(85 days)
The Miro3D Wound Matrix is intended for the management of wounds including:
- Partial and full thickness wounds
- Pressure ulcers
- Venous ulcers
- Chronic vascular ulcers
- Diabetic ulcers
- Tunneled, undermined wounds
- Trauma wounds (abrasions, lacerations, second-degree burns, and skin tears)
- Draining wounds
- Surgical wounds (donor sites/grafts, post-Mohs' surgery, post-laser surgery, podiatric, wound dehiscence)
The Reprise Miro3D Wound Matrix is a sterile, single use, non-crosslinked acellular wound dressing that is derived from porcine liver tissue. The liver is perfusion decellularized resulting in a collagen matrix that is dried and cut to defined sizes. The Miro3D porous scaffold provides a protective environment for wound healing. The device is packaged dry, terminally sterilized in its packaging by e-beam irradiation and is rehydrated with sterile saline or lactated Ringer's solution prior to use. The Miro3D Wound Matrix is provided in four sizes that may be cut to fit a wound size prior to application.
The provided FDA 510(k) summary for the Miro3D Wound Matrix does not describe a study that uses AI/ML or involves human readers interpreting diagnostic images. Instead, it describes a medical device, a wound matrix, and its non-clinical performance data to demonstrate substantial equivalence to a predicate device.
Therefore, I cannot provide information on acceptance criteria and a study that proves the device meets them as related to AI/ML or human interpretation of images. The document exclusively details the bench testing and animal study for a physical wound care device, not a diagnostic or AI-driven system.
However, I can extract the acceptance criteria and study findings related to the Miro3D Wound Matrix's physical and biological performance, as described in the provided text.
Acceptance Criteria and Study for Miro3D Wound Matrix (Non-AI/ML Device)
Based on the provided 510(k) summary for the Miro3D Wound Matrix, the acceptance criteria and supporting studies are focused on demonstrating the device's physical properties, biocompatibility, and performance in wound healing, compared to a predicate device. This is not an AI/ML diagnostic or image interpretation study.
1. Table of Acceptance Criteria and Reported Device Performance
| Feature/Test | Acceptance Criteria (Implicit from comparability) | Reported Device Performance and Study Findings |
|---|---|---|
| Intended Use | Same as predicate (Wound management: providing a protective environment for wound healing) | The Miro3D Wound Matrix has the same Intended Use as the predicate MiroDerm Wound Matrix. |
| Material/Chemical Composition | Same as predicate (Perfusion-decellularized porcine liver) | "The devices have the same material/chemical composition..." |
| Principle of Operation | Same as predicate (Provide a protective environment for wound healing) | "The devices have the same... principle of operation..." |
| Clinical Use | Same as predicate | "The devices have the same... clinical use..." |
| Biocompatibility | Meets ISO 10993 standards for relevant biological endpoints (Cytotoxicity, Sensitization, Intracutaneous Reactivity, Acute Systemic Toxicity, Material Mediated Pyrogenicity, Implantation, Subacute Systemic Toxicity, Subchronic Systemic Toxicity, Genotoxicity) | "Biocompatibility testing or justification for all applicable biological endpoints per ISO 10993-1:2018 were completed." (Specific results not detailed but implied adherence to standards). |
| Sterilization Assurance Level (SAL) | 10^-6 | Reported as 10^-6 for e-beam irradiation. |
| Viral Inactivation | Manufacturing process capable of inactivating four viruses. | "Manufacturing process is capable of inactivating four viruses." |
| Package Stability | Meets specified ASTM and ISO standards (ASTM F988-09, ASTM F2096, ISO 11607-1:2019, ASTM F2825-18, ASTM D4169-16, and ASTM F2096-11). | Package Stability Testing was conducted and presumably met the standards, allowing for the stated shelf life. |
| Product Testing (Bench) | Meets established specifications for: - Collagen denaturation temperature - Mechanical properties - Dimensions - Rehydration properties - Residual detergent - Residual DNA - Bacterial endotoxin - Viral inactivation | The listed bench tests were conducted. The implication is that the results demonstrated the device's conformance to its specifications and comparability to the predicate. |
| Wound Healing Performance (Animal Study) | Comparable performance to predicate device (MiroDerm) in a porcine full-thickness wound healing model. | "The study results indicated that Miro3D performed comparably to MiroDerm in all aspects evaluated." |
| Shelf Life | Ability to support 18 months shelf life (initial), with real-time aging supporting 3 years. | "18 months (as of this submission date; real-time aging will continue to support 3 year shelf life)" |
2. Sample Sizes Used for the Test Set and Data Provenance
- Test Set (Animal Study): A "GLP compliant animal study to evaluate Miro3D compared to MiroDerm on healing of porcine full thickness wounds" was conducted. The specific sample size (number of animals or wounds) is not explicitly stated in the provided text.
- Data Provenance: The animal study was "GLP compliant," implying a controlled laboratory setting. The country of origin is not specified but given the FDA submission, it would typically be conducted in a country adhering to GLP standards (e.g., U.S. or equivalent). The study was prospective in nature, as it intentionally compared the subject device to the predicate in a living model.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
- This information is not applicable and not provided. The "ground truth" for this device's performance was established through objective laboratory testing (bench tests) and direct biological observation/measurement in an animal model, not through expert radiological or diagnostic image interpretation.
4. Adjudication Method for the Test Set
- Not applicable as there were no human readers interpreting data that required adjudication. The animal study would have involved histological, photographic, and perhaps gross morphological assessments, likely by qualified veterinary pathologists or researchers, but no "adjudication method" in the sense of reconciling human reader disagreements on diagnostic interpretations.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and Effect Size
- No, an MRMC comparative effectiveness study was not done. This type of study is specifically for evaluating the impact of AI on human interpretation of diagnostic images. The Miro3D Wound Matrix is a physical medical device, not a diagnostic AI system.
6. If a Standalone (i.e., Algorithm Only Without Human-in-the-Loop Performance) Was Done
- Not applicable. There is no algorithm or AI model being evaluated for standalone performance.
7. The Type of Ground Truth Used
- For Bench Testing: The ground truth was based on objective measurement against predefined specifications (e.g., specific values for residual DNA, collagen analysis, dimensions, endotoxin levels) and adherence to industry standards (e.g., ISO, ASTM).
- For Animal Study (Proxy for in vivo performance): The ground truth was established through direct observation and measurement of wound healing parameters in the porcine model, comparing the subject device (Miro3D) against the predicate (MiroDerm). This would involve histological analysis, macroscopic assessment of wound closure, and potentially other biomarkers, confirmed by veterinary professionals.
8. The Sample Size for the Training Set
- Not applicable. This device is a physical wound matrix, not an AI/ML algorithm that requires a training set.
9. How the Ground Truth for the Training Set Was Established
- Not applicable. As there is no AI/ML algorithm, there is no training set or associated ground truth establishment process in this context.
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Image /page/0/Picture/0 description: The image contains the logos of the Department of Health and Human Services (HHS) and the Food and Drug Administration (FDA). The HHS logo is on the left, and the FDA logo is on the right. The FDA logo includes the FDA acronym in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.
August 25, 2022
Reprise Biomedical, Inc. Kathy Herzog Regulatory Consultant 17400 Medina Road Suite 100 Plymouth, Minnesota 55447
Re: K221520
Trade/Device Name: Miro3D Wound Matrix Regulatory Class: Not Classified Product Code: KGN
Dear Kathy Herzog:
The Food and Drug Administration (FDA) is sending this letter to notify you of an administrative change related to your previous substantial equivalence (SE) determination letter dated August 18, 2022. Specifically, FDA is updating this SE Letter as an administrative correction to include the 510k Summary document for K221520, as it was inadvertently excluded from our August 18, 2022 SE Letter.
Please note that the 510(k) submission was not re-reviewed. For questions regarding this letter please contact Julie Morabito, OHT4: Office of Surgical and Infection Control Devices, 240-247-6328 or at julie.morabito@fda.hhs.gov.
Sincerely,
Julie A. Morabito -S
Julie Morabito, Ph.D. Assistant Director DHT4B: Division of Infection Control and Plastic Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
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Image /page/1/Picture/0 description: The image contains the logos of the Department of Health & Human Services and the Food and Drug Administration (FDA). The Department of Health & Human Services logo is on the left, and the FDA logo is on the right. The FDA logo includes the text "FDA U.S. FOOD & DRUG ADMINISTRATION" in blue.
August 18, 2022
Reprise Biomedical, Inc. Kathy Herzog Regulatory Consultant 17400 Medina Road Suite 100 Plymouth, Minnesota 55447
Re: K221520
Trade/Device Name: Miro3D Wound Matrix Regulatory Class: Not Classified Product Code: KGN Dated: Mav 24, 2022 Received: May 25, 2022
Dear Kathy Herzog:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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
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requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE(@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Julie Morabito, Ph.D. Assistant Director DHT4B: Division of Infection Control and Plastic Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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Form Approved: OMB No. 0910-0120
Expiration Date: 06/30/2023
See PRA Statement below.
DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
Indications for Use
510(k) Number (if known) K221520
Device Name Miro3D Wound Matrix
Indications for Use (Describe)
The Miro3D Wound Matrix is intended for the management of wounds including:
- · Partial and full thickness wounds
- · Pressure ulcers
- Venous ulcers
- Chronic vascular ulcers
- · Diabetic ulcers
- Tunneled, undermined wounds
- · Trauma wounds (abrasions, lacerations, second-degree burns, and skin tears)
- · Draining wounds
- · Surgical wounds (donor sites/grafts, post-Mohs' surgery, post-laser surgery, podiatric, wound dehiscence)
Type of Use (Select one or both, as applicable) | Over-The-Counter Use (21 CFR 801 Subpart C) X Prescription Use (Part 21 CFR 801 Subpart D)
CONTINUE ON A SEPARATE PAGE IF NEEDED.
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DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.
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510(k) Summary
This summary of 510(k) safety and effectiveness information is submitted in accordance with the requirements of 21 CFR §807.92:
I. SUBMITTER
Reprise Biomedical, Inc. 17400 Medina Road, Suite 100 Plymouth, MN 55447 763-284-6795
Contact Person: Carrie Powers Date Prepared: August 18, 2022
II. DEVICE
| Trade/Proprietary Names: | Miro3D Wound Matrix |
|---|---|
| Common Name: | Animal-derived, extracellular matrix wound care product |
| Regulation Number: | Unclassified |
| Regulation Name: | NA |
| Device Class: | Unclassified |
| Product Code: | KGN |
| Panel: | General & Plastic Surgery |
III. PREDICATE DEVICE
MiroDerm Wound Matrix (also known as Miromatrix Wound Matrix), K140510 This predicate has not been subject to a design-related recall. No reference devices were used in this submission.
IV. DEVICE DESCRIPTION
The Reprise Miro3D Wound Matrix is a sterile, single use, non-crosslinked acellular wound dressing that is derived from porcine liver tissue. The liver is perfusion decellularized resulting in a collagen matrix that is dried and cut to defined sizes. The Miro3D porous scaffold provides a protective environment for wound healing. The device is packaged dry, terminally sterilized in its packaging by e-beam irradiation and is rehydrated with sterile saline or lactated Ringer's solution prior to use. The Miro3D Wound Matrix is provided in four sizes that may be cut to fit a wound size prior to application.
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V. INDICATIONS FOR USE
The Miro3D Wound Matrix is indicated for the following:
The Miro3D Wound Matrix is intended for the management of wounds including:
- Partial and full thickness wounds o
- o Pressure ulcers
- Venous ulcers o
- Chronic vascular ulcers ●
- Diabetic ulcers ●
- Tunneled, undermined wounds ●
- Trauma wounds (abrasions, lacerations, second-degree burns, and skin tears)
- Draining wounds o
- . Surgical wounds (donor sites/grafts, post-Mohs' surgery, post-laser surgery, podiatric, wound dehiscence)
VI. COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE DEVICE
The Miro3D Wound Matrix is the dry, uncompressed version of MiroDerm which is supplied as a wet, compressed flat sheet. The subject and predicate devices have the same technological characteristics as the change in configuration does not change the Intended Use or fundamental scientific technology of the collagen matrix for wound management. No new device materials or manufacturing materials are introduced with the Miro3D as compared to MiroDerm. The devices have the same material/chemical composition, principle of operation, clinical use, biocompatibility, and sterilization. The device packaging materials for Miro3D (PETG and Tyvek) are commonly used in the medical device industry with a long history of safe use.
| Feature | Miro3DWound Matrix(Subject Device) | MiroDermWound Matrix(Predicate Device) |
|---|---|---|
| K Number | K221520 | K140510 |
| Classification | Unclassified (pre-amendment) | Unclassified (pre-amendment) |
| Product Code | KGN | KGN |
| Class | II | II |
| Intended Use | Wound management | Wound management |
| Indications ForUse | The Miro3D Wound Matrix isintended for the management ofwounds including: | The Miromatrix Wound Matrixis intended for the managementof wounds including: |
| Feature | Miro3DWound Matrix(Subject Device) | MiroDermWound Matrix(Predicate Device) |
| • Partial and full thicknesswounds• Pressure ulcers• Venous ulcers• Chronic vascular ulcers• Diabetic ulcers• Tunneled, undermined wounds• Trauma wounds (abrasions,lacerations, second-degreeburns, and skin tears)• Draining wounds• Surgical wounds (donorsites/grafts, post-Mohs'surgery, post-laser surgery,podiatric, wound dehiscence) | • Partial and full thicknesswounds• Pressure ulcers• Venous ulcers• Chronic vascular ulcers• Diabetic ulcers• Tunneled, undermined wounds• Trauma wounds (abrasions,lacerations, second-degreeburns, and skin tears)• Draining wounds• Surgical wounds (donorsites/grafts, post-Mohs'surgery, post-laser surgery,podiatric, wound dehiscence) | |
| Type of Use | Wound management | Wound management |
| User | Physician or other cliniciantrained in wound care | Physician or other cliniciantrained in wound care |
| Intended UseEnvironment | Surgical suite, hospital,ambulatory surgery center orout-patient clinic | Surgical suite, hospital,ambulatory surgery center orout-patient clinic |
| Description | Animal-sourced, non-crosslinked, acellular collagentissue matrix | Animal-sourced, non-crosslinked, acellular collagentissue matrix |
| Principle ofOperation | Provide a protectiveenvironment for woundhealing | Provide a protectiveenvironment for woundhealing |
| Material | Perfusion-decellularizedporcine liver | Perfusion-decellularizedporcine liver |
| Resorbable | Yes | Yes |
| Configuration | Three-dimensional collagenscaffold provided in four sizes(W x L), all 2 cm thickness(Model Number)• 2 cm x 2 cm (3000)• 3 cm x 3 cm (3005)• 5 cm x 5 cm (3010)• 10 cm x 5 cm (3015) | Flat collagen sheet provided innine sizes (W x L), thicknessranging from 0.3 to 1.5 mm(Model Number):• 2 cm x 2 cm (BLM-200-02-0202)• 2 cm x 3 cm (BLM-200-02-0203)• 3 cm x 3 cm (BLM-200-02-0303) |
| Feature | Miro3DWound Matrix(Subject Device) | MiroDermWound Matrix(Predicate Device) |
| 4 cm x 4 cm (BLM-200-02-0404) 3 cm x 7 cm (BLM-200-02-0307) 5 cm x 5 cm (BLM-200-02-0505) 8 cm x 8 cm (BLM-200-02-0808) 7 cm x 10 cm (BLM-200-02-0710) 8 cm x 15 cm (BLM-200-02-0815) | ||
| Wound MatrixPreparation | Rehydrate a minimum of fiveminutes in either sterile saline orlactated Ringer's solution;cut/trim the wound matrix to fitwound | Soak for two minutes in eithersterile saline or lactated Ringer'ssolution; cut/trim wound matrixto fit wound |
| Single Use orReusable | Single Use | Single Use |
| SterilizationMethod | Electron beam irradiation | Electron beam irradiation |
| SterilizationAssurance Level(SAL) | $10^{-6}$ | $10^{-6}$ |
| Packaging | Device package: Packaged dry in a PETG plastic tray and snap-on lid with Tyvek lid seal Sterile barrier: Aluminum laminate foil pouch Shelf box: Cardboard | Device package: Packaged wet in an aluminum laminate foil pouch Sterile barrier: Aluminum laminate foil pouch Shelf box: Cardboard |
| Shelf Life | 18 months (as of this submissiondate; real-time aging willcontinue to support 3 year shelflife) | 3 years |
| StorageConditions | No special storage conditionsrequired | No special storage conditionsrequired |
| Biocompatibility | Biocompatibility testing orjustification for all applicable | Biocompatibility testing orjustification for all applicable |
| Feature | Miro3DWound Matrix(Subject Device) | MiroDermWound Matrix(Predicate Device) |
| biological endpoints per ISO10993-1:2018 were completed | biological endpoints per ISO10993-1:2009 were completed | |
| ViralInactivation | Manufacturing process iscapable of inactivating fourviruses | Manufacturing process iscapable of inactivating fourviruses |
| Bench Testing | The following tests wereconducted:● Residual DNA● Collagen analysis● Endotoxin● Expiration dating● Residual detergent● Dimensions● Rehydration | The following tests wereconducted:● Residual DNA● Collagen analysis● Endotoxin● Expiration dating● Residual detergent |
| Animal WoundHealing Study | GLP Study to evaluate Miro3Dcompared to MiroDerm as acontrol article in a porcine fullthickness wound healing model | None completed |
Table 1: Subject vs. Predicate Wound Matrix Comparison
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VII. PERFORMANCE DATA
The following performance data were provided in support of the substantial equivalence determination:
1. Biocompatibility Testing
- Cytotoxicity, ISO 10993-5:2009 a.
- b. Sensitization, ISO 10993-10:2010
- c. Intracutaneous Reactivity, ISO 10993-10:2010
- d. Acute Systemic Toxicity, ISO 10993-11: 2017
- e. Material Mediated Pyrogenicity, ISO 10993-11:2017
- f. Implantation, ISO 10993-6:2016
- Subacute Systemic Toxicity, ISO 10993-11:2017 g.
- h. Subchronic Systemic Toxicity, ISO 10993-11:2017
- Genotoxicity (Ames Bacterial Reverse Mutation and Mouse Lymphoma), ISO i. 10993-3:2014
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2. Bench Testing
- Package Stability Testing, ASTM F988-09, ASTM F2096, ISO 11607-1:2019, a. ASTM F2825-18, ASTM D4169-16, and ASTM F2096-11
- b. Product Testing
-
- Collagen denaturation temperature, ASTM D3418
-
- Mechanical testing Dimensional
-
- Rehvdration
-
- Residual detergent
-
- Residual DNA
-
- Bacterial endotoxin testing, ST72:2019
-
- Viral inactivation
-
In addition, Reprise Biomedical sponsored a GLP compliant animal study to evaluate Miro3D compared to MiroDerm on healing of porcine full thickness wounds. The study results indicated that Miro3D performed comparably to MiroDerm in all aspects evaluated.
MR compatibility was not evaluated.
VIII. CONCLUSIONS
The subject Miro3D Wound Matrix has the same Intended Use as the predicate MiroDerm Wound Matrix to provide a protective environment for wound healing. The subject and predicate devices have the same technological characteristics as the change in configuration (dry, uncompressed for Miro3D and wet, compressed for MiroDerm) does not change the Intended Use, chemical composition, or fundamental scientific technology of the collagen matrix for wound management. The Miro3D device packaging materials are common in the industry and do not introduce any new hazards. These modifications in configuration and device packaging materials do not raise different questions of safety and effectiveness compared to the predicate device. Performance testing provides evidence the Miro3D device performs as intended and is as safe and effective as the predicate device. Therefore, the subject Miro3D device is substantially equivalent to the predicate MiroDerm device (K140510).
N/A