(30 days)
PICO is indicated for patients who would benefit from a suction device (negative pressure wound therapy) as it may promote wound healing via removal of low to moderate levels of exudate and infectious materials.
Appropriate wound types include:
- Chronic
- Acute
- Traumatic
- Subacute and dehisced wounds
- Partial-thickness burns
- Ulcers (such as diabetic or pressure)
- Flaps and grafts
- Closed surgical incisions
PICO Single Use Negative Pressure Wound Therapy System is suitable for use both in a hospital and homecare setting.
PICO Single Use Negative Pressure Wound Therapy System is a small, lightweight, portable, electro-mechanical pump system connected through a flexible tube to a super-absorbent, gentle adhesive dressing. Secondary fixation strips are also provided to ensure an adequate seal is achieved. The pump, the dressing and fixation strips are supplied sterile and for single use. PICO was designed to deliver negative pressure wound therapy to low and to moderate exudate levels of acute and chronic wound types. PICO Single Use Negative Pressure Wound Therapy System is suitable for use in both a hospital and homecare setting.
This submission K172521 is for a PICO Single Use Negative Pressure Wound Therapy System. The submission states that "The only difference between the subject device and the predicate device is the compliance against the requirements of IEC60601." This means that the device itself has not changed, only the testing and certifications for electrical safety and electromagnetic compatibility to updated standards. Therefore, there are no "acceptance criteria" or "reported device performance" in the typical sense of a clinical or analytical study, as the device's functional performance and efficacy are assumed to be the same as the predicate device.
Instead, the "acceptance criteria" for this submission are related to compliance with updated electrical and usability standards, and the "study" proving it meets these is the retesting and certification by a new testing house.
Here's how the provided information relates to your request:
1. A table of acceptance criteria and the reported device performance
| Acceptance Criteria (Compliance with Standards) | Reported Device Performance (Certification) |
|---|---|
| AAMI / ANSI ES60601-1:2005/(R)2012 And A1:2012,, C1:2009/(R)2012 and . A2:2010/(R)2012 (Medical Electrical Equipment - General Requirements for Basic Safety and Essential Performance) | Tested and certified by Intertek Testing Service NA, Inc (USA) |
| . IEC60601-1-2 Edition 4 (2014) (Medical Electrical Equipment - Electromagnetic Disturbances - Requirements and Tests) | Tested and certified by Intertek Testing Service NA, Inc (USA) |
| IEC 60601-1-6 Edition 3.1 2013-10 (Medical Electrical Equipment - Usability) | Tested and certified by Intertek Testing Service NA, Inc (USA) |
| IEC 60601-1-11 Edition 2.0 2015-01 (Medical Electrical Equipment - Home Healthcare Environment) | Tested and certified by Intertek Testing Service NA, Inc (USA) |
2. Sample size used for the test set and the data provenance
This information is not applicable as this is not a study involving patient data or a test set in the clinical/performance sense. The "test set" here refers to the device itself being subjected to engineering tests for compliance with electrical and safety standards.
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. Ground truth, in the context of clinical or diagnostic studies, is not relevant here. The "ground truth" for compliance with electrical standards is the standard itself, and the experts are the personnel at the testing and certification body (Intertek Testing Service NA, Inc (USA)) who conducted and verified the tests. Their qualifications would be in electrical engineering, biomedical engineering, and regulatory compliance, but specific numbers and detailed qualifications are not provided in this document.
4. Adjudication method for the test set
This information is not applicable. Adjudication methods (like 2+1 or 3+1) are used for resolving discrepancies in expert opinions, typically in clinical studies or image interpretation. Here, the "adjudication" is the formal process of testing and certifying by a recognized body (Intertek) against defined standards.
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. An MRMC study is relevant for AI-powered diagnostic devices. This device is a negative pressure wound therapy system, not an AI diagnostic tool.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This information is not applicable. This is not an algorithm-only device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
As explained above, "ground truth" in the typical clinical context is not applicable. The "ground truth" for this submission is compliance with the specified electrical safety, EMC, usability, and home healthcare environment standards (AAMI / ANSI ES60601-1, IEC60601-1-2, IEC 60601-1-6, IEC 60601-1-11).
8. The sample size for the training set
This information is not applicable as this is not an AI/machine learning device that requires a training set.
9. How the ground truth for the training set was established
This information is not applicable as this is not an AI/machine learning device.
{0}------------------------------------------------
Image /page/0/Picture/2 description: The image shows the seal of the U.S. Department of Health & Human Services. The seal features the department's name encircling a symbol. The symbol is a stylized representation of a human figure, with three faces in profile, one behind the other. The seal is in black and white.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
September 20, 2017
Smith & Nephew Medical Limited Samantha Neilson Senior Regulatory Affairs Manager, Advanced Wound Management 101 Hessle Road Hull, Yorkshire HU3 2BN GB
Re: K172521
Trade/Device Name: PICO Single Use Negative Pressure Wound Therapy System Regulation Number: 21 CFR 878.4780 Regulation Name: Powered Suction Pump Regulatory Class: Class II Product Code: OMP Dated: August 18, 2017 Received: August 21, 2017
Dear Samantha Neilson:
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, listing 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 device
{1}------------------------------------------------
related 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.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education (DICE) at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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 Industry and Consumer Education (DICE) at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely,
David Krause -S
for Binita S. Ashar, M.D., M.B.A., F.A.C.S. Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
{2}------------------------------------------------
DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
Indications for Use
Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement below.
510(k) Number (if known)
K172521
Device Name
PICO Single Use Negative Pressure Wound Therapy System
Indications for Use (Describe)
PICO is indicated for patients who would benefit from a suction device (negative pressure wound therapy) as it may promote wound healing via removal of low to moderate levels of exudate and infectious materials.
Appropriate wound types include:
- Chronic
- Acute
- Traumatic
- Subacute and dehisced wounds
- Partial-thickness burns
- Ulcers (such as diabetic or pressure)
- Flaps and grafts
- Closed surgical incisions
PICO Single Use Negative Pressure Wound Therapy System is suitable for use both in a hospital and homecare setting.
Type of Use (Select one or both, as applicable)
Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
CONTINUE ON A SEPARATE PAGE IF NEEDED.
This section applies only to requirements of the Paperwork Reduction Act of 1995.
*DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW! *
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov
"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."
FORM FDA 3881 (8/14)
{3}------------------------------------------------
510(K) SUMMARY
PICO Single Use Negative Pressure Wound Therapy System
| General Information | |
|---|---|
| Submitter Name/Address: | Smith & Nephew Medical Limited |
| 101 Hessle Road, | |
| Hull | |
| HU3 2BN | |
| United Kingdom | |
| Establishment Registration Number: | 8043484 |
| Contact Person: | Samantha Neilson, Senior Regulatory |
| Affairs Manager | |
| Phone Number | +44 1482 673790 |
| Date Prepared: | August 18, 2017 |
| Device Description | |
| Trade Name: | PICO Single Use Negative Pressure |
| Wound Therapy System | |
| Common or Usual Name: | Negative Pressure Wound Therapy |
| powered suction pump | |
| Classification Name: | Powered suction pump (21 CFR 878.4780) |
| Regulatory Class: | Class II |
| Product Code: | OMP |
| Predicate Device Information | |
| 510(k) Number: | K151436 |
| Device: | PICO Single Use Negative Pressure |
| Wound Therapy System | |
| Clearance Date: | January 28, 2016 |
{4}------------------------------------------------
Device Description
PICO Single Use Negative Pressure Wound Therapy System is a small, lightweight, portable, electro-mechanical pump system connected through a flexible tube to a super-absorbent, gentle adhesive dressing. Secondary fixation strips are also provided to ensure an adequate seal is achieved. The pump, the dressing and fixation strips are supplied sterile and for single use. PICO was designed to deliver negative pressure wound therapy to low and to moderate exudate levels of acute and chronic wound types. PICO Single Use Negative Pressure Wound Therapy System is suitable for use in both a hospital and homecare setting.
Indications for Use
PICO is indicated for patients who would benefit from a suction device (negative pressure wound therapy) as it may promote wound healing via removal of low to moderate levels of exudate and infectious materials.
Appropriate wound types include:
- Chronic
- Acute
- Traumatic
- Subacute and dehisced wounds
- Partial-thickness burns, Ulcers (such as diabetic or pressure)
- Flaps and grafts
- Closed surgical incisions
PICO Single Use Negative Pressure Wound Therapy System is suitable for use in both a hospital and homecare setting.
Comparison between New and Predicate Device
The Indications for Use statement of the PICO Single Use Negative Pressure Wound Therapy System is identical to the predicate device. The subject device
{5}------------------------------------------------
and the predicate device are the same. The only difference between the subject device and the predicate device is the compliance against the requirements of IEC60601.
The subject device has been retested to demonstrate compliance with
- AAMI / ANSI ES60601-1:2005/(R)2012 And A1:2012,, C1:2009/(R)2012 and . A2:2010/(R)2012
- . IEC60601-1-2 Edition 4 (2014)
- IEC 60601-1-6 Edition 3.1 2013-10, Medical Electrical Equipment Part 1-6: . General Requirements For Basic Safety And Essential Performance -Collateral Standard: Usability. (General I (QS/RM))
- IEC 60601-1-11 Edition 2.0 2015-01, Medical Electrical Equipment Part 1-. 11: General Requirements For Basic Safety And Essential Performance -Collateral Standard: Requirements For Medical Electrical Equipment And Medical Electrical Systems Used In The Home Healthcare Environment. (General II (ES/EMC))
while the predicate device was tested and cleared to the requirements of
- IEC60601-1:2005 + CORR.1 (2006) + CORR.2 (2007) ●
- IEC60601-1-2 Edition 3 (2007) ●
- IEC 60601-1-6: 2010 (Third Edition) Medical electrical equipment Part 1-6: . General requirements for basic safety and essential performance - Collateral standard: Usability)
- IEC 60601-1-11: 2010 (First Edition) General requirements for basic safety . and essential performance - Collateral standard: Requirements for medical electrical equipment and medical electrical systems used in the home healthcare environment
The Instructions for Use and the pump label been updated to reflect a change in test house. The cleared device was tested and certified by CSA Group (Canada)
{6}------------------------------------------------
whilst the subject device was tested and certified by Intertek Testing Service NA, Inc (USA).
Conclusions
In establishing substantial equivalence to the predicate devices, Smith & Nephew Medical Ltd evaluated the indications for use, materials, technology, product specifications and energy requirements of the device. As there are no design differences between the subject device and the predicate device, PICO Single Use Negative Pressure Wound Therapy System is substantially equivalent to the predicate for the intended use.
§ 878.4780 Powered suction pump.
(a)
Identification. A powered suction pump is a portable, AC-powered or compressed air-powered device intended to be used to remove infectious materials from wounds or fluids from a patient's airway or respiratory support system. The device may be used during surgery in the operating room or at the patient's bedside. The device may include a microbial filter.(b)
Classification. Class II.