxins)
These are standard engineering and medical device performance tests. There is no mention of an AI algorithm, a test set for AI, ground truth establishment by experts, MRMC studies, or standalone AI performance.
Therefore, I cannot fulfill the request as the provided text does not contain any information about an AI component or a study proving an AI device meets acceptance criteria. The device described is a physical water purification system, not an AI-powered diagnostic or assistive tool.
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(65 days)
01876
Re: K231410
Trade/Device Name: RenaPure Endotoxin Retentive Filter Regulation Number: 21 CFR 876.5665
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| Classification Name | Water purification system for hemodialysis, 21 CFR 876.5665
The RenaPure filter is a bacterial and endotoxin retentive filter intended for use in a centralized loop as the final step of a water purification cascade to provide standard dialysis water to machine servicing multiple patients. This filter is not intended to service as the sole means of water purification and therefore must be used in conjunction with other water treatment equipment.
The RenaPure filter is a 20" cartridge style filter in a polypropylene casing that contains dual-layered, 0.22 micron polyethersulfone (PES) pleated membranes which are separated by polypropylene screen layers. The PES membrane is charge modified with a positive charge coating, similar to the predicate device, that aids in removal of endotoxin by charge attraction. Filter configurations are based on an industry standard 222 header design with silicone O-rings at the open end of the filter and flat or fin end caps at the closed end. The filter cartridge is installed in a durable filter housing and operates in a dead-end mode. The filter is designed to remove bacteria and endotoxin from water used in hemodialysis with similar water flow characteristics as the predicate device. The filter provided non-sterile.
The provided text describes the regulatory clearance of the RenaPure Endotoxin Retentive Filter and includes a summary of non-clinical performance assessment, but it does not contain information about:
- Acceptance criteria expressed as specific quantitative thresholds for device performance.
- A comparative study with human readers (MRMC study) or effect sizes of AI assistance.
- Standalone algorithm performance.
- Sample sizes for test sets or training sets in the context of an AI/algorithm study.
- Data provenance, number of experts for ground truth, or adjudication methods for an AI/algorithm study.
- Ground truth type for training data.
The document focuses on the physical and functional performance of a medical device (a filter) through bench testing and biocompatibility assessment, not on the performance of a diagnostic AI algorithm.
Therefore, I cannot fulfill your request as the necessary information regarding acceptance criteria, study details, and AI performance metrics (including expert involvement, sample sizes, and ground truth establishment) is not present in the provided text.
The "Performance (bench) testing" section within the "Non-clinical Performance Assessment" is the closest to describing a study, but it lacks the specific details requested concerning acceptance criteria, ground truth, and expert involvement usually associated with AI algorithm evaluation.
What the document does state about performance assessment:
- Study type: Non-clinical bench testing.
- Tests performed:
- Flow/Pressure Drop measurements
- Endotoxin Retention
- Bacterial Retention
- Compatibility to Hot Water and Chemical Disinfections
- Housing Fit tests
- Compatibility with Deionized water
- Results: "Testing demonstrated that the RenaPure filter met the intended design requirements and will operate as a drop-in replacement to the predicate device."
- Biocompatibility: A series of biocompatibility tests, including exhaustive extraction and toxicological risk assessment, were performed. "All biocompatibility testing passed and the risk of any toxic leachates from the RenaPure filter were considered negligible."
- Ground Truth: For these physical device tests, the "ground truth" would be established by the physical measurements and chemical analyses themselves, validated against engineering specifications and regulatory standards. There are no "experts" in the sense of clinical readers establishing ground truth for perception tasks.
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(267 days)
Name: i3 ONE (203100-S); i3 TWO connect (203200-S); i3 TWO direct (203300-S) Regulation Number: 21 CFR 876.5665
The intended use of the i3 Membrane Water Filters i3 ONE, i3 TWO connect, i3 TWO direct is to filter EPA quality drinking water. The i3 Membrane Water Filters retain bacteria, which may aid in infection control. The filters produce water that is appropriate for washing and drinking, superficial wound cleansing (minor cuts, scrapes and abrasions), cleaning of equipment used in medical procedures and washing of surgeon's hands. The i3 Membrane Water Filters are not intended to provide water that can be used as a substitute for USP grade sterile water.
The i3 Point-of-Use Water Filters are supplied sterile and 100% integrity tested. The membrane within the filter cartridge is rated and validated at 0.2 µm to remove bacteria and particles in the water supply. This membrane reduces bacteria with more than 7 log levels per square centimeter filtration area. This represents the bacterial retention, the core element of infection prevention. Furthermore, a bacteriostatic additive is present in the outer housings parts of the filter, which prevents retrograde contamination of the filter. In addition, the inlet of the tap water filter is inclined to prevent the water from hitting the siphon. This also prevents retrograde contamination from the siphon, which would be caused by rising aerosols from the direct impact of the water jet. The Water Filters are designed to be used for a maximum of 50 days following initial connection. Suspending use does not extend filter life. The i3 ONE / i3 TWO connect / i3 TWO direct Water Filters are intended to be used within the healthcare environment such as hospitals, nursing homes, health care facilities or clinical settings where immunecompromised patients may be exposed to waterborne microorganisms originating from the water supply. The i3 Membrane Water Filters are disposable and designed for the use on tap or the shower.
Here's a breakdown of the acceptance criteria and study information based on the provided text, focusing on the absence of information related to AI/ML devices as the text concerns water filters:
This document describes a medical device submission for water filters (i3 ONE, i3 TWO connect, i3 TWO direct), not an AI/ML device. Therefore, many of the requested categories related to AI/ML performance, such as test sets, ground truth establishment, expert adjudication, MRMC studies, standalone algorithm performance, and training set information, are not applicable and are absent from the provided text.
1. A table of acceptance criteria and the reported device performance
Since this is not an AI/ML device, the "acceptance criteria" are generally related to the physical, chemical, and microbiological performance of the water filters. The document describes several performance tests against established standards and criteria, rather than specific numerical "acceptance criteria" in a table format. However, the reported performance is presented in relation to the requirements for such devices.
Acceptance Criterion (Inferred from testing) | Reported Device Performance and Related Information |
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Microbial Retention: | |
Bacterial retention of membrane filters | - Examined following ASTM F 838 - 15a. |
- Showed very good retention performances with reductions of bacterial count of more than 10^7 colony-forming units (CFU)/cm² filter area.
- All filters passed integrity test prior to and after bacterial retention test.
- (Filter Retention in comparison table): > 10^7 CFU/cm²; > 10^10 CFU/device (matching predicate). |
| Bacteriostatic Additive Efficacy: | |
| Prevention of retrograde contamination | - Reduces retrograde contamination by more than 99.5% for Pseudomonas aeruginosa even after 8 weeks of use. - Achieved 99.5% protection against retrograde contamination for Escherichia coli, Klebsiella pneumoniae, Proteus mirabilis, Acinetobacter baumannii, and Staphylococcus aureus. |
| Silver Migration: | |
| Acceptable levels of silver ion migration | - Silver-based ions found to be more than 10 times less according to the suggestion of the Environmental Protection Agency. |
| Maximum Operating Temperature & Pressure: | |
| Withstand thermal disinfection | - Tested at up to 5 bar and up to 70°C (for 30 minutes continuous period). - Filters passed integrity tests after these conditions. |
| Flow Rate: | |
| Guaranteed function at various pressures | - Tested at 1, 2, 3, 4, and 5 bar (approx. 15, 30, 45, 60, and 75 PSI) static water pressure. - Intended use guaranteed at each of these pressures. |
| Sterilization: | |
| Sterility and shelf life | - Available sterile with a shelf life of 50 days. - Bioburden and sterilization validation assessed and conducted successfully.
- Sterilization dose of 25 kGy for SAL 10^-6 substantiated. |
| Shelf Life: | |
| Maintenance of integrity and sterility over time | - Tested by a 5-year accelerated test. - 5-year real-time aging test started in 2019.
- Packaging passed peel, dye, and bubble tests.
- Filter confirmed sterile after a 5-year life.
- Further integrity tests of the filter carried out. |
| Biocompatibility: | |
| Compatibility with biological systems | - Biocompatibility review performed for all three filter types using ISO 10993-1 and subsequent ISO 10993 series standards. - Concluded that the products are biocompatible. |
| Additional Tests (Passed product specifications): | |
| Mechanical integrity and chemical resistance | - Burst Pressure Testing - Durability Testing
- Transport Testing
- Drop Testing
- Chlorine Testing for chemical disinfection
- Wipe Disinfection Testing |
| Risk Management: | |
| Acceptable risk profile | - Hazards assessed under ISO 14971. - No risk deemed unacceptable; overall risk profile low (risks mitigated under design control and ASTM testing). |
The following questions are not applicable to the submitted device (water filter) as it is not an AI/ML product. The document does not contain information on these aspects.
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Sample size used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective)
- This is not an AI/ML device. The "test set" refers to the tested filter samples, but specific sample sizes for each test are not detailed in the summary. The tests are non-clinical performance and lab-based.
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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 an AI/ML device. Ground truth for the performance of a physical device like a water filter is established through standardized laboratory testing (e.g., CFU counts, integrity tests, material analysis) rather than expert consensus on medical images or patient data.
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Adjudication method (e.g., 2+1, 3+1, none) for the test set
- Not an AI/ML device. Adjudication methods are relevant for ambiguous cases in human interpretation, which is not applicable here.
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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 an AI/ML device. MRMC studies are for evaluating diagnostic performance with human readers, typically in imaging.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not an AI/ML device. This refers to algorithm-only performance, which isn't applicable.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
- For this device, "ground truth" is based on the results of standardized physico-chemical and microbiological laboratory tests (e.g., bacterial count reduction as per ASTM F 838 - 15a, material analysis for silver migration, physical stress tests).
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The sample size for the training set
- Not an AI/ML device. There is no training set mentioned or applicable.
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How the ground truth for the training set was established
- Not an AI/ML device. Not applicable.
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(69 days)
Trade/Device Name: AmeriWater MediQA Reverse Osmosis System (MSP3HF) Regulation Number: 21 CFR 876.5665
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| Classification: | Class II Medical Device under §876.5665
The AmeriWater MediQA Reverse Osmosis System is one component of a water treatment system designed to pre-treat and purify potable water using reverse osmosis for making dialysate for hemodialysis applications. The device is intended to be a component in a complete water purification system, and is not a complete water treatment system. It must be preceded by pretreatment devices, and may need to be followed by post-treatment devices as well to meet current AAMI and Federal (U.S.) standards. The AmeriWater MediQA is intended for use in water rooms in a hospital, clinic, or dialysis center. The device includes an integrated heat sanitization process.
This Special 510(K) submission is for the addition of a new model to the AmeriWater MediQA Reverse Osmosis System product line originally cleared for market under 510(k) number K131904. The new model. MSP3HF is complementary to the rest of the product line and is not intended to replace or enhance features of any existing model.
The MSP3HF is a single pass reverse osmosis (RO) that uses pretreated soft water to produce water for hemodialysis applications. The system is capable of producing dialysis quality water at a flow rate up to 16.0 gallons per minute (gpm). The new model, like the predicate device, includes heat sanitization capabilities for the reverse osmosis system.
Model MSP3HF, is identical in design to the existing model MSP3 (K131904) with the exception of the RO pump. While model MSP3 includes a pump with a 20-stage impeller, the new model MSP3HF includes a pump with a 24-stage impeller (currently used on model MDP4). The increase in impeller stages results in the pump forcing more water through the existing membrane elements per unit time. Both the 20-stage pump and the 24-stage pump include the same pump motor. The increase in flow rate does not exceed the operating parameters of the membrane elements per the membrane manufacturer's specifications, and operating pressures remain the same as the predicate device. The increased flow rate does not change the product water quality (level of impurities), and the product water continues to meet all current AAMI/ISO and Federal requirements as confirmed by verification and validation testing. There are no changes to the software used in the device or to the water contacting materials. All software and materials used in the new model are identical to the predicate device.
The new model does not result in any changes to the heat sanitization process. The temperatures, contact times, and operating pressures remain the same as the predicate device. During the heat sanitization process, the heated water is recirculated through the MediQA system for the duration of the contact time. The flow path, operating pressure, water temperature, and contact time are identical between the predicate device and the new device during heat sanitization. There are no new issues regarding safety or effectiveness of the heat sanitization process.
The scientific concept for the operation of the AmeriWater MEDIQA Reverse Osmosis System is the principle of reverse osmosis. The MEDIQA system uses a pump (RO pump) to apply the pressure required for reverse osmosis. Pretreated soft water enters the MEDIQA through an inlet solenoid valve, filling the feed water tank. The RO pump forces water from the feed tank through the RO membrane elements. The water entering the RO membrane element exits the membrane element in two flow streams. The water forced through the RO membrane element is known as permeate water. It is purified water that meets all current AAMI/ISO and Federal requirements for water used in hemodialysis applications. The water rejected by the membrane contains an increased level of dissolved contaminants. It passes out of the RO module as the second flow stream called concentrate, and is sent to drain.
The built in heat sanitization feature provides heat sanitization of the reverse osmosis membranes and the MEDIQA system's pipe work. Heat sanitization can be activated manually using the HEATSAN buttons on the touch screen display or automatically if timer clock settings are implemented. The frequency of heat sanitization will depend upon usage and application demands. Monitoring of the system for bacterial content is required at regular intervals to determine the optimum frequency for heat sanitization.
This document describes the regulatory submission for the AmeriWater MediQA Reverse Osmosis System, Model MSP3HF. It is a Special 510(k) submission for the addition of a new model to an existing product line (K131904). The new model, MSP3HF, is largely identical to the predicate device, Model MSP3, with the primary difference being an upgrade to the RO pump to achieve a higher flow rate.
Here's an analysis of the acceptance criteria and supporting study details:
1. Table of Acceptance Criteria and Reported Device Performance
The submission doesn't explicitly list "acceptance criteria" in a tabulated format with pass/fail results for the new model MSP3HF in the same way one might expect for a novel device. Instead, it demonstrates substantial equivalence to a predicate device (MSP3) by showing that the new model meets the same performance standards and that the design change (pump upgrade) does not negatively impact safety or effectiveness. The implicit acceptance criteria are that the device continues to meet the requirements of relevant standards and functions as intended.
Acceptance Criteria (Implicit) | Reported Device Performance (MSP3HF) |
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Product Water Quality: Meets AAMI and Federal (U.S.) standards for water used in hemodialysis. | Verified to produce water that meets ANSI/AAMI/ISO 23500-1:2019 requirements for dialysis water. |
RO Contaminant Rejection Rate: | >94% (Identical to predicate) |
Permeate Flow Rate: | Up to 16.0 gpm (+20%) (Increased from predicate's 12.0 gpm + 20%, but remains within membrane operating parameters). |
Heat Sanitization Efficacy: Effective in reducing bacteria. | Verification that there is no change to the heat sanitization cycle temperature (185°F) or contact time (30 minutes). The effectiveness of the original parameters was validated for the predicate device. Microbiological testing results for the predicate showed effectiveness in bacterial reduction. |
Operating Pressures: Within safe operating range. | Actual Operating PSI: 165 psi (Identical to predicate and within the membrane's max operating pressure of 600 psi). |
Electrical Safety: Conforms to relevant electrical safety standards. | ETL listing report number 100988725LAX-001 (revised 25-Oct-2022) confirms compliance with UL 6010-1, UL 61010-2-010, CSA C22.2#61010-1-12, and CSA C22.2#61010-2-010. (Identical to predicate) |
EMC Performance: Meets EMC standards. | No new EMC testing conducted. The predicate device met BS EN 61326:1998/IEC 61326-1:1997, BS EN 61000-3-2:1995. Design changes do not introduce new EMC-related risks. (Identical to predicate) |
Software Functionality: | No changes to device software; identical to predicate. |
Biocompatibility: Water contacting materials are safe. | Water contacting materials are identical to the predicate device. No new biocompatibility testing was conducted. |
2. Sample size used for the test set and the data provenance
The document does not specify a "test set" in the context of individual patient data or a specific number of devices tested for the new model MSP3HF.
- For the original predicate device (K131904): Non-clinical testing was conducted to verify and validate performance. The details of samples used for these initial tests are not provided in this summary.
- For the new model (MSP3HF): Verification and validation testing was conducted. This included "complete system testing" where the device's performance was observed under various conditions. The sample size for this testing is implicitly "one device" (the MSP3HF model) or a representative number of units for its functional verification. The data provenance is internal testing by AmeriWater, LLC.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This information is not applicable as this is a medical device (water purification system), not an AI/imaging device requiring expert interpretation for ground truth. Technical performance against established industry standards is the primary assessment.
4. Adjudication method for the test set
This information is not applicable for the same reason as point 3.
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 as this is a medical device (water purification system), not an AI/imaging device.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This information is not applicable as this is a physical medical device, not a software algorithm. The device operates autonomously to purify water.
7. The type of ground truth used
The "ground truth" for this device's performance is established by its ability to meet the specified performance parameters outlined in ANSI/AAMI/ISO 23500-1:2019 (for water quality) and ANSI AAMI ISO 23500-2:2019 and ANSI AAMI ISO 23500-3:2019 (for equipment and water standards for hemodialysis). Additionally, microbiological testing for the predicate device proved the effectiveness of the heat sanitization function.
8. The sample size for the training set
This information is not applicable as this is a physical medical device, not an AI/machine learning model that requires a training set.
9. How the ground truth for the training set was established
This information is not applicable for the same reason as point 8.
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