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510(k) Data Aggregation

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use
    Device Description
    AI/ML Overview
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    K Number
    K230694
    Manufacturer
    Date Cleared
    2023-04-13

    (31 days)

    Product Code
    Regulation Number
    876.1310
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The NaviCam Stomach Capsule is intended for visualization of the stomach of adults (>/=22 years) with BMI < 38. The system can be used in clinics and hospitals, including ER settings.

    The NaviCam Tether is an accessory of the NaviCam Stomach Capsule. It is intended to aid the Capsule for visualizing the esophagus (not magnetically maneuvered) prior to the Capsule's release into the stomach capsule endoscopy (MCCE) procedure.

    Device Description

    The NaviCam Xpress Stomach System is a novel endoscopic capsule imaging system intended to obtain images of the stomach. It differs from passive capsule endoscopy systems in that it uses magnetic fields to allow the position of the capsule within the stomach to be controlled by an operator.

    The NaviCam Xpress Stomach System includes the following key components:

      1. Ingestible capsule (CP-US-7005) for obtaining images.
      1. Data recorder (MC-US-1006) for logging image data.
      1. Locator (SB-US-2006) for turning on the capsule and for determining if the capsule is still in the body.
      1. Controller, NaviEC-2000 (MC-US-1002) with the NaviCtrl software that allows the navigation of the capsule within the stomach.
      1. ESView software for review of the images obtained by the capsule and generating reports.
    • Optional Accessory: NaviCam Tether (ES-US-7005) for aiding the capsule in visualizing 6. the esophagus.
    AI/ML Overview

    This document is a 510(k) summary for a software addition, not a comprehensive clinical study report. Therefore, much of the requested information about clinical performance, ground truth, and expert involvement is not present in this document.

    Here's a breakdown of what can be extracted based on the provided text:

    Device: NaviCam Xpress Stomach System (addition of GastroScan feature to NaviCtrl software)

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly list acceptance criteria in terms of specific performance metrics (e.g., sensitivity, specificity, accuracy) for the device's diagnostic capabilities. Instead, it focuses on demonstrating that the software addition does not negatively impact the existing cleared device's performance or introduce new risks. The reported "performance" is that the device "performs as intended based on the non-clinical bench testing."

    Acceptance Criteria (Implied by the submission)Reported Device Performance
    Software updates function as intendedVerified through Software Verification Testing
    Device remains safe and effective (no new risks introduced by software update)Demonstrated by Human Factors Engineering/Usability Testing/Evaluation, performance bench testing, software risk analysis, and cybersecurity FMEA risk analysis.
    No changes to existing indications for useThe device retains the same Indications for Use as the predicate device.
    No degradation in performance compared to the predicate deviceNot explicitly quantified, but implied by successful non-clinical testing.

    2. Sample Size Used for the Test Set and Data Provenance

    • Test Set Sample Size: Not specified for any performance testing related to diagnostic accuracy. The non-clinical performance and bench testing would have used specific test cases, but the number of such cases is not provided.
    • Data Provenance: The new software features were evaluated through non-clinical performance and bench testing. This is typically internal testing. No information about country of origin for this testing or whether it was retrospective or prospective is provided. The document states that "No additional Animal and clinical performance testing were conducted."

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts

    Not applicable for this submission, as no new clinical performance testing was conducted. Ground truth for previous clinical evidence (mentioned in point 9) would have been established, but details are not provided here.

    4. Adjudication Method for the Test Set

    Not applicable for this submission, as no new clinical performance testing was conducted.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    No, a MRMC comparative effectiveness study was not done for this submission. The document explicitly states "No additional clinical literature has been provided in this submission." It refers to previous clinical evidence from predicate devices but does not provide details of those studies in this document.

    6. Standalone Performance Study

    A standalone study of the algorithm's core diagnostic performance (e.g., sensitivity/specificity for detecting stomach abnormalities) was not performed as part of this specific submission. The submission focuses on the safety and efficacy of a software addition to an already cleared device. The "performance bench testing" mentioned would assess the functionality of the new software feature (GastroScan) rather than clinical diagnostic accuracy.

    7. Type of Ground Truth Used

    For this specific submission, the "ground truth" for the non-clinical performance and bench testing would be defined by the expected outcomes of the software functions and hardware interactions as specified in design documents and testing protocols. No clinical ground truth (e.g., pathology, expert consensus on patient cases) was used for this particular submission's evaluation.

    8. Sample Size for the Training Set

    No training set information is provided, as this submission is for a software feature addition to a previously cleared device. It's unlikely that machine learning model training was a primary component of this specific update.

    9. How the Ground Truth for the Training Set Was Established

    Not applicable for this submission (see point 8).

    Summary of this Submission's Focus:

    This 510(k) submission (K230694) is for a software update (GastroScan feature) to an already cleared device (NaviCam Xpress Stomach System, K203192). The primary goal of this submission is to demonstrate that this software addition does not change the indications for use, does not introduce new risks, and does not negatively impact the performance of the existing device. Therefore, the evidence focuses on non-clinical software verification, human factors, and risk analysis, rather than new clinical trials or diagnostic performance metrics. The clinical evidence for the overall system's diagnostic capabilities would have been established in previous submissions (DEN190037 and K203192).

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    K Number
    K201106
    Manufacturer
    Date Cleared
    2020-05-21

    (27 days)

    Product Code
    Regulation Number
    876.1725
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    IntraMarX 3D Radiopaque Markers is a diagnostic test indicated for assisting in the evaluation of colonic motility in patients with severe constipation, as diagnosed by a healthcare professional, but otherwise negative GI evaluations. For use in adult, IntraMarX 3D Radiopaque Markers is dispensed only by physicians to patients for oral intake.

    Device Description

    The IntraMarX 3D Radiopaque Markers can be used for the diagnosis of many Gl conditions, including chronic constipation, colonic inertia, hypomotility and outlet delay. Each of the IntraMarX 3D capsules contains 24 tiny radiopaque rings within the capsule is swallowed by the patient under the direction of physician. As this capsule moves through the digestive system, the capsule shell will dissolve and leave the rings in the GI tract of the patient; which will show up later during an x-ray scan. Five days after swallowing the capsule, a single x-ray scan of the abdomen will be taken to see the location of the rings and how many are left in the Gl tract of the patient. The physician will make evaluations based on the rings remaining and make a diagnosis of GI conditions of the patient.

    AI/ML Overview

    Here's an analysis of the provided text regarding the acceptance criteria and study for the IntraMarX 3D Radiopaque Marker, formatted as requested:

    1. Table of Acceptance Criteria and Reported Device Performance

    The provided text describes a 510(k) submission, which primarily focuses on demonstrating substantial equivalence to a predicate device rather than setting new acceptance criteria for novel performance claims. The "acceptance criteria" here are therefore inferred from the comparison of characteristics and the non-clinical performance data, which aim to show the device meets existing standards and is as safe and effective as the predicate.

    Acceptance Criterion (Inferred from Substantial Equivalence and Standards)Reported Device Performance (IntraMarX 3D)
    Biocompatibility:
    - Absence of CytotoxicityPass (per ISO 10993-5)
    - Acceptable Implantation ResponsePass (per ISO 10993-6)
    - Absence of Intracutaneous Reactivity/SensitizationPass (per ISO 10993-10)
    - Absence of Material-Mediated Pyrogenicity/Systemic/Subacute ToxicityPass (per ISO 10993-11)
    Radiopacity:Pass (per ASTM F640-12)
    Functional Equivalence:- Same Indications for Use as predicate.- Same Mechanism of Action (oral intake).- Same Capsule Material (HPMC).- Similar Radiopaque Marker Material (Thermoplastic Elastomer 50% for subject vs. Polyvinyl Chloride 45-46% for predicate, both with Barium Sulfate).- Same Sterile status (No), Single-Use (Yes), Shelf Life (2 Years).- Differences in capsule packaging and image area diameter are acknowledged but not stated to impact safety/effectiveness as they don't raise new questions.
    Safety and Effectiveness:Performance testing demonstrated the IntraMarX 3D is as safe and effective as the predicate device.

    2. Sample Size Used for the Test Set and Data Provenance

    The document does not specify a sample size for a test set in the context of clinical performance or diagnostic accuracy. The studies mentioned are primarily non-clinical (biocompatibility, radiopacity). The data provenance is generally not explicitly stated beyond implying these are results from tests conducted by the manufacturer, Ankon Medical Technologies (Shanghai) Co., Ltd., to support substantial equivalence. It does not refer to patient data or clinical studies.

    3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of Those Experts

    This information is not provided in the document. The studies mentioned are non-clinical hardware/material tests rather than diagnostic performance studies requiring expert ground truth for interpretation.

    4. Adjudication Method for the Test Set

    This information is not provided as the document does not describe a clinical study or a test set requiring adjudication.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and Effect Size

    A Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not conducted or described in this submission. The document focuses on showing substantial equivalence of a physical medical device (radiopaque markers) to a predicate device, based on material properties and non-clinical performance, not on the diagnostic accuracy of an AI algorithm or its impact on human reader performance.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

    This device, the "IntraMarX 3D Radiopaque Marker," is a physical diagnostic aid. It is not an AI algorithm and therefore, no standalone algorithm performance study was mentioned or would be applicable in this context. The "diagnosis" is made by a physician based on the visualization of the markers on an X-ray.

    7. The Type of Ground Truth Used

    For the non-clinical tests (biocompatibility, radiopacity), the "ground truth" implicitly comes from the established pass/fail criteria of the referenced international and national standards (ISO, ASTM). For example, a material either passes or fails the cytotoxicity test based on the standard's definition. There is no mention of expert consensus, pathology, or outcomes data as "ground truth" for the device, as it's not a diagnostic algorithm being evaluated for accuracy against such benchmarks.

    8. The Sample Size for the Training Set

    This information is not applicable/not provided. The IntraMarX 3D Radiopaque Marker is a physical device, not an AI algorithm that requires a training set.

    9. How the Ground Truth for the Training Set Was Established

    This information is not applicable/not provided for the same reason as above.

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    K Number
    K191087
    Manufacturer
    Date Cleared
    2019-12-18

    (238 days)

    Product Code
    Regulation Number
    876.1725
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    IntraMarX Radiopaque Markers is a diagnostic test indicated for assisting in the evaluation of colonic motility in patients with severe constipation, as diagnosed by a healthcare professional, but otherwise negative GI evaluations. For use in adult only, IntraMarX Radiopaque Markers is dispensed by physicians to patients for oral intake.

    Device Description

    The IntraMarX capsule can be used for the diagnosis of many GI conditions, including chronic constipation, colonic inertia, hypomotility and outlet delay. Each of the IntraMarX capsules contains 24 tiny radiopaque rings within the capsule shell. The capsule is swallowed by the direction of physician. As this capsule moves through the digestive system, the capsule shell will dissolve and leave the rings in the GI tract of the patient; which will show up later during an X-ray scan. Five days after swallowing the capsule, a single scan of the abdomen will be taken to see the location of the rings and how many are left in the GI tract of the patient. The physician will make evaluations based on the rings remaining and make a diagnosis of GI conditions of the patient.

    AI/ML Overview

    The provided text describes the submission for FDA clearance of the "IntraMarX Radiopaque Markers" device (K191087) and compares it to a predicate device, the "SITZMARKS Capsule" (K181750).

    However, the document does not contain specific acceptance criteria for "device performance" in terms of clinical outcomes, nor does it present a detailed study that proves the device meets such criteria in a comparative effectiveness manner (e.g., against human readers or other diagnostic methods). Instead, it focuses on demonstrating substantial equivalence to a predicate device through non-clinical performance data (material safety, physical properties, etc.).

    Here's an analysis based on the available information, noting what's present and what's missing:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly state quantitative acceptance criteria for clinical performance (e.g., sensitivity, specificity, accuracy in diagnosing colonic motility issues) and thus does not report device performance against such criteria. The reported "performance" falls under non-clinical testing for safety and basic functionality.

    Acceptance Criteria (Internal/Standard)Reported Device Performance (Non-Clinical)
    Cytotoxicity per ISO 10993-5Pass
    Implantation per ISO 10993-6Pass
    Sensitization per ISO 10993-10Pass
    Systemic Toxicity per ISO 10993-11Pass
    Sample Prep & Reference Materials per ISO 10993-12Pass
    Microbial Limit/Burden per USP 42-NF37 <61>Acceptable
    Microbial Limit/Burden per USP 42-NF37 <62>Acceptable
    Accelerated Aging per ASTM F1980-16Pass
    Packaging & Transportation per ASTM D4332-14Pass
    Packaging & Transportation per ASTM D4169-16Pass
    Extraction of Medical Plastics per ASTM F619-14Pass
    Radiopacity per ASTM F640-12Pass
    Heavy metal testing per ISO 8536-4Pass
    Heavy metal testing per ISO 3826-1Pass
    Validation Of Analytical Procedures per ICH Q2 (R1)Pass
    Barium ion precipitation (customer protocol)Pass

    2. Sample size used for the test set and the data provenance

    The document does not describe a clinical "test set" in the context of diagnostic accuracy for colonic motility. All listed tests are non-clinical, focusing on material and physical properties of the device itself. Therefore, information on sample size and data provenance (country, retrospective/prospective) related to a clinical test set is not provided.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    Not applicable. As no clinical test set for diagnostic performance is described, there's no mention of experts establishing ground truth for such a set.

    4. Adjudication method for the test set

    Not applicable. No clinical test set needing adjudication is described.

    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 device is a passive radiopaque marker, not an AI software. Therefore, an MRMC study related to AI assistance is not relevant or described.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    Not applicable. This is a physical medical device, not an algorithm.

    7. The type of ground truth used

    For the non-clinical tests, the "ground truth" is defined by the specific parameters and requirements of the cited ISO, ASTM, USP, and ICH standards/protocols. For example:

    • Cytotoxicity: Ground truth is whether cell viability falls below a certain threshold when exposed to device materials.
    • Radiopacity: Ground truth is whether the markers are visible on X-ray according to the specified standard.
    • Heavy metal testing: Ground truth is whether heavy metal levels are within established safe limits.

    8. The sample size for the training set

    Not applicable. This device is not an AI algorithm that requires a training set.

    9. How the ground truth for the training set was established

    Not applicable. This device is not an AI algorithm.


    Summary of Device and Approval Context:

    The "IntraMarX Radiopaque Markers" device is a diagnostic aid consisting of capsules containing radiopaque rings. Patients swallow the capsule, and after five days, an X-ray of the abdomen is taken to observe the remaining rings in the GI tract. Physicians interpret the location and number of rings to evaluate colonic motility in patients with severe constipation.

    The FDA clearance (K191087) is based on demonstrating substantial equivalence to a previously cleared predicate device, the "SITZMARKS Capsule" (K181750). This means the applicant showed that their device has the same intended use and similar technological characteristics, and that any differences do not raise new questions of safety or effectiveness. The core of this demonstration relies entirely on the non-clinical performance data listed above, proving the physical and biological safety of the marker material and its radiopacity. There is no mention of new clinical studies on diagnostic accuracy for this submission. The effectiveness is presumed to be equivalent to the predicate device, which itself would have had to demonstrate effectiveness.

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