(36 days)
Containment and Counting of Sponges in the Operating Room or a hospital setting.
Pocket Count: Transparent, compartmentalized, disposable bag which allows visual confirmation of sponge count and visual estimate of absorbed fluid. Pocket Count provides partial containment of contaminated sponges, thereby, decreasing worker exposure to contents.
SafeTCount: Transparent, disposable hand shaped covering which is used to collect sponges. When the covering is turned inside out it contains the contaminated sponges thereby decreasing worker exposure to contents. The SafeTCount allows visual confirmation of sponge count and visual estimate of absorbed fluid.
This document is a 510(k) premarket notification for the "Pocket Count or SafeTCount" surgical sponge counter. It primarily focuses on demonstrating substantial equivalence to pre-existing predicate devices. As such, it does not contain a typical study where specific acceptance criteria are set and then experimentally proven by the device.
Instead, the document details a comparison study to establish substantial equivalence based on design and intended use, rather than a performance study with quantitative acceptance criteria.
Here's an analysis of the information provided:
1. A table of acceptance criteria and the reported device performance
The document does not present acceptance criteria in the traditional sense of measurable performance targets (e.g., accuracy, sensitivity, specificity) with associated reported device performance. Instead, the "performance" section of the substantial equivalence comparison table (page 3, {3}) states:
| Performance | Holds up to 5 lap sponges or 10 - 4x4's | Holds up to 5 lap sponges or 10 - 4x4's | Holds up to 5 lap sponges or 10 - 4x4's | No Claim Made |
|---|
This indicates the device's capacity, which is a design specification, not a performance metric that would typically be tested against acceptance criteria in a clinical study. The "acceptance criteria" here implicitly revolve around demonstrating that the new devices (Pocket Count and SafeTCount) are substantially equivalent in their intended use, design, material, and performance characteristics (like capacity) to legally marketed predicate devices.
2. Sample size used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective)
- Sample Size for Test Set: Not applicable. This submission is for a physical device (surgical sponge counter) and does not involve a "test set" of data in the context of an algorithm or diagnostic device. The evaluation is based on comparing design features and stated capacities to predicate devices.
- Data Provenance: Not applicable for a typical "test set" as described for an algorithm. The data provenance would refer to the characteristics of the predicate devices themselves (e.g., "legally marketed in interstate commerce prior to May 28, 1976").
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable. "Ground truth" in this context would generally refer to a medical diagnosis or outcome used to evaluate an AI/diagnostic device. For a surgical sponge counter, the "truth" is whether it effectively contains and allows counting of sponges as designed, which is assessed through design comparison and manufacturer claims, not expert consensus on diagnostic data.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set
Not applicable. There is no test set in the sense of diagnostic data requiring adjudication. The FDA's review process determines substantial equivalence based on the submitted information comparing the device to predicates.
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 document is for a physical medical device (surgical sponge counter), not an AI or diagnostic tool that would involve human readers or cases.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This is not an algorithm or software device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
Not applicable. The "ground truth" for this type of device is its functional design and capacity to hold sponges, which is inherently understood through its physical properties and intended use. The comparison is against predicate devices that perform the same function.
8. The sample size for the training set
Not applicable. This is not an AI or algorithm-driven device that requires a training set.
9. How the ground truth for the training set was established
Not applicable. There is no training set for this device.
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Image /page/0/Picture/1 description: The image shows the seal of the Department of Health and Human Services (HHS). The seal features a stylized eagle with three stripes representing the three branches of government. The eagle is surrounded by the words "DEPARTMENT OF HEALTH AND HUMAN SERVICES - USA" in a circular arrangement. The seal is black and white and appears to be a scanned image.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
MAR 2 1 2006
SAGE Products, Inc. c/o Ms. Karen Pinto Regulatory Affairs Manager 815 Tek Drive, P.O. Box 9693 Crystal Lake, Illinois 60039-9693
Re: K972302 Trade/Device Name: Pocket Count or SafeTCount Regulation Number: 21 CFR 880.2740 Regulation Name: Surgical sponge scale Regulatory Class: I Exempt Product Code: LWH Dated: June 18, 1997 Received: June 19, 1997
Dear Ms. Pinto:
This letter corrects our substantially equivalent letter of July 25, 1997.
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 (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.
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); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21
{1}------------------------------------------------
Page 2 – Ms. Karen Pinto
CFR Part 820); and if applicable, the electronic product radiation control provisions (sections 531-542 of the Act); 21 CFR 1000-1050.
This letter will allow you to continue 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 (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html
Sincerely vours,
l.mll.
Mark N. Melkerson Acting Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health
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Image /page/2/Picture/0 description: The image shows the logo for SAGE PRODUCTS INC. The word "SAGE" is in large, bold, black letters. Below the word "SAGE" is the word "PRODUCTS INC" in smaller, black letters. Above the logo is the number "K972302" in black handwriting.
JUL 25 1997
| 17 | 510(k) Summary |
|---|---|
| Company Name | Sage Products Inc. |
| Street Address | 815 Tek Drive, Crystal Lake, IL 60014 |
| Date of Summary Preparation | June 18, 1997 |
| Device Name | |
| Trade or Proprietary Name | Pocket Count or SafeTCount |
| Common Name | Surgical Sponge Counter (CFR designation does not exist) |
| Classification Name | Sponge Counter |
| Intended Use | Containment and Counting of Sponges |
| Description | |
| Pocket Count | Transparent, compartmentalized, disposable bag which allowsvisual confirmation of sponge count and visual estimate ofabsorbed fluid. Pocket Count provides partial containment ofcontaminated sponges, thereby, decreasing worker exposure tocontents. |
| SafeTCount | Transparent, disposable hand shaped covering which is used tocollect sponges. When the covering is turned inside out itcontains the contaminated sponges thereby decreasing worke |
Section 17, page 12 of 13 of Submission
Page 1 of 2 of Summary
"Innovative health care products since 1971"
fluid.
exposure to contents. The SafeTCount allows visual
confirmation of sponge count and visual estimate of absorbed
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Image /page/3/Picture/0 description: The image shows the logo for SAGE PRODUCTS INC. The word "SAGE" is written in large, bold, sans-serif font, with each letter having a slightly futuristic or stylized design. Below "SAGE", the words "PRODUCTS INC" are written in a smaller, sans-serif font. A horizontal line spans the length of the words "PRODUCTS INC".
510(K)
Substantial Equivalence Comparison
ﻟﻤﺴﺘﻌﻤﻞ
ﺔ ﻣﻦ ﺍﻟ
| Product Name | Pocket Count | Bag-It | SafeTCount | Multi-Mitt |
|---|---|---|---|---|
| Manufacturer | Sage Products | Devon | Sage Products | Devon |
| Intended Use of Product | Containment and counting of sponges | Containment and counting of sponges | Containment and counting of sponges | Containment and counting of sponges |
| Design | compartmentalized pockets | compartmentalized pockets | hand shaped hand covering | rectangular hand covering |
| Pull Tabs | Available | Not available | N/A | N/A |
| Material | Polyethylene | Polyethylene | Polyethylene | Polyethylene |
| Clarity | Transparent | Transparent | Transparent | Transparent |
| Sterility | Non-Sterile | Non-Sterile | Non-Sterile | Non-Sterile |
| Target Population | OR/Hospital | OR | OR/Hospital | Hospital |
| Compliance with Standards | N/A | N/A | 21 CFR 800.20 | 21 CFR 800.20 |
| Performance | Holds up to 5 lap sponges or 10 - 4x4's | Holds up to 5 lap sponges or 10 - 4x4's | Holds up to 5 lap sponges or 10 - 4x4's | No Claim Made |
| Accessories Available | Bracket for mounting | Bracket for mounting | Bracket for mounting | Bracket for mounting |
Section 17, page 13 of 13 of Submission
Page 2 of 2 of Summary
"Innovative health care products since 1971"
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| 510(k) Number (if known): | K97 23 02 |
|---|---|
| --------------------------- | ----------- |
Device Name: Sponge Counter_
Indications For Use:
Containment and Counting of Sponges in the Operating Room or a hospital setting.
Section 16, page 11 of 13 of submission
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Prescription Use (Per 21 CFR 801.109)
OR
Over-The-Counter Use X
(Optional Format 1-2-96)
§ 880.2740 Surgical sponge scale.
(a)
Identification. A surgical sponge scale is a nonelectrically powered device used to weigh surgical sponges that have been used to absorb blood during surgery so that, by comparison with the known dry weight of the sponges, an estimate may be made of the blood lost by the patient during surgery.(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 § 880.9. The device also 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.