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510(k) Data Aggregation

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    Applicant Name (Manufacturer) :

    Anexa Biomedical, Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    For Over-the-Counter Use: For moistening absorbent wound dressings and cleaning minor cuts, minor burns, superficial abrasions and minor irritations of the skin.

    For Prescription Use: For moistening absorbent wound dressings and for moistening, debriding and cleaning acute and chronic dermal lesions, such as stage I-IV pressure ulcers, diabetic ulcers, foot ulcers, post-surgical wounds, first and second degree burns, cuts, abrasions and minor skin irritations and for device irrigation.

    Device Description

    The Sterile Water and Sterile Normal Saline devices are wound and device cleaning solutions that are intended for moistening and debriding of dermal wounds and for device irrigation. The solution is either sterile water or sterile normal saline for irrigation and meets the requirements of USP. The devices are offered in 100mL, 250mL, and 500mL bottles, and 120mL cups.

    AI/ML Overview

    The provided document describes a 510(k) premarket notification for the "Anexa Wound Flush, Sterile Water and Sterile Normal Saline" device. This is a medical device clearance, not an AI/ML device approval, therefore, many of the requested criteria related to AI/ML device evaluation are not applicable.

    Based on the information provided in the document:

    1. Table of acceptance criteria and the reported device performance:

    Acceptance Criteria CategorySpecific Criteria/Tests (as per document)Reported Device Performance
    BiocompatibilityISO 10993 standard tests for:Found to be non-cytotoxic
    - CytotoxicityFound to be non-irritating
    - IrritationFound to be non-sensitizing
    Material/Composition0.9% Sterile Saline or Sterile WaterMeets USP requirements
    No antimicrobial or other substance addedConfirmed
    Sterility(Implied by "Sterile Water" and "Sterile Normal Saline", and adherence to ISO standards like AAMI / ANSI / ISO 11137-1:2006/(R)2010 for Sterilization)Not explicitly detailed in performance column, but clearance implies compliance
    Shelf Life/StabilityASTM F1980-07 (Reapproved 2011) - Accelerated AgingNot explicitly detailed in performance column, but implied by testing
    Packaging IntegrityAATNU / ANSI/ ISO 11607-1:2006/(R)2010Not explicitly detailed in performance column, but implied by testing
    Packaging ProcessesAAMI / ANSI / ISO 11607-2:2006/(R)2010Not explicitly detailed in performance column, but implied by testing
    Biocontamination ControlAAMI / ANSI / ISO 11737-1:2006 (R)2011 (Sterilization of medical devices — Microbiological methods — Part 1: Determination of a population of microorganisms on products)Not explicitly detailed in performance column, but implied by testing
    Bacterial Endotoxins TestingAAMI / ANSI / ISO 11737-2:2009/(R)2014 (Sterilization of medical devices — Microbiological methods — Part 2: Tests of sterility performed in the definition, validation and maintenance of a sterilization process)Not explicitly detailed in performance column, but implied by testing

    The document concludes that "Sterile Water and Sterile Normal Saline perform at least as well as the predicates' devices" and are "substantially equivalent" based on these comparisons and tests.

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective):

    This document does not specify a "test set" in the context of an AI/ML algorithm. The tests conducted (biocompatibility, sterility, etc.) are standard material and device performance tests, not AI model evaluations. Therefore, information about sample size, country of origin, or retrospective/prospective nature of data for an AI/ML 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 (e.g. radiologist with 10 years of experience):

    Not applicable. This device is not an AI/ML algorithm that requires expert-established ground truth for a test set.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:

    Not applicable. This device is not an AI/ML algorithm that requires an adjudication method for a test set.

    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 wound flush solution, not an AI system.

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

    Not applicable. This device is a wound flush solution, not an AI algorithm.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc):

    Not applicable. The "ground truth" for this device would be its chemical composition, sterility, and biocompatibility, which are verified through laboratory testing against established physical, chemical, and biological standards (e.g., USP , ISO 10993 standards). This is not equivalent to ground truth in the context of AI/ML.

    8. The sample size for the training set:

    Not applicable. This device is a wound flush solution, 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 training set for an AI/ML algorithm, no ground truth needs to be established for it.

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    K Number
    K161658
    Date Cleared
    2016-09-14

    (90 days)

    Product Code
    Regulation Number
    N/A
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    ANEXA BIOMEDICAL, INC.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    For moistening of absorbent wound dressings and irrigation to remove loose debris and dirt from the wound.

    Device Description

    The Wound Flush, Sterile Water & Sterile Normal Saline device can be used 1) for moistening a dry sterile dressing for wound cleansing and 2) irrigation to remove loose debris and dirt from the wound. The mechanical action of fluid moving across the wound provides the mechanism of action and aids in the removal of loose foreign material such as dirt and debris. The product has a shelf life of 2-years.

    The solution is available as sterile saline for irrigation and is gamma sterilized. The subject device is offered in various bottle sizes of 100ml, 250ml, and 500ml and cup sizes of 120ml.

    AI/ML Overview

    Here's an analysis of the provided text regarding the acceptance criteria and study information for the Anexa Wound Flush, Sterile Water & Sterile Normal Saline device:

    1. Table of Acceptance Criteria and Reported Device Performance

    The provided document does not explicitly present a table of "acceptance criteria" in the traditional sense of performance metrics for a medical device (e.g., sensitivity, specificity, accuracy). Instead, it describes a substantial equivalence (SE) determination based on a comparison to a predicate device and a series of non-clinical tests. The "performance" is demonstrated by passing these tests and showing similarity to the predicate.

    Acceptance Criteria (Demonstrated by)Reported Device Performance (as stated in the document)
    Substantial Equivalence to Predicate Device (K083042)The device is substantially equivalent to the legally marketed predicate device (Nurse Assist, Inc. Wound Flush, Sterile Water & Sterile Normal Saline). Similarities noted include:
    • Same Regulatory Product Code (FRO)
    • Same Classification (Pre-amendment)
    • Similar Indications for Use
    • Similar Principle of Operation (mechanical action removing foreign objects)
    • Same Chemical Composition (0.9% Sterile Saline or Sterile Water; no additives)
    • Uses same materials and container designs
    • Same method of sterilization (gamma) |
      | Biocompatibility Testing | Anexa conducted and passed the following biocompatibility tests:
    • Cytotoxicity
    • Dermal Sensitization
    • Intracutaneous test (direct injection)
    • Acute Systemic Toxicity
    • Bacterial Endotoxin Test |
      | Compliance with Recognized Standards (Non-Clinical Testing) | Anexa conducted and passed tests according to the following standards:
    • ASTM F1980-07 (Reapproved 2011)
    • AAMI/ANSI/ISO 11607-1:2006/(R)2010
    • AAMI/ANSI/ISO 11607-2:2006/(R)2010
    • AAMI / ANSI / ISO 11137-1:2006/(R)2010
    • AAMI / ANSI / ISO 11137-2:2013
    • AAMI / ANSI / ISO 11737-1:2006 (R)2011
    • AAMI / ANSI / ISO 11737-2:2009/(R)2014
    • AAMI/ANSI/ISO 10993-1:2009/(R) 2013
    • AAMI / ANSI/ISO 10993-5:2009/(R) 2014
    • ISO 10993-10 Third Edition 2010-08-01
    • AAMI/ANSI/ISO 10993-11:2006/(R)2010
    • AAMI TIR 22:2007
    • AAMI TIR 33:2005
    • AAMI/ANSI/ISO TIR 13004:2013 |
      | Device Stability / Shelf-life | Product has a shelf life of 2-years. This implies successful testing to demonstrate this. |

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

    The document describes non-clinical testing and a comparison to a predicate device, not a "test set" in the context of clinical performance evaluation (e.g., for an AI algorithm). The sample sizes for the specific non-clinical tests (biocompatibility, shelf-life, etc.) are not provided in this summary. The data provenance is also not explicitly stated beyond being part of Anexa Biomedical, Inc.'s internal testing records.

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

    This information is not applicable as the document describes non-clinical testing for a wound flush solution, not a diagnostic device requiring expert interpretation or ground truth establishment in a clinical setting.

    4. Adjudication Method for the Test Set

    This information is not applicable for the same reasons as #3.

    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

    This information is not applicable. The device is a wound flush solution, not an AI-powered diagnostic tool. An MRMC study is explicitly designed for evaluating the impact of AI on human reader performance.

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

    This information is not applicable. The device is a wound flush solution, not an algorithm.

    7. The Type of Ground Truth Used

    For the non-clinical tests (biocompatibility, sterility, shelf-life), the "ground truth" would be established by:

    • Reference Standards/Controls: For biocompatibility, comparisons are made to established safe materials and adverse reactions are assessed.
    • Scientific Methods and Measurements: For sterility, microbiological testing to confirm absence of microorganisms. For shelf-life, stability studies measuring chemical and physical properties over time.
    • Compliance with Recognized Standards: Meeting the pass/fail criteria outlined in the referenced ASTM, AAMI/ANSI/ISO standards.

    For the substantial equivalence claim, the "ground truth" is the legally marketed predicate device and its established safety and effectiveness profile.

    8. The Sample Size for the Training Set

    This information is not applicable as the device is not an AI algorithm requiring a training set.

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

    This information is not applicable for the same reasons as #8.

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