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510(k) Data Aggregation

    K Number
    K202443
    Manufacturer
    Date Cleared
    2021-03-11

    (197 days)

    Product Code
    Regulation Number
    878.5040
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    BSL Co., Ltd

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

    The Smart Kit is disposable and is indicated for autologous fat transfer is also technically called as autologous fat grafting or reinjection of concentrated adipose-tissue into the recipient body areas. The Smart kit can be used for concentration and transfer of homogenous adipose tissues with legally marketed lipoplasty system when the concentrated and homogenous fat tissue is re-injected into the recipient body areas of the same patient autologously. This device is intended for autologous fat transfer. The Smart Kit is intended for use in the following surgical specialties when the concentration of harvested adipose tissue is desired. Neurosurgery / Gastrointestinal Surgery / General surgery / Orthopedic Surgery / Gynecological Surgery / Thoracic Surgery / Laparoscopic Surgery / Arthroscopic Surgery / Plastic and reconstructive surgery

    Device Description

    The fat harvested by liposuction, called as lipoaspirates, contains fat tissues, bloody impurities and tumescent solution. The harvested lipoaspirates are not appropriate for autologous fat transfer without removal of the bloody impurities and tumescent solution containing anesthetic agent, anti-coagulant agent, antibiotics and etc. In addition, the harvested fat tissues are not homogeneous and contain bigger fibrotic tissues. Smart kit is designed and developed for harvest of a variety of sizes of homogeneous adipose tissues in a closed sterile way for autologous fat transfer surgical technique. Using a separate cannula, Manual handheld suction unit, and plunger, aspirate the adipose tissue or fill the syringe with adipose tissue and centrifuge with the cap in front of the syringe. Centrifuged adipose tissue is divided into blood and fluid layer, adipose tissue layer, and free oil layer. Those are located at the bottom of the piston. After centrifugation, the plunger is pushed unlocked to the piston and free oil is drained to the outside of the syringe as the free oil moves to the top of the piston through the hole at the front of the piston. Open the cap in front of the syringe, lock the plunger completely and push it, the blood and fluid layers at the bottom of the adipose tissue will be drained and only the adipose tissue will remain inside the syringe. Depending on the syringe capacity, there are three types of piston: 10ml, 20ml, 60ml. The built-in filter adapter consists of a filter for separating the fiber and adipose tissue to facilitate movement through needles of lumpy adipose tissues and a body for receiving it. Connect the syringe containing the adipose tissue and the empty syringe to the connection parts at both ends of the built-in filter adapter and push the plunger of the syringe containing the adipose tissue to allow the adipose tissue to pass through the filter. Fiber and adipose tissues larger than the pore size is filtered, and adipose tissue smaller than the pore size of the filter is passed through to separate adipose tissue.

    AI/ML Overview

    The provided text describes a medical device called "Smart Kit" and its performance testing for FDA 510(k) clearance, asserting its substantial equivalence to a predicate device. However, the document does not contain details of a study proving the device meets acceptance criteria related to a specific AI algorithm or its performance in a clinical setting.

    The "Performance Testing" section focuses on physical and chemical properties of the device itself (e.g., appearance, water tightness, material compatibility, sterilization). The "Cell Viability Test" is the most relevant performance metric that could be interpreted as a clinical outcome, but it is a general statement about maintaining cell viability for autologous fat transfer.

    Therefore, most of the requested information about AI model performance, sample sizes for test/training sets, expert adjudication, MRMC studies, and standalone AI performance cannot be extracted from this document, as it describes a physical medical device, not an AI algorithm.

    Below is a table of acceptance criteria and reported device performance from the document. The remaining requested information is largely not applicable or not provided in the context of this device's clearance.


    Acceptance Criteria and Reported Device Performance (Smart Kit)

    Test ItemTest RequirementReported Device Performance
    AppearanceThere should be no visible scratches, damage, or foreign materialMet acceptance criteria for all tests performed.
    MeasurementWhen measuring with Vernier calipers, according to the dimension of "shape and structure" part, the stated should be within ± 5%Met acceptance criteria for all tests performed.
    Water TightnessWhen tested according to the test method, there should be no leakageMet acceptance criteria for all tests performed.
    Centrifugation Compatibility Test (Leakage)When tested according to the test method, it should be aspirated to the maximum capacity without leakageMet acceptance criteria for all tests performed.
    Cell Viability TestThe finally filtered adipose tissues for autologous fat transfer should maintain at least over 85 % of the cell viability.Met acceptance criteria for all tests performed.
    Pore SizeWhen measuring with Vernier calipers, according to the dimension of 'shape and structure' part, the stated should be within ± 15 %.Met acceptance criteria for all tests performed.
    pHDifference of pH $\leq$ 1.5Met acceptance criteria for all tests performed.
    Potassium permanganate reducing substancesDifference of the consumption $\leq$ 2.0 mLMet acceptance criteria for all tests performed.
    Evaporating residueDifference of residues $\leq$ 1.0mgMet acceptance criteria for all tests performed.
    Heavy MetalsThe test solution should not be darker than blank solution.Met acceptance criteria for all tests performed.
    Ultraviolet-visibleDifference of the maximum absorbance at (250~350) nm $\leq$ 0.1Met acceptance criteria for all tests performed.

    Study Details (Information Not Provided or Not Applicable to AI Performance)

    1. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective):
      • Not provided. The document describes performance testing for a physical device, not an AI algorithm evaluated on a clinical test set.
    2. 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/Not provided. This information is relevant for AI validation studies involving expert annotations, which is not the subject of this document. The 'Cell Viability Test' implies a laboratory-based assessment, not expert interpretation.
    3. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
      • Not applicable/Not provided. This pertains to expert review in AI studies.
    4. 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:
      • No. This is not a study about AI assistance or human reader performance.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
      • Not applicable. The "Smart Kit" is a physical device for autologous fat transfer, not a standalone algorithm.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
      • For the performance tests listed, the "ground truth" would be established by laboratory measurements, physicochemical standards, and biological assays (e.g., cell viability assays). It is not expert consensus, pathology, or outcomes data in the typical sense of AI/clinical studies.
    7. The sample size for the training set:
      • Not applicable/Not provided. The document describes a physical medical device. There is no mention of an AI algorithm requiring a training set.
    8. How the ground truth for the training set was established:
      • Not applicable/Not provided. No training set is mentioned as there is no AI algorithm being validated.
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    K Number
    K172717
    Manufacturer
    Date Cleared
    2018-05-25

    (259 days)

    Product Code
    Regulation Number
    878.5040
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    BSL Co.

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

    The Automatic Tissue Processing Unit is used in medical procedures involving the harvesting and transferring of autologous adipose tissue. The Automatic Tissue Processing Unit is used for concentrating adipose tissue harvested with a legally marketed lipoplasty system. The Automatic Tissue Processing Unit is intended for use in the following surgical specialties when the concentration of harvested adipose tissue is desired.

    • Neurosurgery Gastrointestinal Surgery Urological Surgery Plastic and Reconstructive Surgery General Surgery Orthopedic Surgery Gynecological Surgery Thoracic Surgery Laparoscopic Surgery Arthoscopic Surgery
    Device Description

    The fat harvested by liposuction, called as lipoaspirates, contains fat tissues, bloody impurities and tumescent solution. The harvested lipoaspirates are not appropriate for autologous fat transfer without removal of the bloody impurities and tumescent solution containing anesthetic agent, anti-coagulant agent, antibiotics etc. In addition, the harvested fat tissues are not homogenous and contain uneven fibrotic tissues. So, for the purpose of in autologous fat transfer surgical technique. ACPU kit is designed and developed for harvest of the fine homologous adipose tissue in a sterile and closed way. ACPU needs to be centrifuged by using exclusive centrifuge (ACS Combo-A-Centrifuge/Product code: JQC) and the kits are single-use only.

    AI/ML Overview

    Here's an analysis of the provided FDA 510(k) summary regarding the Automatic Tissue Processing Unit, structuring the information according to your requested points:

    Device: Automatic Tissue Processing Unit (ACPU-100/ACPU-200)

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria are implicitly defined by the successful results of the specified tests, indicating that the device meets predetermined standards for each parameter. The "Requirements" column serves as the acceptance criteria.

    Test ItemAcceptance Criteria (Requirements)Reported Device Performance (Results)
    AppearanceNo defects, flaws, breakage, or contamination of foreign objects.Pass
    MeasurementWithin ±5% of stated dimensions.Pass
    LeakageNo leakage.Pass
    Residuals of cleaning liquidLess than 20 ml.Pass
    PackagingAdhesive strength not less than 3N (ASTM F-88).Pass
    Nucleated Cell CountMore than 3.86x10^5 per ml of adipose tissue."3.86 over" - Implies greater than or equal to, thus meeting the criteria.
    Nucleated Cell ViabilityMore than 71.4%."71.4% over" - Implies greater than or equal to, thus meeting the criteria.
    Extraction test:
    Appearance (sample prep extract)No foreign material.Pass
    pH (Difference)≤ 1.5Pass
    KMnO4 Reducing agents (Difference in titres)≤ 2.0 mlPass
    Evaporating residue (Difference in extractables)≤ 1.0 mgPass
    Heavy metal (as Pb)Not darker than standard solution.Pass
    UV-vis Spectrum (Difference in absorbance 250nm-350nm)≤ 0.1Pass
    Biocompatibility Tests:
    Cytotoxicity (ISO 10993-5)Pass (implicitly defined by standard)Pass
    Skin Sensitization (ISO 10993-10)Pass (implicitly defined by standard)Pass
    Intracutaneous Reactivity Test (ISO 10993-10)Pass (implicitly defined by standard)Pass
    Acute Systemic Toxicity Test (ISO 10993-11)Pass (implicitly defined by standard)Pass
    Pyrogen Test (ISO 10993-11, Annex F)Pass (implicitly defined by standard)Pass
    Hemolysis Test (ISO 10993-4)Pass (implicitly defined by standard)Pass

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

    The document does not explicitly state the sample size for the "bench tests." The tests listed are primarily physical, chemical, and biological characterization tests performed on the device itself or its materials, rather than a clinical human subject test set. The data provenance is not specified, but these are laboratory tests rather than patient data.

    3. Number of Experts Used to Establish Ground Truth and Their Qualifications

    Since the tests performed are bench tests (biocompatibility, mechanical, sterility, extraction, cell counts/viability), the concept of "ground truth" established by human experts in a diagnostic or clinical context is not applicable. The ground truth for these tests is based on objective laboratory measurements and established scientific standards (e.g., ISO guidelines, ASTM standards, chemical analysis techniques).

    4. Adjudication Method for the Test Set

    Adjudication methods like "2+1" or "3+1" are relevant for clinical studies where human interpretation of medical images or outcomes needs consensus. For the bench tests described, adjudication is not applicable. The "results" are objective measurements.

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

    No MRMC comparative effectiveness study was done. The document describes bench testing to demonstrate functionality and substantial equivalence to a predicate device, not a human reader study.

    6. Standalone (Algorithm Only) Performance Study

    Not applicable. This device is an Automatic Tissue Processing Unit, a mechanical/biological processing system, not an AI algorithm.

    7. Type of Ground Truth Used

    The "ground truth" for the performance data in this submission consists of:

    • Objective physical measurements: Dimensions, leakage, adhesive strength.
    • Chemical analysis results: Residuals of cleaning liquid, pH, KMnO4 reducing agents, evaporating residue, heavy metals, UV-vis spectrum.
    • Biological assay results: Nucleated cell count and viability.
    • Standardized biological test outcomes: Biocompatibility tests (cytotoxicity, sensitization, systemic toxicity, pyrogenicity, hemolysis) performed according to ISO standards, where "Pass" is the objective outcome based on the standard's criteria.

    8. Sample Size for the Training Set

    Not applicable. This device is not an AI/ML algorithm that requires a training set. The data presented is for validation and verification of the physical device's performance.

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

    Not applicable, as there is no training set for this type of device.

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