(28 days)
To locate, illuminate within, and transilluminate across nasal and sinus structures in patients aged 18 and over.
The PathAssist Light Fiber is a flexible instrument that can be connected to a light source to emit light from its distal end. It has a fiber nominal working length of 27.6cm with an outer diameter of 0.5mm (0.020"). The device consists of a flexible illumination fiber, a protective sheath and a light post, with an overall device length of 117cm. The Light Fiber is provided sterile and is for single use only. The Light Fiber is packaged with a commercially available male tuohy borst adapter and a sinus cannula.
This is a submission for a 510(k) premarket notification for a medical device called the "PathAssist™ Light Fiber™." As such, the documentation provided does not contain information about a study designed to prove the device meets acceptance criteria in the manner you've outlined for an AI/algorithm-based device.
The PathAssist™ Light Fiber™ is a manual surgical instrument, specifically a sinus guidewire. Its regulatory pathway relies on demonstrating substantial equivalence to a predicate device rather than undergoing extensive clinical trials with performance metrics like sensitivity, specificity, etc., typically associated with AI/ML diagnostic tools.
However, I can extract the relevant information available within the provided text to answer your questions where possible, and explicitly state when the requested information is not applicable or not provided.
Here's a breakdown based on the provided document:
Acceptance Criteria and Device Performance (Not applicable in the AI/ML sense)
For this device, "acceptance criteria" are related to demonstrating that the device meets its design specifications and performs its intended function safely and effectively, primarily through engineering and functional testing, and by establishing substantial equivalence to a predicate device.
1. A table of acceptance criteria and the reported device performance
| Acceptance Criteria (Implied) | Reported Device Performance |
|---|---|
| Functional Compatibility: Compatibility with LED light sources | "Design verification testing included functional testing to support compatibility of the Light Fiber with LED light sources." |
| Design Specifications: Meeting intended design parameters | "Performance testing demonstrated that the subject device meets design specifications and performs as intended." |
| Safety and Effectiveness: Performance as intended | "Performance testing has demonstrated that the device is safe and effective and that its performance is substantially equivalent to the predicate device." |
| Substantial Equivalence: To predicate device [K111763] | "The Light Fiber has the same indications for use and fundamental scientific technology as the predicate device. The Light Fiber is substantially equivalent to the predicate device." |
| Sterility: Provided sterile and for single use | "The Light Fiber is provided sterile and is for single use only." |
2. Sample size used for the test set and the data provenance
- Sample size: Not specified. The testing described is "design verification testing" and "functional testing," which typically involves engineering samples rather than patient data sets characteristic of AI/ML studies.
- Data provenance: Not applicable in the context of patient data. The provenance would be the internal testing facilities of Entellus Medical, Inc.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Not applicable. This device is a physical instrument, not an AI/ML algorithm requiring expert opinion for ground truth. "Ground truth" for this device would be established by engineering specifications and physical measurements.
4. Adjudication method for the test set
- Not applicable. There is no mention of expert adjudication as this is not an AI/ML diagnostic device study.
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. This is not an AI-assisted device. The document states that "animal and clinical data were not submitted."
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not applicable. This device is a manual surgical instrument; it is not an algorithm and does not operate standalone.
7. The type of ground truth used
- Type of Ground Truth: Design specifications, functional requirements, and physical characteristics. For example, testing light emission, flexibility, and dimensions against pre-defined specifications.
8. The sample size for the training set
- Not applicable. This device does not use an AI/ML algorithm that requires a training set.
9. How the ground truth for the training set was established
- Not applicable. Does not apply to this type of device.
Summary of the Study (as described in the document):
The "study" or "performance data" provided for the PathAssist™ Light Fiber™ consisted solely of design verification testing. This testing included:
- Functional testing: Specifically to support the compatibility of the Light Fiber with LED light sources.
- Confirmation that the device meets its design specifications.
- Verification that the device performs as intended.
The document explicitly states that sterilization, shelf life, packaging testing, biocompatibility, animal, and clinical data were NOT submitted. The conclusion drawn from this performance data was that the device is safe and effective and is substantially equivalent to its predicate device [K111763]. This aligns with the regulatory requirements for Class I devices and the 510(k) pathway, which primarily focuses on demonstrating substantial equivalence.
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K/20962
APR 2 7 2012
Image /page/0/Picture/3 description: The image shows the logo for "entellus MEDICAL". The logo consists of a circular design on the left, made up of several curved lines that create a swirling effect. To the right of the circular design is the word "entellus" in a simple, sans-serif font. Below "entellus" is the word "MEDICAL" in smaller, capitalized letters with a trademark symbol.
510(k) Summary
Date Prepared: Submitter Information:
Establishment Registration:
Contact Information:
March 29, 2012 Entellus Medical, Inc. 6705 Wedgwood Court, North Maple Grove, MN 55311
3006345872
Garrett P. Ahlborg Regulatory Affairs Specialist (763) 463-7074 gahlborg@entellusmedical.com
ENT Manual Surgical Instrument
PathAssist™ Light Fiber™
Class I, 21 CFR 874.4420
Sinus Guidewire
Device Information: Trade Name: Common Name: Classification Name: Product Code: Regulation Number:
Predicate Device: PathAssist™ Light Fiber™ [K111763]
Device Description:
The PathAssist Light Fiber is a flexible instrument that can be connected to a light source to emit light from its distal end. It has a fiber nominal working length of 27.6cm with an outer diameter of 0.5mm (0.020"). The device consists of a flexible illumination fiber, a protective sheath and a light post, with an overall device length of 117cm. The Light Fiber is provided sterile and is for single use only.
LRC
Image /page/0/Figure/15 description: The image shows a diagram of a light fiber. The diagram labels the different parts of the light fiber, including the light post, strain relief, flexible sheath, and fiber. The light fiber is shown as a long, thin tube with a loop in the middle.
PathAssist Light Fiber
The Light Fiber is packaged with a commercially available male tuohy borst adapter and a sinus cannula.
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Indications for Use:
To locate, illuminate within, and transilluminate across nasal and sinus structures in patients aged 18 and over.
Contraindications:
None
Technological Characteristics:
The Light Fiber has the same indications for use and fundamental scientific technology as the predicate device [K111763]. The subject device has the same technological characteristics (i.e., principle of operation, design, function, materials, biocompatibility and sterility) as the predicate device.
Substantial Equivalence:
The Light Fiber has the same indications for use and fundamental scientific technology as the predicate device. The Light Fiber is substantially equivalent to the predicate device.
Performance Data:
Performance testing of the Light Fiber consisted of design verification testing. Design verification testing included functional testing to support compatibility of the Light Fiber with LED light sources. Sterilization, shelf life, packaging testing, biocompatibility, animal and clinical data were not submitted. Performance testing demonstrated that the subject device meets design specifications and performs as intended.
Conclusion:
In conclusion, the indications for use and technological characteristics are the same as or equivalent to the predicate device. Performance testing has demonstrated that the device is safe and effective and that its performance is substantially equivalent to the predicate device.
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Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle with three tail feathers, representing the department's commitment to health, human services, and well-being. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" are arranged in a circular pattern around the eagle.
Food and Drug Administration 10903 New Hampshire Avenue Document Mail Center - WO66-G609 Silver Spring, MD 20993-0002
APR 2 7 2012
Entellus Medical, Inc. % Garrett P. Ahlborg 6705 Wedgwood Court North Maple Grove, MN 55311
Re: K120962
Trade/Device Name: PathAssist TM Light FiberTM Regulation Number: 21 CFR 874.4420 Regulation Name: ENT Manual Surgical Instrument Regulatory Class: Class I Product Code: LRC Dated: March 29, 2012 Received: March 30. 2012
Dear Mr. Ahlborg:
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 indications for use stated in the enclosure) to legally marketed predicate devices marketed in 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. Ilsting of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to 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); medical device reporting (reporting of medical devicerelated adverse events) (21 CFR 803); 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 1000-1050.
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If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, []Misbranding by reference to premarket notification (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
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 (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely yours,
R. Hampt
Malvina B. Eydelman, M.D. Director Division of Ophthalmic, Neurological, and Ear, Nose, Throat Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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6. Indications for Use Statement
510(k) Number (if known):
Device Name:
PathAssist™ Light Fiber™
Indications for Use
To locate, illuminate within, and transilluminate across nasal and sinus structures in patients aged 18 and over.
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH Office of Device Evaluation (ODE)
| Prescription Use | X |
|---|---|
| OR/AND | Over-the-Counter Use |
(Division Sign-Off)
Division of Ophthalmic Neurological and Ear,
Nose and Throat Devices
K120962 510(k) Number.
§ 874.4420 Ear, nose, and throat manual surgical instrument.
(a)
Identification. An ear, nose, and throat manual surgical instrument is one of a variety of devices intended for use in surgical procedures to examine or treat the bronchus, esophagus, trachea, larynx, pharynx, nasal and paranasal sinus, or ear. This generic type of device includes the esophageal dilator; tracheal bistour (a long, narrow surgical knife); tracheal dilator; tracheal hook; laryngeal injection set; laryngeal knife; laryngeal saw; laryngeal trocar; laryngectomy tube; adenoid curette; adenotome; metal tongue depressor; mouth gag; oral screw; salpingeal curette; tonsillectome; tonsil guillotine; tonsil screw; tonsil snare; tonsil suction tube; tonsil suturing hook; antom reforator; ethmoid curette; frontal sinus-rasp; nasal curette; nasal rasp; nasal rongeur; nasal saw; nasal scissors; nasal snare; sinus irrigator; sinus trephine; ear curette; ear excavator; ear rasp; ear scissor, ear snare; ear spoon; ear suction tube; malleous ripper; mastoid gauge; microsurgical ear chisel; myringotomy tube inserter; ossici holding clamp; sacculotomy tack inserter; vein press; wire ear loop; microrule; mirror; mobilizer; ear, nose, and throat punch; ear, nose and throat knife; and ear, nose, and throat trocar.(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 § 874.9.