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510(k) Data Aggregation
(72 days)
The AeroForm® Tissue Expander System, Smooth is used for soft tissue expansion in breast reconstruction following mastectomy, for the treatment of underdeveloped breasts and for the treatment of soft tissue deformities in the breast.
The AeroForm® Tissue Expander, Smooth is intended for temporary subcutaneous or submuscular implantation and is not intended for use beyond six months
The AeroForm Tissue Expander System, Smooth is a sterile, temporary implant for breast reconstruction. This device is comprised of an implantable tissue expander (Expander), a remote control (Controller), and a Master Key. The AeroForm Tissue Expander, Smooth is constructed of an outer silicone shell and an inner gas barrier (bag) with an internal reservoir of compressed Carbon Dioxide (CO2) gas. The CO2 gas is released within the Expander by using the remote control (Controller), resulting in gradual expansion of the Expander. In a typical, two-stage breast reconstruction, a tissue expander device is placed under the pectoralis major muscle and remaining skin following a mastectomy procedure. The Expander is gradually expanded over time through the release of carbon dioxide, causing the overlying skin and muscle to stretch. When adequate tissue coverage is achieved, the expansion device is removed and replaced with a breast implant.
This document describes the premarket notification for the AeroForm Tissue Expander System, Smooth. The "acceptance criteria" and "device performance" in this context refer to the mechanical and performance testing conducted to demonstrate substantial equivalence to a predicate device, rather than the performance of an AI/ML model.
Here's an analysis based on the provided text:
Acceptance Criteria and Reported Device Performance
The acceptance criteria for this device are based on demonstrating that the modified device (smooth shell) meets the design input requirements and performs equivalently to the predicate device (textured shell). The study focuses on mechanical performance testing as outlined in ASTM F1441 and internal design verification and validation testing.
Table of Acceptance Criteria and Reported Device Performance:
Acceptance Criteria Category | Specific Tests/Requirements | Reported Device Performance |
---|---|---|
Mechanical Performance | - Simulated Use Testing | All mechanical performance testing results met pre-determined acceptance criteria |
- Endurance / Stress Tests | All mechanical performance testing results met pre-determined acceptance criteria | |
- Dimensional Measurement | All mechanical performance testing results met pre-determined acceptance criteria | |
- Shell Tensile Set | All mechanical performance testing results met pre-determined acceptance criteria | |
- Shell Break Force | All mechanical performance testing results met pre-determined acceptance criteria | |
- Non-Critical Fused or Adhered Joints | All mechanical performance testing results met pre-determined acceptance criteria | |
Standard Compliance | - Requirements of ASTM F1441, Standard Specification for Soft Tissue Expanders | The device met the requirements of the ASTM F1441 standard. |
Design Control | - Internal company controls and design control procedures for safety and intended use | Design verification and validation testing criteria were met. |
Risk Assessment | - No new harms or risks introduced compared to predicate | No new risks were introduced as a result of the device modifications. |
Substantial Equivalence | - Identical intended use, indications for use, operating principles, performance, and technological characteristics (except shell texture) | Demonstrated substantial equivalence to the predicate device. |
Since this submission is for a medical device (tissue expander) and not an AI/ML product, the following points regarding AI/ML study design are not applicable to this document. The information provided does not describe an AI/ML study.
- Sample size used for the test set and the data provenance: Not applicable; no AI/ML test set is described.
- Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable; ground truth establishment for an AI/ML model is not described.
- Adjudication method (e.g., 2+1, 3+1, none) for the test set: Not applicable; no expert adjudication for an AI/ML test set.
- 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; no AI assistance for human readers is described.
- If a standalone (i.e., algorithm only without human-in-the-loop performance) was done: Not applicable; this device is not an algorithm.
- The type of ground truth used (expert consensus, pathology, outcomes data, etc.): Not applicable; no ground truth for an AI/ML model. The "ground truth" for this device's performance is derived from standardized mechanical testing and design verification.
- The sample size for the training set: Not applicable; no AI/ML training set is described.
- How the ground truth for the training set was established: Not applicable; no AI/ML training set is described.
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(84 days)
The AeroForm® Tissue Expander System is used for soft tissue expansion in breast reconstruction following mastectorny. for the treatment of underdeveloped breasts, and for the treatment of soft tissue deformities in the breast.
The AeroForm® Tissue Expander is intended for temporary subcutaneous or submuscular implantation and is not intended for use beyond 6 months.
The AeroForm Tissue Expander System (AeroForm System) is a sterile temporary implant for breast reconstruction and is comprised of a sterile, implantable tissue expander), a remote control (Controller), and a Master Key. The AeroForm Tissue Expander is a comprised of an outer textured silicone shell, an inner gas barrier (bag), with an internal reservoir of compressed Carbon Dioxide (CO2) gas, which is released within the Expander by using the remote control (Controller), resulting in gradual expansion of the Expander. In a typical, twostage breast reconstruction, a tissue expander device is placed under the pectoralis major muscle and remaining skin following a mastectomy procedure. The Expander is gradually expanded over time through the release of carbon dioxide, causing the overlying skin and muscle to stretch. When adequate tissue coverage is achieved, the expansion device is removed and replaced with a breast implant.
This document describes the regulatory submission for the AeroForm Tissue Expander System. It is not an AI/ML device, so many of the requested fields are not applicable. I will fill in the applicable information about the device's acceptance criteria and the studies performed.
1. A table of acceptance criteria and the reported device performance
Test | Acceptance Criteria | Reported Device Performance |
---|---|---|
Mechanical Performance Testing | ||
Endurance / Stress Tests (cycle, impact, elongation, sustained pressure) | Meet requirements of ASTM F1441 and pre-determined criteria | All results met pre-determined acceptance criteria and ASTM standard requirements |
Break Force | Meet requirements of ASTM F1441 and pre-determined criteria | All results met pre-determined acceptance criteria |
Fused or Adhered Joint Testing | Meet requirements of ASTM F1441 and pre-determined criteria | All results met pre-determined acceptance criteria |
Overexpansion | Meet requirements of ASTM F1441 and pre-determined criteria | All results met pre-determined acceptance criteria |
Sterilization and Package Integrity Testing | Package remains intact after climatic conditioning, gross leak, and seal strength testing | Demonstrates package remains intact |
Software Testing | Compliant with EN 62304 and applicable US FDA guidance documents | Unit, System, and Regression Testing performed, compliant |
Biocompatibility Testing (EN ISO 10993) | All tests (Genotoxicity, Cytotoxicity, Sensitization, Irritation, Acute Systemic Toxicity, Sub-chronic Toxicity, Chronic Toxicity, Implantation) pass requirements | All tests passed the requirements of EN ISO 10993, demonstrating biological safety |
Electrical Safety & EMC Testing | Meet applicable standards | Performed (details not provided in summary) |
Shelf Life Testing | Device integrity maintained over specified shelf life | Performed (details not provided in summary) |
Human Factors Evaluation | Device is safe and effective for intended users and use environments | Performed (details not provided in summary) |
2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
The document primarily describes pre-clinical and verification/validation testing for a physical medical device (tissue expander). There is no mention of a "test set" in the context of an AI/ML device employing a dataset for evaluation. The "test set" for mechanical and biological performance refers to the physical devices and materials tested. The provenance of these tests are standard laboratory and engineering tests; no data provenance from patient populations is mentioned for these specific tests in the provided text.
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. This is not an AI/ML device relying on expert-annotated ground truth for a test set. The "ground truth" for the performance attributes is established through recognized international standards (e.g., ASTM F1441, EN ISO 10993) and internal engineering specifications, executed and assessed by qualified engineering and scientific personnel.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. As this is not an AI/ML device, there is no expert adjudication of outputs from an algorithm. Results are assessed against pre-defined quantitative and qualitative acceptance criteria from recognized standards and internal specifications.
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 is not an AI/ML device, and no MRMC study with human readers or AI assistance was conducted or mentioned.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This is a physical medical device (tissue expander) with a software component for control; it is not a standalone algorithm. The software testing mentioned is for the functionality and compliance of the embedded software, not for a diagnostic or predictive AI algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
The "ground truth" for this device's performance evaluation lies in:
- Mechanical Integrity/Performance: Compliance with ASTM F1441 standards and internal engineering design specifications.
- Biocompatibility: Conformance to EN ISO 10993 standards.
- Software: Compliance with EN 62304 and FDA guidance for software development (functional correctness, safety).
- Sterilization/Shelf Life: Compliance with applicable standards for sterility, package integrity, and stability over time.
These are established through standardized testing methodologies rather than expert consensus on medical images or pathology.
8. The sample size for the training set
Not applicable. This is not an AI/ML device that requires a training set.
9. How the ground truth for the training set was established
Not applicable. This is not an AI/ML device that requires a training set.
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