(49 days)
Nasopore® Ear is a fragmentable ear packing and is indicated for use in patients, undergoing outer ear surgery, as a space occupying stent to separate and prevent adhesions between mucosal surfaces; to help control minimal bleeding, following ear surgery, by tamponade effect and blood absorption.
Nasopore® Ear is composed of a bioresorbable poly(DL-lactide-co-sscription caprolactone) urethane that fragments within several days after insertion in the outer ear, whereafter it is drained from the cavity. The type of Nasopore® Ear is indicated on the label. Nasopore® Ear is packed in a blister closed by a medical paper lid. Nasopore® Ear is indicated for single-use.
The provided text describes the 510(k) summary for the Nasopore® Ear device, focusing on its substantial equivalence to predicate devices rather than a standalone performance study with specific acceptance criteria and detailed device performance metrics.
Therefore, many of the requested details about acceptance criteria, a specific study proving it, sample sizes, expert involvement, and ground truth establishment are not available in the provided document. The submission relies on demonstrating substantial equivalence based on the device's material composition and intended use being similar to existing cleared devices, rather than an independent performance study with defined acceptance criteria.
Here's a breakdown of what can be gleaned from the text, and what information is missing:
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria | Reported Device Performance |
|---|---|
| Not explicitly stated as numerical criteria for this device | The safety and effectiveness of the Nasopore® were demonstrated via Performance Data: data collected from design verification tests and analyses. |
| In vitro degradation testing | |
| Shelf life testing | |
| Substantial equivalence to predicate devices in terms of physical characteristics and intended use. |
Explanation: The document does not set numerical acceptance criteria for the Nasopore® Ear device's performance in a clinical study. Instead, it relies on demonstrating substantial equivalence to predicate devices (Invotec Ear Tampon (Wick) w/String and Nasopore® Nasal Dressing). The "performance data" mentioned refers to design verification tests (in vitro degradation and shelf life), which are engineering tests, not clinical performance metrics against specific acceptance criteria.
2. Sample size used for the test set and the data provenance
- Sample Size: Not applicable/Not mentioned. The document does not describe a clinical test set with human or animal subjects for performance evaluation against specific criteria.
- Data Provenance: Not applicable/Not mentioned for a clinical test set. The "performance data" mentioned (in vitro degradation, shelf life testing) would typically be conducted in a lab setting.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Number of Experts: Not applicable/Not mentioned. No test set requiring expert ground truth is described.
- Qualifications of Experts: Not applicable/Not mentioned.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Adjudication Method: Not applicable/Not mentioned. No clinical test set requiring adjudication is described.
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
- MRMC Study: No. This is not an AI-assisted device. The Nasopore® Ear is a physical medical device.
- Effect Size of AI Improvement: Not applicable.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Standalone Performance: Not applicable. This is a physical medical device, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- Type of Ground Truth: Not applicable for a typical clinical performance study. The "ground truth" for the claims in this submission is the established safety and effectiveness of the predicate devices and the physical/chemical properties verified by design tests.
8. The sample size for the training set
- Sample Size for Training Set: Not applicable/Not mentioned. This is not an AI device that requires a training set.
9. How the ground truth for the training set was established
- Ground Truth for Training Set: Not applicable.
In summary, the 510(k) submission for Nasopore® Ear relies on a demonstration of "substantial equivalence" to legally marketed predicate devices, rather than a de novo clinical performance study with explicit acceptance criteria. The performance data mentioned (in vitro degradation, shelf life) are design verification tests, not clinical performance metrics. The underlying rationale is that if the new device is made of the same material, uses the same manufacturing process, and is intended for a similar use as a previously cleared device, then its safety and effectiveness are considered substantially equivalent.
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Image /page/0/Picture/2 description: The image shows the words "bioresorbable solution" on the top line, followed by the word "POLYGANICS" on the second line. The third line shows the number "K062540". The text is black and the background is white.
510(k) Summary of Safety and Effectiveness
| Submitter: | Polyganics BVL.J. Zielstraweg 19713 GX, GroningenThe Netherlandswww.polyganics.com | OCT 18 2006 |
|---|---|---|
| Contact Person: | Jan NieuwenhuisManaging DirectorTel : +31 50 588 6588Fax : +31 50 588 6599Mobile: +31 653 211 303E-mail : jan.nieuwenhuis@polyganics.com | |
| Date Prepared: | August 18th, 2006 | |
| General Provisions: | Trade Name: Nasopore®Common Name: Ear WickClassification Name: Ear Wick, 21 CFR 874.5220Device Classification: Class I non exempt. | |
| Predicate Devices: | - Invotec Ear Tampon (Wick) w/String; Invotec Internat.; K973578- Nasopore® nasal dressing, Polyganics, K052099 | |
| Performance Standards | For the Nasopore® performance, the FDA, under section 514 of the Food, Drug and Cosmetic Act, has not established standards. | |
| Indications for Use | Nasopore® Ear is a fragmentable ear packing and is indicated for use in pa-tients, undergoing outer ear surgery, as a space occupying stent to separate and prevent adhesions between mucosal surfaces; to help control minimal bleeding, following ear surgery, by tamponade effect and blood absorption. |
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Image /page/1/Picture/2 description: The image shows the words "bioresorbable solution" underlined, followed by the word "POLYGANICS" in large, bold letters. Below that is the number "K062540" in a handwritten style. The text appears to be part of a label or document, possibly related to a medical or scientific product.
- Device De-Nasopore® Ear is composed of a bioresorbable poly(DL-lactide-co-sscription caprolactone) urethane that fragments within several days after insertion in the outer ear, whereafter it is drained from the cavity.
The type of Nasopore® Ear is indicated on the label. Nasopore® Ear is packed in a blister closed by a medical paper lid. Nasopore® Ear is indicated for single-use.
The safety and effectiveness of the Nasopore® have been demonstrated via Performance Data: data collected from design verification tests and analyses. The design verification testing consisted of the following:
- In vitro degradation testing -
- Shelf life testing -
The intended use of Nasopore Ear is substantially equivalent to those fea-Summary of Substantial tured with the competitor device Invotec Ear Tampon (Wick) w/String (ref. Equivalence 510(k)973578). The safety (biocompatibility) and efficacv of Nasopore® Ear is demonstrated by its substantial equivalent Nasopore® Nasal dressing (ref. 510(k)052099; Polyganics BV).
Polyganics BV already markets Nasopore® Nasal Dressing. The subject device, Nasopore® Ear, is made from the same material as Nasopore® Nasal Dressing. The subject device is substantially equivalent to Nasopore® Nasal Dressing with respect to physical characteristics and with regard to the intended use of the device, i.e. a space occupying stent to separate and prevent adhesions between mucosal surfaces and help control minimal bleeding following surgery, by tamponade effect and blood absorption, Nasopore® Nasal dressing in the nasal/sinus cavities and Nasopore® Ear in the outer ear. The predicate device Nasopore® Nasal Dressing is made of a fragmentable poly(DL-lactide-co-s-caprolactone) urethane and the identical manufacturing process is used to produce the foam. The subject and predicate device are made of poly(DL-lactide-co-s-caprolactone) urethanen, which has demonstrated to be satisfactory biocompatible.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/2/Picture/1 description: The image is a black and white logo for the U.S. Department of Health & Human Services. The logo features a stylized image of an eagle with its wings spread, and the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" are arranged in a circle around the eagle. The eagle is composed of three curved lines that form the shape of the bird's body and wings. The text is in all capital letters and is evenly spaced around the circle.
Public Health Service
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
Polyganics BV c/o Jan Nieuwenhuis L.J. Zielstraweg 1 9713 GX, Groningen The Netherlands
Re: K062540
Trade/Device Name: Nasopore® Ear Regulation Number: 21 CFR 874.5220 Regulation Name: ENT Synthetic Polymer Material Regulatory Class: Class I Product Code: KCN Dated: August 21, 2006 Received: August 30, 2006
Dear Mr. Nieuwenhuis:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indicetions for use stated in the enclosure) to legally marketed predicate devices market the interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA), You may, therefore, market the device, subject to the general controls provisions of the Act The general controls provisions of the Act include requirements for annual registration, inc not. devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.
OCT 1 8 2006
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 100-1050.
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Page 2 - Mr. Jan Nieuwenhuis
This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Office of Compliance at (240) 276-0115. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely yours.
M.B. Eggleton, M.D.
Malvina B. Eydelman, M.D. Director Division of Ophthalmic and Ear, Nose and Throat Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Nasopore® Ear
bioresorbable solution
POLYGANICS
Indications for Use Form
3 143 11 15
510(k) Number:
Device Name:
Nasopore® Ear
Indications for Use:
Nasopore® Ear is a fragmentable ear packing and is indicated for use in patients, undergoing ear surgery, as a space occupying stent to separate and prevent adhesions between mucosal surfaces, to help control minimal bleeding, following ear surgery, by tamponade effect and blood absorption.
(FLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Prescription Use x (Per 21 CFR 801.109)
Over-The-Counter Use
(Optional Format 1-2-96)
(Division Sign-Off)
OR
510(k) Number _
Seimus Marden
(Division Sign-Off) Division of Ophthalmic Ea Nose and Throat Devi
510(k) Number
x Prescription Use (Per 21 CFR 801.109)
18 August 2006
Page 8 of 45
§ 874.5220 Ear, nose, and throat drug administration device.
(a)
Identification. An ear, nose, and throat drug administration device is one of a group of ear, nose, and throat devices intended specifically to administer medicinal substances to treat ear, nose, and throat disorders. These instruments include the powder blower, dropper, ear wick, manual nebulizer pump, and nasal inhaler.(b)
Classification. Class I (general controls). The device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 874.9. If the device is not labeled or otherwise represented as sterile, it is exempt from the current good manufacturing practice requirements of the quality system regulation in part 820 of this chapter, with the exception of § 820.180, with respect to general requirements concerning records, and § 820.198, with respect to complaint files.