(154 days)
The Miromatrix Biological Mesh TW is indicated for the management and protection of tendon injuries in which there has been no substantial loss of tendon tissue.
The Miromatrix Biological Mesh TW is an implantable, animal-sourced, acellular surgical mesh that is derived from porcine liver tissue. The liver tissue undergoes perfusion decellularization and the resulting mesh is comprised primarily of collagen type I. The Miromatrix Biological Mesh TW provides a scaffold during tissue repair and is designed to be an interface between the tendon and tendon sheath or the surrounding tissues. The Miromatrix Biological Mesh TW is designed for placement under, around or over the injured tendon. The device is terminally sterilized by electron beam irradiation in its packaging and is hydrated, moist and flexible when its packaging is opened. The mesh is available in sizes ranging from 1 cm x 2 cm to 10 cm x 20 cm, and may be trimmed or cut as required before being sutured to the surgical site.
The provided text is a 510(k) premarket notification letter and a 510(k) summary for a medical device called the "Miromatrix Biological Mesh TW." This document is used by the FDA to determine substantial equivalence to a legally marketed predicate device, not to prove that a device meets specific acceptance criteria through a clinical or algorithmic performance study in the way an AI/ML medical device would.
Therefore, many of the requested details, such as:
- Acceptance criteria (in the context of an AI/ML study)
- Study that proves the device meets acceptance criteria (in the context of an AI/ML study)
- Sample sizes for test sets, data provenance
- Number of experts and their qualifications for ground truth
- Adjudication method
- Multi-reader multi-case (MRMC) comparative effectiveness study
- Standalone algorithm performance
- Type of ground truth used (expert consensus, pathology, outcomes data, etc.)
- Sample size for training set
- How ground truth for the training set was established
are not applicable to the information provided in this document.
This document describes a surgical mesh product, which is a physical implant, not a software algorithm or an AI/ML medical device. The "performance data" mentioned refers to bench testing (tensile strength, suture pullout strength) and animal studies (tissue attachment, healing response) conducted to demonstrate the physical and biological performance of the mesh, not the performance of an AI algorithm.
The core of this 510(k) submission is to demonstrate substantial equivalence to a predicate device based on:
- Identical Indications for Use.
- Similar Technological Characteristics (design, materials, performance). The key point here is that if there are differences, they must not raise new questions of safety and effectiveness.
Here's a summary of the information that is present in the document, framed in the context of device approval, though not directly corresponding to AI/ML acceptance criteria:
1. A table of acceptance criteria and the reported device performance
- Acceptance Goal (Substantial Equivalence): The Miromatrix Biological Mesh TW must perform comparably to the predicate device (Integra Tendon Wrap™ Tendon Protector) in terms of safety and effectiveness for its intended use, and any differences in technological characteristics must not raise new questions of safety or effectiveness.
- Performance Metrics (from animal/bench testing):
- Tensile Strength & Suture Pullout Strength: The Miromatrix Biological Mesh TW was shown to have higher tensile and suture pullout strength than the predicate device. The conclusion states these differences "do not have any impact on safety and effectiveness, and therefore, on substantial equivalence."
- Tissue Attachment (animal study): After 4 and 10 weeks, the average tissue attachment was comparable between the Miromatrix Biological Mesh TW and the predicate device in an Achilles tendon defect model.
- Healing Response (animal study): The healing response at 4 and 10 weeks was also comparable.
- Biocompatibility: Established based on the identical material (porcine liver tissue) to a previously cleared reference device (Miromatrix Biological Mesh, K134033). No new biocompatibility testing was required.
- Shelf Life: Shelf life testing was performed to establish the proposed shelf life.
2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- No specific "test set" in the AI/ML sense. The document mentions "bench and animal data."
- Animal study: A "4 and 10-week partial Achilles tendon defect model" was used. The specific number of animals is not provided.
- Bench testing: Performed for tensile and suture pullout strength. The number of samples tested is not provided.
- Data Provenance: Not specified, but generally, studies for FDA submissions are expected to follow good laboratory practices.
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. Ground truth in this context would refer to the validated physical and biological properties of the mesh and the animal model outcomes, which are measured or observed by scientific/technical personnel, not "experts" establishing a diagnostic "ground truth."
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable. This methodology is for assessing subjective human interpretation, not for objective measurements or animal study outcomes.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
- Not applicable. This relates to AI assistance for human interpretation, which is not relevant to a surgical mesh.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not applicable. This is for AI algorithms.
7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)
- No "ground truth" in the AI/ML sense. The "truth" is established by direct measurement of physical properties (e.g., tensile strength) and observation of biological responses in animal models (e.g., tissue attachment, healing response) according to established scientific methods.
8. The sample size for the training set
- Not applicable. There is no "training set" for a physical device in this context.
9. How the ground truth for the training set was established
- Not applicable. See point 8.
§ 878.3300 Surgical mesh.
(a)
Identification. Surgical mesh is a metallic or polymeric screen intended to be implanted to reinforce soft tissue or bone where weakness exists. Examples of surgical mesh are metallic and polymeric mesh for hernia repair, and acetabular and cement restrictor mesh used during orthopedic surgery.(b)
Classification. Class II.