(357 days)
BIONECT® Hydrogel Gauze Pads are indicated for the dressing and management of partial to full thickness dermal ulcers (pressure sores, venous stasis ulcers, arterial ulcers, diabetic ulcers), wounds including cuts, abrasions, donor sites, and post-operative incisions, irritations of the skin, and first and second degree burns.
BIONECT® Hydrogel Gauze Pads are sterile cotton gauze pads impregnated with a hydrogel that is prepared from sodium hyaluronate and purified water to form a hydrogel dressing. Sodium hyaluronate is a polysaccharide biopolymer that can increase the viscosity of the gel. BIONECT® Hydrogel Gauze Pads, since they are a hydrogel dressing, provide a soothing, moist environment that is supportive to wound healing.
The provided text describes a 510(k) premarket notification for Bionect® Hydrogel Gauze Pads. This type of submission focuses on demonstrating substantial equivalence to a predicate device, rather than establishing primary effectiveness through new, controlled clinical trials with specific acceptance criteria as might be seen for novel therapeutic devices or diagnostic AI. Therefore, the information requested for AI/diagnostic devices will not be fully present in this documentation.
Here's an analysis based on the available information:
1. Table of Acceptance Criteria and Reported Device Performance
Formal acceptance criteria for performance benchmarks (e.g., sensitivity, specificity, accuracy) are not applicable in this 510(k) summary because it is not an AI diagnostic or therapeutic device. The "performance" being evaluated is primarily the safety and technological characteristics in comparison to a predicate device, not diagnostic accuracy or treatment efficacy against a specific metric.
The document states:
- "In vitro and in vivo biocompatibility testing (cytotoxicity, dermal irritation, and dermal sensitization tests) has been performed... These tests all support the safe use of BIONECT® Hydrogel Gauze Pads..."
- "Clinical experience with BIONECT® Hydrogel Gauze Pads in approximately 430 patients... indicates that BIONECT® Hydrogel Gauze Pads are safe for their intended use."
The acceptance criteria here are implicitly:
- Biocompatibility tests pass safety standards.
- Clinical experience shows no unexpected or significant safety concerns.
- Technological characteristics (occlusion, bioburden, moist wound healing) are "not different from the predicate device."
| Acceptance Criteria (Implied for 510(k) - Safety & Equivalence) | Reported Device Performance |
|---|---|
| Biocompatibility (cytotoxicity, dermal irritation, sensitization) meets FDA recommendations. | All tests "support the safe use of BIONECT® Hydrogel Gauze Pads as a hydrogel temporary dressing in contact with breached or compromised skin." |
| Clinical safety in intended use environment. | "Clinical experience... in approximately 430 patients... indicates that BIONECT® Hydrogel Gauze Pads are safe for their intended use." |
| Technological characteristics (occlusion, bioburden level, moist wound healing) are not different from the predicate device. | "The technological characteristics of the device... are not different from the predicate device cited." |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size (Clinical Experience): Approximately 430 patients.
- Data Provenance: The document states "16 clinical trials (13 controlled)." It does not specify the country of origin, but given the submission is to the U.S. FDA, it is likely that at least some, if not all, of these studies were conducted in a manner acceptable for US regulatory purposes. The studies are described as "clinical experience," implying they were prospective observations or trials, though detailed design is not provided. They are prospective data from clinical trials.
3. Number of Experts Used to Establish Ground Truth and Qualifications
This information is not applicable/provided in this 510(k) document. The clinical experience mentioned likely involved medical professionals managing patient wounds, but the context is not about establishing a "ground truth" for an AI algorithm's output. The "ground truth" implicitly would be the clinical assessment of wound healing and safety by treating physicians, but this is not framed as an expert ground truth for evaluating an algorithm.
4. Adjudication Method for the Test Set
This information is not applicable/provided. The clinical experience likely involved physician assessment, but there's no mention of a formal adjudication method for a "test set" in the context of an algorithm or diagnostic performance.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done, and the effect size of human readers improving with AI vs. without AI assistance
There was no MRMC comparative effectiveness study and no AI component to this device. BIONECT® Hydrogel Gauze Pads are a physical wound dressing, not an AI-powered diagnostic or therapeutic tool.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done
There was no standalone algorithm performance study as this is not an AI device.
7. The type of ground truth used
The closest concept to "ground truth" for this device would be:
- Biocompatibility test results: Objective laboratory measures against established ISO standards.
- Clinical observations/outcomes: Physician's assessment of wound healing, adverse events, and safety during the 16 clinical trials. This is based on expert clinical judgment and patient outcomes.
8. The Sample Size for the Training Set
This is not applicable/provided. There is no AI model, and therefore no training set. The "clinical experience" with 430 patients and biocompatibility tests serve as the data supporting the device's safety and equivalence.
9. How the Ground Truth for the Training Set was Established
This is not applicable/provided. There is no AI model or training set in the context of this device and 510(k) submission.
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SEP 2 2 1998
510(k) Premarket Notification K973721 BIONECT® Hydrogel Gauze Pads Amendment No. 3
fidia Pharmaceutical Corporation
July 1, 1998
10. 510(k) SUMMARY
Summary Information 10.1
10.1.1 Submitter's name and address
FIDIA Pharmaceutical Corporation 2000 K Street, NW, Suite 700 Washington, DC 20006
Contact person and telephone number:
Roberto Fiorentini, M.D., President (202) 371-9898 Telephone: (202) 371-1666 Telefax:
Date summary was prepared:
July 1, 1998
10.1.2 Name of the Device
| Trade Name: | BIONECT® Hydrogel Gauze Pads |
|---|---|
| Common Name: | Hyaluronic acid sodium salt hydrogel dressing-impregnated |
| gauze pads | |
| Classification Name: | Hydrogel Wound and Burn Dressing |
10.1.3 Identification of predicate device to which substantial equivalence is being claimed
BIONECT® Hydrogel Gauze Pads are substantially equivalent in function and intended use to the following cleared non-interactive wound and burn dressing: BIONECT® Hydrogel.
10.1.4 Device description
Explanation of how the device functions: BIONECT® Hydrogel Gauze Pads, since they contain a hydrogel, provide a moist wound environment that is supportive to wound healing.
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fidia Pharmaceutical Corporation
Basic scientific concepts that form the basis for the device: BIONECT® Hydrogel Gauze Pads, since they are a hydrogel dressing, provide a soothing, moist environment that is supportive to wound healing.
Significant physical and performance characteristics of the device such as device design, materials used, and physical properties: BIONECT® Hydrogel Gauze Pads are sterile cotton gauze pads impregnated with a hydrogel that is prepared from sodium hyaluronate and purified water to form a hydrogel dressing. Sodium hyaluronate is a polysaccharide biopolymer that can increase the viscosity of the gel. BIONECT® Hydrogel Gauze Pads, since they are a hydrogel dressing, provide a soothing, moist environment that is supportive to wound healing.
10.1.5 Statement of the intended use of the device, including general description of the conditions the device will mitigate and the patient population for which the device is intended
BIONECT® Hydrogel Gauze Pads are indicated for the dressing and management of partial to full thickness dermal ulcers (pressure sores, venous stasis ulcers, arterial ulcers, diabetic ulcers), wounds including cuts, abrasions, donor sites, and post-operative incisions, irritations of the skin, and first and second degree burns.
These indication statements are not substantially different from the predicate device identified in Section 10.1.3.
10.1.6 Statement of how the technological characteristics of the device compare to those of the predicate device
The technological characteristics of the device such as occlusion, bioburden level, and moist wound healing are not different from the predicate device cited.
Assessment of performance data 10.2
In vitro and in vivo biocompatibility testing (cytotoxicity, dermal irritation, and dermal sensitization tests) has been performed on the bulk solution that impregnates BIONECT® Hydrogel Gauze Pads in accordance with FDA recommendations. These tests all
5 Office of Device Evaluation General Program Memorandum #695-1, International Standard ISO-10993, "Biological Evaluation of Medical Devices part 1: Evaluation and Testing," dated 1 May 1995.
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fidia Pharmaceutical Corporation
July 1, 1998
support the safe use of BIONECT® Hydrogel Gauze Pads as a hydrogel temporary dressing in contact with breached or compromised skin.
Clinical experience with BIONECT® Hydrogel Gauze Pads in approximately 430 patients with various types of ulcers and burns in 16 clinical trials (13 controlled), indicates that BIONECT® Hydrogel Gauze Pads are safe for their intended use.
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Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is a stylized symbol that resembles three human profiles facing right, with flowing lines beneath them.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
SEP 2 2 1998
Roberto Fiorentini, M.D. President Fidia Pharmaceutical Corporation 2000 K Street, N.W., Suite 700 Washington, D.C. 20006
K973721, K973722, K973724 and K973725 Re: Trade Name: Bionect Hydrogel Gauze Pads, Bionect Hydrogel Foam Bionect Hyrdogel Spray and Bionect Clear Hydrogel Regulatory Class: Unclassified Product Code: MGQ Dated: July 1 and July 8, 1998 Received: July 1 and July 9, 1998
Dear Dr. Fiorentini:
We have reviewed your Section 510(k) notification of intent to market the devices referenced above and we have determined the devices are substantially equivalent (for the indications for use stated in the enclosures) to 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 (the Act). You may, therefore, market your devices subject to the general controls provisions of the Federal Food, Drug, and Cosmetic Act (Act) and the following limitations:
- 1 . These devices may not be labeled for use on third degree burns.
-
- These devices may not be labeled as having any accelerating effect on the rate of wound healing or epithelization.
-
- These devices may not be labeled as a long-term, permanent, or no-change dressing, or as an artificial (synthetic) skin.
-
- These devices may not be labeled as a treatment or a cure for any type of wound.
The labeling claims listed above would be considered a major modification in the intended use of the devices and would require a premarket notification submission (21 CFR 807.81). The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practices, labeling, and prohibitions against misbranding and adulteration.
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Page 2 - Roberto Fiorentini, M.D.
If your devices are classified (see above) into either class II (Special Controls) or class III (Premarket Approval) they may be subject to such additional controls. Existing major regulations affecting your devices can be found in the Code of Federal Regulations (CFR), Title 21, Parts 800 to 895. A substantially equivalent determination assumes compliance with the Good Manufacturing Practices (GMP) for Medical Devices: General GMP regulation (21 CFR Part 820) and that, through periodic GMP inspections, the Food and Drug Administration (FDA) will verify such assumptions. Failure to comply with the GMP regulation may result in regulatory action. In addition, FDA may publish further announcements concerning your devices in the Federal Register. Please note: this response to your premarket notification submission does not affect any obligation you might have under sections 531 through 542 of the Act for devices under the Electronic Product Radiation Control provisions, or other Federal laws or regulations.
This letter will allow you to begin marketing your devices as described in your 510(k) premarket notification. The FDA finding of substantial equivalence of your devices to a legally marketed predicate device results in a classification for your devices and thus, permits your devices to proceed to the market.
If you desire specific advice for your devices on our labeling regulation (21 CFR Part 801 and additionally 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4595. Additionally, for questions on the promotion and advertising of your devices, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers Assistance at its toll-free number (800) 638-2041 or 301-443-6597 or at its internet address http://www.fda.gov/cdrh/dsmamain.html.
Sincerely yours,
Celia M. Witten, Ph.D., M.D.
Celia M. Witten, Ph.D., M.D. Director Division of General and Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosures -----------------------
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fidia Pharmaceutical Corporation
July 1, 1998
2. INDICATIONS FOR USE
510(k) Number (if known): K973721
BIONECT® Hydrogel Gauze Pads Device Name:
Indications for Use:
BIONECT® Hydrogel Gauze Pads are indicated for the dressing and management of partial to full thickness dermal ulcers (pressure sores, venous stasis ulcers, arterial ulcers, diabetic ulcers), wounds including cuts, abrasions, donor sites, and post-operative incisions, irritations of the skin, and first and second degree burns.
V prescription
celles
Prescription Use _ (Per 21 CFR 801.109)
N/A