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510(k) Data Aggregation

    K Number
    K252505
    Date Cleared
    2025-08-28

    (20 days)

    Product Code
    Regulation Number
    880.6250
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Basic Medical Technology Inc.

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

    Powder-Free Vinyl Exam Gloves, clear is a disposable device intended for medical purposes that is worn on the examiner's hand to prevent contamination between patient and examiner.

    Device Description

    The subject device is a powder free vinyl patient examination glove, provided as non-sterile and disposable device. It is provided with clear color. Available in four sizes small, medium, large, and extra - large users can choose the most suitable option.

    AI/ML Overview

    The provided FDA 510(k) clearance letter and summary describe the regulatory approval process for "Powder-Free Vinyl Exam Gloves, clear." This is a Class I medical device, and the clearance is based on demonstrating substantial equivalence to a predicate device, K220469, "Disposable Vinyl Examination Glove."

    The study described is not a clinical study involving human patients or complex AI algorithms necessitating multi-reader, multi-case (MRMC) studies or expert adjudication of medical images. Instead, it's a non-clinical performance study focused on the physical, chemical, and biological properties of the gloves.

    Therefore, many of the requested points related to AI performance, human reader improvement, and complex ground truth establishment for medical diagnosis are not applicable to this type of device and study.

    Here's the breakdown of the information that is applicable:


    Acceptance Criteria and Device Performance for Powder-Free Vinyl Exam Gloves, Clear

    The acceptance criteria and device performance are primarily based on non-clinical testing according to recognized industry standards (ASTM and ISO). The goal is to demonstrate that the subject device meets the same performance specifications as the predicate device.

    1. Table of Acceptance Criteria and Reported Device Performance

    Methodology (Standard)Test PerformedAcceptance CriteriaReported Device PerformanceOutcome
    ASTM D5250-19, ASTM D3767-03Physical Dimensions: LengthS/M/L/XL: 230 mm230 mmPass
    Physical Dimensions: WidthS: 85±5 mm; M: 95±5 mm; L: 105±5 mm; XL: 115±5 mmS: 85-86 mm; M: 95-96 mm; L: 104-106 mm; XL: 115-116 mmPass
    Physical Dimensions: ThicknessFinger: 0.08 mm; Palm: 0.08 mmFinger: 0.09-0.12 mm; Palm: 0.08-0.10 mmPass
    ASTM D5250-19, ASTM D412-16Physical Properties: Before aging (Tensile strength)11 MPa, min14 - 22 MPaPass
    Physical Properties: Before aging (Ultimate elongation)300%, min302 - 419 %Pass
    Physical Properties: After aging (Tensile strength)11 MPa, min14 - 21 MPaPass
    Physical Properties: After aging (Ultimate elongation)300%, min303 - 433 %Pass
    ASTM D5250-19, ASTM D5151-19Water leak test (Freedom from holes)G-I, AQL 2.5 (ISO 2859-1)PassPass
    ASTM D5250-19, ASTM D6124-06Powder ResidueMax 2 mg/glove0.37-0.53 mgPass
    ISO 10993-10:2021SensitizationNon-sensitizingUnder conditions of the study, not a sensitizer.Pass
    ISO 10993-23:2021IrritationNon-irritatingUnder the conditions of the study, not an irritant.Pass
    ISO 10993-5:2009CytotoxicityNon-CytotoxicityUnder conditions of the study, device is not cytotoxic.Pass

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

    • Sample Size: The document does not specify a precise numerical sample size (e.g., number of gloves) for each non-clinical test. However, it indicates that testing was performed according to the specified ASTM and ISO standards, which inherently define the necessary sample sizes and methodologies for ensuring statistical validity within their respective contexts (e.g., AQL for the water leak test).
    • Data Provenance: The document does not explicitly state the country of origin for the data. Given the "Basic Medical Technology Inc." is located in Ontario, CA (presumably California, USA) and the predicate device manufacturer is a Chinese company (CHIFENG HUAWEI MEDICAL SCIENCE TECHNOLOGY CO., LTD.), the testing could have been performed either in the US, China, or accredited labs elsewhere.
    • Retrospective or Prospective: This testing is inherently prospective as it involves the manufacturing and testing of new device samples to demonstrate compliance with standards.

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

    • Not Applicable: For this type of non-clinical device (medical gloves), "ground truth" is not established by medical experts interpreting images or clinical data. Instead, it's established by the physical and chemical properties of the material as measured by standardized laboratory methods. The "experts" would be the accredited laboratory personnel performing the tests according to the ASTM and ISO standards, not medical professionals like radiologists.

    4. Adjudication Method for the Test Set

    • Not Applicable: Adjudication methods (e.g., 2+1, 3+1) are used for resolving discrepancies in expert interpretations of complex data (like medical images). This is a physical product testing scenario where results are quantitative measurements against objective criteria, so no adjudication by multiple human observers is required.

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

    • Not Applicable: An MRMC study is relevant for evaluating the impact of AI algorithms on human reader performance in tasks like diagnostic imaging. This device is a pair of medical gloves; there is no AI component or human reader interpretation task involved.

    6. Standalone (i.e., algorithm only without human-in-the-loop performance) Study

    • Not Applicable: This pertains to AI algorithm performance evaluation. There is no AI algorithm in "Powder-Free Vinyl Exam Gloves, clear." The "standalone" performance here refers to the device's physical and biological properties.

    7. Type of Ground Truth Used

    • The "ground truth" for this device is based on objective, standardized measurements of its physical properties (e.g., dimensions, tensile strength, elongation, hole detection) and biological compatibility (e.g., cytotoxicity, irritation, sensitization), as defined by internationally recognized ASTM and ISO standards. It is not based on expert consensus, pathology, or outcomes data in the clinical sense.

    8. Sample Size for the Training Set

    • Not Applicable: This is not an AI/machine learning device. Therefore, there is no "training set" in the context of an algorithm. The manufacturing process of the gloves would have its own quality control and process validation, which might involve data collection analogous to a training set for process refinement, but this is distinct from AI model training.

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

    • Not Applicable: As there is no AI training set, this question is irrelevant.
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    Why did this record match?
    Applicant Name (Manufacturer) :

    Basic Medical Technology Inc.

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

    The glove is a disposable device intended for medical purposes that is worn on the examiner's hand to prevent contamination between patient and examiner.

    Gloves were tested for use with Chemotherapy drugs, Fentanyl Citrate, Simulated Gastric acid and Xylazine in Fentanyl Citrate in accordance with ASTM D6978-05 Standards Practice for assessment of Medical Glove to Permeation by chemotherapy drugs.

    Device Description

    Nitrile Powder-Free Exam Gloves Tested for Use with Chemotherapy Drugs, Opioid Fentanyl Citrate, Simulated Gastric Acid and Xylazine in Fentanyl Citrate is a Class I patient examination glove and specialty chemotherapy gloves, that made from synthetic nitrile latex. They are pink color, non-sterile, powder-free, fingertip textured, ambidextrous with beaded cuff, and single use only, and come in different sizes- XS, S, M, L, XL and XXL.

    The device meets all the specifications in ASTM D6319-19, Standard specification for Nitrile Examination Gloves. Additionally, the gloves have been been tested for biocompatibility and permeability to chemotherapy drugs, Fentanyl Citrate, Gastric Acid and Xylazine in Fentanyl Citrate.

    AI/ML Overview

    This document describes the acceptance criteria and the study that proves the device meets the acceptance criteria for a medical device submitted for FDA 510(k) clearance.

    The device in question is Nitrile Powder-Free Exam Gloves Tested for Use with Chemotherapy Drugs, Opioid Fentanyl Citrate, Simulated Gastric Acid and Xylazine in Fentanyl Citrate.


    Acceptance Criteria and Device Performance Study

    The acceptance criteria for this device are primarily based on established industry standards for medical examination gloves and specific permeation resistance tests for various chemical substances. The study conducted to prove the device meets these criteria is a series of non-clinical performance tests.

    1. Table of Acceptance Criteria and Reported Device Performance

    Test PerformedMethodologyAcceptance CriteriaReported Device Performance
    Freedom From HolesASTM D6319-19, ASTM D5151-19Meet requirement inspection level G-1, AQL 2.5 (ISO2859-1)Pass
    Dimension - LengthASTM D6319-19Minimum 220mm for size XS-S
    Minimum 230mm for size M-XXLPass
    Dimension - WidthASTM D6319-19XS: 70±10mm
    S: 80±10mm
    M: 95±10mm
    L: 110±10mm
    XL: 120±10mm
    XXL: 130±10mmPass
    Dimension - ThicknessASTM D6319-19Finger: 0.05mm (min)
    Palm: 0.05mm (min)Pass
    Physical PropertiesASTM D6319-19, ASTM D412-16Before aging:
    Tensile Strength (Min 14 Mpa)
    Elongation (Min 500%)
    After aging:
    Tensile Strength (Min 14 Mpa)
    Elongation (Min 400%)Pass (All criteria met)
    Powder ResidueASTM D6319-19, ASTM D6124-06Not more than 2 mg per glovePass
    Skin Irritation (Biocompatibility)ISO10993-23:2021Under the conditions of the study, not a primary skin irritantPass (Not a primary skin irritant)
    Skin Sensitization (Biocompatibility)ISO10993-10:2021Under the conditions of the study, not a contact sensitizerPass (Not a contact sensitizer)
    Acute Systemic Toxicity (Biocompatibility)ISO 10993-11:2017Under the conditions of the study, no signs of acute systemic toxicity were observedPass (No signs of acute systemic toxicity were observed)
    Chemotherapy Drugs PermeationASTM D6978-05 (2023)Minimum Breakthrough Detection Time (minutes)
    Carboplatin: >240
    Carmustine: Varies (15.3 min reported)
    Cisplatin: >240
    Cyclophosphamide: >240
    Cytarabine HCl: >240
    Dacarbazine: >240
    Daunorubicin HCl: >240
    Doxorubicin HCl: >240
    Etoposide: >240
    5-Fluorouracil: >240
    Gemcitabine HCl: >240
    Ifosfamide: >240
    Irinotecan HCl: >240
    Mechlorethamine HCl: >240
    Melphalan HCl: >240
    Methotrexate: >240
    Mitomycin-C: >240
    Mitoxantrone HCl: >240
    Pacilitaxel: >240
    Thiotepa: Varies (28.2 min reported)Carboplatin: >240 min.
    Carmustine: 15.3 min.
    Cisplatin: >240 min.
    Cyclophosphamide: >240 min.
    Cytarabine HCl: >240 min.
    Dacarbazine: >240 min.
    Daunorubicin HCl: >240 min.
    Doxorubicin HCl: >240 min.
    Etoposide: >240 min.
    5-Fluorouracil: >240 min.
    Gemcitabine HCl: >240 min.
    Ifosfamide: >240 min.
    Irinotecan HCl: >240 min.
    Mechlorethamine HCl: >240 min.
    Melphalan HCl: >240 min.
    Methotrexate: >240 min.
    Mitomycin-C: >240 min.
    Mitoxantrone HCl: >240 min.
    Pacilitaxel: >240 min.
    Thiotepa: 28.2 min.
    Note: The document explicitly states that Carmustine and Thiotepa have "extremely low permeation times" and are accompanied by a "Warning: Do not use with Carmustine and Thiotepa," indicating that the stated permeation times for these two drugs are not >240 minutes and are accepted for the specified usage.
    Fentanyl, Gastric Acid, Xylazine PermeationASTM D6978-05 (2023)Minimum Breakthrough Detection Time (minutes)
    Fentanyl Citrate Injection: >240
    Simulated Gastric Acid: >240
    Fentanyl Citrate:Xylazine HCl (50:50): >240Fentanyl Citrate Injection: >240 min.
    Simulated Gastric Acid: >240 min.
    Fentanyl Citrate (50mcg/ml): Xylazine HCl (100mg/ml), 50:50: >240 min.

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

    The document does not explicitly state the specific sample sizes (number of gloves) used for each individual test. However, it indicates that the tests were conducted according to established ASTM and ISO standards, which typically specify appropriate sample sizes for such tests to ensure statistical validity.

    The data provenance is through non-clinical testing performed in accordance with recognized international and national standards (ASTM, ISO). This implies the data were prospectively generated for the purpose of this submission. The country of origin of the data is not specified, but the use of international standards suggests a globally accepted testing methodology.

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

    This information is not applicable (N/A) as the device is a physical product (medical glove) and the performance is evaluated through objective, standardized laboratory tests (e.g., measuring permeation time, tensile strength, dimensions) rather than expert interpretation of images or clinical data. There is no "ground truth" established by human experts in the context of diagnostic accuracy for this type of device.

    4. Adjudication Method for the Test Set

    This information is not applicable (N/A) for the same reason as above. Adjudication methods like 2+1 or 3+1 are relevant for studies involving human interpretation (e.g., radiology reads) where discrepancies need to be resolved. The tests performed for this device are objective measurements.

    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 (N/A). This document pertains to the clearance of a physical medical device (gloves), not an AI algorithm or a diagnostic imaging device that would involve human readers.

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

    This information is not applicable (N/A). As mentioned, this is a physical medical device, not a software algorithm.

    7. The Type of Ground Truth Used

    The "ground truth" for this device's performance is established by objective, quantitative measurements obtained through standardized laboratory testing methodologies (ASTM and ISO standards). For example:

    • Permeation: Measured breakthrough time of specific chemicals through the glove material.
    • Physical Properties: Measured tensile strength, elongation, length, width, and thickness.
    • Biocompatibility: Observed biological responses (e.g., irritation, sensitization, systemic toxicity) in controlled in-vitro or in-vivo (animal) tests as per ISO standards.
      This is not based on expert consensus, pathology, or outcomes data in the clinical sense, but rather on direct physical and chemical testing.

    8. The Sample Size for the Training Set

    This information is not applicable (N/A). This device is a manufactured product that undergoes performance and biocompatibility testing. There is no "training set" in the context of machine learning. The manufacturing process is designed and validated to consistently produce gloves meeting the specified criteria.

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

    This information is not applicable (N/A) as there is no training set for this device. The "ground truth" for the device's design and manufacturing is derived from the established standards (ASTM, ISO) that define the performance characteristics expected of such gloves. Quality control during manufacturing ensures conformity to these standards.

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    Why did this record match?
    Applicant Name (Manufacturer) :

    Basic Medical Technology Inc.

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

    The glove is disposable device intended for medical purposes that is worn on the examiner's hand to prevent contamination between patient and examiner. Gloves were tested for use with Chemotherapy drugs, Fentanyl and Gastric acid in accordance with ASTM D6978-05 standards Practice for assessment of Medical Glove to Permeation by chemotherapy drugs.

    Device Description

    Nitrile Powder-Free Exam Gloves 2.8, Tested for Use with Chemotherapy Drugs, Opioid Fentanyl Citrate, Simulated Gastric Acid (light blue, dark blue)

    AI/ML Overview

    The provided document is a 510(k) premarket notification approval letter for Nitrile Powder-Free Exam Gloves. It details the device's substantial equivalence to existing predicate devices and lists the results of permeation tests for various chemotherapy drugs, opioid fentanyl citrate, and simulated gastric acid.

    However, the document does not describe a study involving an AI/software medical device requiring ground truth establishment, expert adjudication, or MRMC comparative effectiveness studies. The "acceptance criteria" discussed in this document relate to the gloves' resistance to permeation by specific chemicals, measured in "Minimum Breakthrough Detection Time."

    Therefore, based solely on the provided text, it is not possible to answer the questions related to AI/software device performance, expert ground truth, adjudication methods, or MRMC studies.

    Here's an attempt to answer the questions based on the information available in the document, acknowledging that most questions are not applicable to this type of device:


    Acceptance Criteria and Device Performance for Nitrile Powder-Free Exam Gloves

    The study presented here is a series of permeation tests conducted to determine the resistance of Nitrile Powder-Free Exam Gloves to various hazardous substances, specifically chemotherapy drugs, opioid fentanyl citrate, and simulated gastric acid. The acceptance criteria are implicit in the detailed breakthrough detection times, aiming to demonstrate the gloves' barrier properties against these substances. The tests were performed in accordance with ASTM D6978-05 standards.

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document directly states the "Minimum Breakthrough Detection Time" for each substance for both the Light Blue and Dark Blue gloves. The implicit acceptance criterion would be that the gloves demonstrate a sufficiently long breakthrough time (ideally >240 minutes) for safe handling, or to clearly identify substances for which the gloves are not suitable. The reported performance is the actual measured breakthrough time.

    Light Blue Glove Performance:

    Chemotherapy Drug / SubstanceMinimum Breakthrough Detection Time (minutes)
    Bendamustine HCl, 5 mg/ml>240 min
    Bortezomib (Velcade), 1 mg/ml>240 min
    Busulfan, 6 mg/ml>240 min
    Carboplatin, 10 mg/ml>240 min
    Carmustine, 3.3 mg/ml12.6 min.
    Carfilzomib, 2 mg/ml>240 min
    Cetuximab (Erbitux), 2 mg/ml>240 min
    Chloroquine, 50mg/ml>240 min
    Cisplatin, 1 mg/ml>240 min
    Cladribine, 1.0 mg/ml>240 min
    Cyclophosphamide, 20 mg/ml>240 min
    Cyclosporin A,100mg/ml>240 min
    Cytarabine HCl, 100 mg/ml>240 min
    Cytovene, 10 mg/ml>240 min
    Dacarbazine, 10 mg/ml>240 min
    Daunorubicin HCl, 5 mg/ml>240 min
    Decitabine, 5 mg/ml>240 min
    Docetaxel, 10 mg/ml>240 min
    Doxorubicin HCl, 2 mg/ml>240 min
    Epirubicin HCl, 2 mg/ml>240 min
    Etoposide, 20 mg/ml>240 min
    Fludarabine Phosphate, 25 mg/ml>240 min
    5-Fluorouracil, 50 mg/ml>240 min
    Gemcitabine HCl, 38 mg/ml>240 min
    Idarubicin HCl, 1 mg/ml>240 min
    Ifosfamide, 50 mg/ml>240 min
    Irinotecan HCl, 20 mg/ml>240 min
    Mechlorethamine HCl, 1 mg/ml>240 min
    Melphalan HCl, 5 mg/ml>240 min
    Methotrexate, 25 mg/ml>240 min
    Mitomycin-C, 0.5 mg/ml>240 min
    Mitoxantrone HCl, 2 mg/ml>240 min
    Oxaliplatin, 2 mg/ml>240 min
    Paclitaxel, 6 mg/ml>240 min
    Retrovir, 10 mg/ml>240 min
    ThioTEPA, 10 mg/ml27.1 min.
    Trisonex, 1 mg/ml>240 min
    Vidaza (Azacitidine), 25 mg/ml>240 min
    Vincristine Sulfate, 1 mg/ml>240 min
    Fentanyl Citrate Injection, 50mcg/ml>240 min
    Gastric Acid>240 min
    Fentanyl Citrate:Xylazine HCl, 50:50>240 min

    Note: Warnings are explicitly provided for Carmustine and ThioTEPA due to extremely low permeation times.

    Dark Blue Glove Performance:

    Chemotherapy Drug / SubstanceMinimum Breakthrough Detection Time (minutes)
    Bendamustine HCl, 5 mg/ml>240 min
    Bortezomib (Velcade), 1 mg/ml>240 min
    Busulfan, 6 mg/ml>240 min
    Carboplatin, 10 mg/ml>240 min
    Carmustine, 3.3 mg/ml11.0 min.
    Carfilzomib, 2 mg/ml>240 min
    Cetuximab (Erbitux), 2 mg/ml>240 min
    Chloroquine, 50mg/ml>240 min
    Cisplatin, 1 mg/ml>240 min
    Cladribine, 1.0 mg/ml>240 min
    Cyclophosphamide, 20 mg/ml>240 min
    Cyclosporin A,100mg/ml>240 min
    Cytarabine HCl, 100 mg/ml>240 min
    Cytovene, 10 mg/ml>240 min
    Dacarbazine, 10 mg/ml>240 min
    Daunorubicin HCl, 5 mg/ml>240 min
    Decitabine, 5 mg/ml>240 min
    Docetaxel, 10 mg/ml>240 min
    Doxorubicin HCl, 2 mg/ml>240 min
    Epirubicin HCl, 2 mg/ml>240 min
    Etoposide, 20 mg/ml>240 min
    Fludarabine Phosphate, 25 mg/ml>240 min
    5-Fluorouracil, 50 mg/ml>240 min
    Gemcitabine HCl, 38 mg/ml>240 min
    Idarubicin HCl, 1 mg/ml>240 min
    Ifosfamide, 50 mg/ml>240 min
    Irinotecan HCl, 20 mg/ml>240 min
    Mechlorethamine HCl, 1 mg/ml>240 min
    Melphalan HCl, 5 mg/ml>240 min
    Methotrexate, 25 mg/ml>240 min
    Mitomycin-C, 0.5 mg/ml>240 min
    Mitoxantrone HCl, 2 mg/ml>240 min
    Oxaliplatin, 2 mg/ml>240 min
    Paclitaxel, 6 mg/ml>240 min
    Retrovir, 10 mg/ml>240 min
    ThioTEPA, 10 mg/ml26.0 min.
    Trisonex, 1 mg/ml>240 min
    Vidaza (Azacitidine), 25 mg/ml>240 min
    Vincristine Sulfate, 1 mg/ml>240 min
    Fentanyl Citrate Injection, 50mcg/ml>240 min
    Gastric Acid>240 min
    Fentanyl Citrate:Xylazine HCl, 50:50>240 min

    Note: Warnings are explicitly provided for Carmustine and ThioTEPA due to extremely low permeation times.

    2. Sample Size and Data Provenance for the Test Set:
    The document does not explicitly state the sample size (number of gloves tested for each substance) used for these permeation tests. It only lists the test results. The data provenance is stated as being tested "in accordance with ASTM D6978-05 standards," which implies a standardized laboratory testing setting. There is no information regarding the country of origin of the data or whether it was retrospective or prospective.

    3. Number of Experts and Qualifications for Ground Truth:
    This section is not applicable to this type of device and study. The "ground truth" here is the physical measurement of chemical permeation, which is determined by laboratory instrumentation and protocols defined by the ASTM standard, not by human expert interpretation or consensus.

    4. Adjudication Method for the Test Set:
    This section is not applicable. Adjudication methods like "2+1" or "3+1" are used in studies involving human readers/experts evaluating data (e.g., medical images) to establish a consensus ground truth. In this study, the "ground truth" is a direct physical measurement.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:
    This section is not applicable. MRMC studies are performed for AI/software devices where human readers interpret medical data, often comparing human performance with and without AI assistance. This document describes chemical permeation tests of gloves, not a diagnostic or prognostic medical device involving human interpretation.

    6. Standalone (Algorithm Only) Performance:
    This section is not applicable. This refers to the performance of an AI algorithm without human intervention. The device in question is a physical glove, not an algorithm.

    7. Type of Ground Truth Used:
    The "ground truth" for this study is a physical measurement of chemical permeation through the glove material, determined by laboratory testing protocols as defined by the ASTM D6978-05 standards. It is not derived from expert consensus, pathology, or outcomes data.

    8. Sample Size for the Training Set:
    This section is not applicable. This study does not involve a training set as it's not an AI/machine learning model development context.

    9. How the Ground Truth for the Training Set was Established:
    This section is not applicable for the reasons stated above.

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    Why did this record match?
    Applicant Name (Manufacturer) :

    Basic Medical Technology Inc.

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

    Nitrile Powder-Free Exam Gloves with Hyaluronic Acid, and tested for Use with Chemotherapy Drugs, Opioid Fentanyl Citrate, Simulated Gastric Acid and Xylazine in Fentanyl Citrate is a disposable device intended for medical purposes that is worn on the examiner's hand to prevent contamination between patient and examiner. Gloves were tested for use with Chemotherapy drugs, Fentanyl, Gastric acid and Xylazine in accordance with ASTM D6978-05 standards Practice for assessment of Medical Glove to Permeation by chemotherapy drugs.

    Device Description

    Nitrile Powder-Free Exam Gloves with Hyaluronic Acid, and tested for Use with Chemotherapy Drugs, Opioid Fentanyl Citrate, Simulated Gastric Acid and Xylazine in Fentanyl Citrate is a Class I patient examination glove and specialty chemotherapy gloves, that made from synthetic nitrile latex. They are non-sterile, powder-free, fingertip textured, ambidextrous with beaded cuff, blue colored nitrile gloves featuring an inner coating of hyaluronic acid and single use only. There are six different sizes- XS, S, M, L, XL and XXL. The gloves are designed and manufactured in accordance with the ASTM D6319-19 standard and are tested for use with chemotherapy drugs, opioid Fentanyl Citrate, simulated Gastric Acid and Xylazine per ASTM D6978-05.

    AI/ML Overview

    The provided document is a 510(k) clearance letter from the FDA for Nitrile Powder-Free Exam Gloves. It details the device's characteristics, indications for use, and a comparison with predicate and reference devices, as well as a summary of non-clinical testing.

    However, the nature of this medical device (examination gloves) means that the provided information does not include the typical "study that proves the device meets the acceptance criteria" in the context of an AI/ML powered device for diagnostic or prognostic purposes, which is what your questions #2 through #9 are geared towards.

    For examination gloves, the "acceptance criteria" are based on physical properties, biocompatibility, and permeation resistance to certain chemicals, assessed through laboratory testing, not clinical studies involving patient data or expert interpretation.

    Therefore, I will answer the questions that are applicable to the provided document and explicitly state when a question is not applicable.


    Acceptance Criteria and Device Performance for Nitrile Powder-Free Exam Gloves

    1. A table of acceptance criteria and the reported device performance

    Test PerformedMethodologyAcceptance CriteriaReported Device Performance
    Freedom From HolesASTM D6319-19, ASTM D5151-19Meet requirement inspection level G-I, AQL 2.5 (ISO2859-1)Pass
    Dimension - LengthASTM D6319-19Minimum 220mm for size XS-S; Minimum 230mm for size M-XXLPass
    Dimension - WidthASTM D6319-19XS: 70±10mm; S: 80±10mm; M: 95±10mm; L: 110±10mm; XL: 120±10mm; XXL: 130±10mmPass
    Dimension - ThicknessASTM D6319-19Finger: 0.05mm (min); Palm: 0.05mm (min)Pass
    Physical Properties (Tensile Strength)ASTM D6319-19, ASTM D412-16Before and After Aging: 14 MPa MinPass
    Physical Properties (Ultimate Elongation)ASTM D6319-19, ASTM D412-16Before Aging: 500% Min; After Aging: 400% MinPass
    Powder ResidueASTM D6319-19, ASTM D6124-06Not more than 2 mg per glovePass
    Skin IrritationISO10993-23:2021Under the conditions of the study, not a primary skin irritantPass
    Skin SensitizationISO10993-10:2021Under the conditions of the study, not a contact sensitizerPass
    Acute Systemic ToxicityISO 10993-11:2017Under the conditions of the study, no signs of acute systemic toxicity were observedPass
    Chemotherapy Drug PermeationASTM D6978-05Refer to the table below for specific drug breakthrough times.Pass (met listed times)

    Chemotherapy and Other Drug Permeation Minimum Breakthrough Detection Times:

    Chemotherapy DrugsMinimum Breakthrough Detection Time
    Carboplatin, 10 mg/ml>240 min.
    Carmustine, 3.3 mg/ml11.6 min.
    Cisplatin, 1 mg/ml>240 min.
    Cyclophosphamide, 20 mg/ml>240 min.
    Cytarabine HCl 100 mg/ml>240 min.
    Dacarbazine, 10 mg/ml>240 min.
    Daunorubicin HCl, 5 mg/ml>240 min.
    Doxorubicin HCl, 2 mg/ml>240 min.
    Etoposide, 20 mg/ml>240 min.
    5-Fluorouracil, 50 mg/ml>240 min.
    Gemcitabine HCl, 38 mg/ml>240 min.
    Idarubicin HCl, 1 mg/ml>240 min.
    Ifosfamide, 50 mg/ml>240 min.
    Irinotecan HCl, 20 mg/ml>240 min.
    Mechlorethamine HCl, 1 mg/ml>240 min.
    Melphalan HCl, 5 mg/ml>240 min.
    Methotrexate, 25 mg/ml>240 min.
    Mitomycin-C, 0.5 mg/ml>240 min.
    Mitoxantrone HCl, 2 mg/ml>240 min.
    Paclitaxel, 6 mg/ml>240 min.
    Thiotepa, 10 mg/ml25.3 min.
    Vincristine Sulfate, 1 mg/ml>240 min.
    Fentanyl, Gastric Acid and XylazineMinimum Breakthrough Detection Time
    Fentanyl Citrate Injection, 50mcg/ml>240 min.
    Simulated Gastric Acid>240 min.
    Fentanyl Citrate (50mcg/ml): Xylazine HCl (100mg/ml), 50:50>240 min.

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
    The document does not specify the exact sample sizes (e.g., number of gloves tested for each physical or chemical property) for the non-clinical tests. It only states that testing was conducted. Data provenance (e.g., country of origin, retrospective/prospective) is not provided as these are laboratory tests of a manufactured product, not data collected from patients.

    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. Ground truth for glove performance tests (physical properties, biocompatibility, chemical permeation) is established by adherence to standardized testing methodologies (e.g., ASTM, ISO standards) and measurable outcomes, not by expert consensus or interpretation in the way it is for diagnostic AI.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
    Not applicable. Adjudication methods like 2+1 or 3+1 are used for establishing ground truth in clinical imaging studies or similar diagnostic contexts where expert consensus is required for labeling data. This does not apply to the laboratory testing of gloves.

    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 type of study is relevant for AI-powered diagnostic or screening tools that assist human interpreters. The device in question is examination gloves, which do not involve human readers interpreting cases or AI assistance.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
    Not applicable. The device is a physical product (gloves), not an algorithm or AI system.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
    The "ground truth" for the device's performance is based on direct measurements and observations derived from standardized laboratory tests (e.g., tensile strength, elongation, hole detection, chemical permeation) defined by recognized industry standards (ASTM, ISO).

    8. The sample size for the training set
    Not applicable. The device is not an AI/ML algorithm that requires a training set.

    9. How the ground truth for the training set was established
    Not applicable. The device is not an AI/ML algorithm.

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    K Number
    K243792
    Date Cleared
    2025-02-18

    (70 days)

    Product Code
    Regulation Number
    880.6250
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Basic Medical Technology Inc.

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

    Nitrile Powder-Free Exam Gloves Tested for Use with Chemotherapy Drugs, Opioid Fentanyl Citrate (Black/White) is a disposable device intended for medical purposes that is worn on the examiner's hand to prevent contamination between patient and examiner. Gloves have been tested for use with Chemotherapy drugs and Fentanyl using ASTM D6978-05.

    Device Description

    Nitrile Powder-Free Exam Gloves Tested for Use with Chemotherapy Drugs, Opioid Fentanyl Citrate (Black, White) is a Class I patient examination glove and specialty chemotherapy gloves, that made from synthetic nitrile latex. They are non-sterile, powder-free, fingertip textured, ambidextrous with beaded cuff, and single use only, and come in different sizes- XS, S, M, L, XL and XXL. The device meets all the specifications in ASTM D6319-19, Standard specification for Nitrile Examination Gloves. Additionally, the gloves have been tested for biocompatibility and permeability to chemotherapy drugs and Fentanyl Citrate.

    AI/ML Overview

    The provided document pertains to the 510(k) premarket notification for Nitrile Powder-Free Exam Gloves Tested for Use with Chemotherapy Drugs, Opioid Fentanyl Citrate (Black, White).

    This submission is for a Class I medical device (gloves), which typically does not involve complex AI algorithms or diagnostic imaging. Therefore, many of the requested criteria related to AI/MRMC studies, expert consensus for ground truth, and training set information are not applicable to this type of device and submission.

    The "acceptance criteria" here refer to the performance standards and safety requirements for medical gloves, particularly their resistance to permeation by chemotherapy drugs and fentanyl, and their physical and biological properties.

    Here's a breakdown based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document presents acceptance criteria and reported performance in the "Summary of Non-Clinical Performance Data" and the "Chemotherapy Drugs Comparison Claim" tables.

    Table 1: General Performance Acceptance Criteria and Reported Results (from page 10)

    Test PerformedMethodologyAcceptance CriteriaResult
    Freedom From HolesASTM D6319-19, ASTM D5151-19Meet requirement inspection level G-1, AQL 2.5 (ISO2859-1)Pass
    Dimension-LengthASTM D6319-19Minimum 230mm for all sizesPass
    Dimension-WidthASTM D6319-19XS: 70±10mm, S: 80±10mm, M: 95±10mm, L: 110±10mm, XL: 120±10mm, XXL: 130±10mmPass
    Dimension-ThicknessASTM D6319-19Finger: 0.05mm (Min), Palm: 0.05mm (Min)Pass
    Physical propertiesASTM D6319-19, ASTM D412-16Tensile Strength (Min 14 MPa), Elongation (Before Aging 500% and after aging 400% Min)Pass
    Powder ResidueASTM D6319-19, ASTM D6124-06Not more than 2 mg per glovePass
    Skin IrritationISO10993-23:2021Not a primary skin irritantPass
    Skin SensitizationISO10993-10:2021Not a contact sensitizerPass
    Acute Systemic ToxicityISO 10993-11:2017No acute systemic toxicityPass

    Table 2: Permeation by Chemotherapy Drugs and Fentanyl Citrate Acceptance Criteria and Reported Results (from page 9)

    NO.Chemotherapy DrugsMinimum Breakthrough Detection Time, minutes (Black Glove)Minimum Breakthrough Detection Time, minutes (White Glove)Predicate Device K230779 (Black)Result of Comparison (to Predicate)
    1Carmustine (3.3mg/ml)14.216.711.3Different (both subject devices perform better than predicate)
    2Cisplatin (1mg/ml)>240>240>240Same
    3Cyclophosphamide (20mg/ml)>240>240>240Same
    4Dacarbazine (10.0 mg/ml)>240>240>240Same
    5Doxorubicin HCl (2 mg/ml)>240>240>240Same
    6Etoposide (20mg/ml)>240>240>240Same
    7Fluorouracil (50mg/ml)>240>240>240Same
    8Paclitaxel (6mg/ml)>240>240>240Same
    9Thiotepa (10mg/ml)14.716.224.7Different (subject devices perform worse for Thiotepa compared to predicate, but the labeling calls out the warning for these drugs)
    NO.Fentanyl CitrateMinimum Breakthrough Detection Time, minutes (Black Glove)Minimum Breakthrough Detection Time, minutes (White Glove)Predicate device K230779Result of Comparison
    1Fentanyl Citrate Injection, 100mcg/2ml>240>240>240Same

    Note: The warning regarding Carmustine and Thiotepa for both black and white gloves is highlighted due to their low permeation times, similar to the predicate device, which also shows a low time for Carmustine and a higher time for Thiotepa. The critical aspect for these drugs is to provide clear warning on the labeling.

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

    The document specifies that the tests were non-clinical, adhering to various ASTM and ISO standards. These standards prescribe the sample sizes and testing methodologies. For example:

    • Freedom from Holes (ASTM D6319-19, ASTM D5151-19): References "inspection level G-I, AQL 2.5 (ISO2859-1)," which indicates specific sampling plans and acceptance quality limits for batch inspection, not individual sample sizes like in a typical clinical study.
    • Permeation by Chemotherapy Drugs (ASTM D6978-05): This standard outlines the test method, including the number of specimens (typically 3 specimens per drug per material), continuous monitoring of breakthrough, and reporting of average breakthrough times.
    • Biocompatibility (ISO 10993 series): These standards specify the number of animals or in-vitro tests required, but precise numbers are not explicitly stated in this summary.

    Data Provenance: The data comes from non-clinical laboratory testing conducted by the manufacturer (Basic Medical Technology Inc.) to demonstrate compliance with recognized industry standards (ASTM, ISO). The document does not specify the country of origin of the raw test data but implies it was generated to support a US FDA submission. The tests are prospective in the sense that they were conducted for this specific submission to demonstrate the device's performance.

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

    Not Applicable. This is a physical device (medical gloves) and not an AI/diagnostic software. "Ground truth" in this context is established by standardized, objective laboratory test methods (e.g., measuring dimensions, tensile strength, breakthrough time using analytical instruments), not by expert consensus on clinical images or data.

    4. Adjudication method for the test set

    Not Applicable. As per point 3, ground truth is established by objective laboratory measurements and adherence to standardized testing protocols, not by expert review or adjudication.

    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 a Class I physical medical device (gloves), not an AI algorithm or diagnostic tool involving human readers.

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

    Not Applicable. This is a physical device, not an algorithm.

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

    The "ground truth" for this device is based on objective measurements performed according to recognized international and national standards (ASTM, ISO). This includes:

    • Physical properties (e.g., dimensions, tensile strength, elongation).
    • Chemical resistance (breakthrough time for chemotherapy drugs and fentanyl).
    • Biological safety (irritation, sensitization, systemic toxicity).

    8. The sample size for the training set

    Not Applicable. This is a physical device. There is no AI model or "training set" in the context of this submission. The "training" for the device would be the manufacturing process and quality control, which are governed by Quality System (QS) regulations.

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

    Not Applicable. As explained in point 8, there is no training set as per AI/ML terminology. The manufacturing process and material specifications are developed and validated based on established engineering principles and industry standards to ensure the gloves meet their intended performance characteristics.

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    Why did this record match?
    Applicant Name (Manufacturer) :

    Basic Medical Technology Inc.

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

    The glove is disposable device intended for medical purposes that is worn on the examiner's hand to prevent contamination between patient and examiner. Gloves were tested for use with Chemotherapy drugs, Fentanyl and Gastric acid in accordance with ASTM D6978-05 standards Practice for assessment of Medical Glove to Permeation by chemotherapy drugs.

    Device Description

    Nitrile Powder-Free Exam Gloves Tested for Use with Chemotherapy Drugs, Opioid Fentanyl Citrate, Simulated Gastric Acid (Light blue, Dark blue) is a Class I patient examination glove and specialty chemotherapy gloves, that made from synthetic nitrile latex. They are non-sterile, powder-free, fingertip textured, ambidextrous with beaded cuff, and single use only, and come in different sizes- XS, S, M, L, XL and XXL.

    AI/ML Overview

    The provided [K243441](https://510k.innolitics.com/search/K243441) document is a 510(k) premarket notification for Nitrile Powder-Free Exam Gloves. This type of device is a Class I medical device and does not involve AI or complex algorithms requiring human-in-the-loop studies or ground truth established by experts.

    Therefore, most of the requested information regarding AI/algorithm performance, human reader studies, and expert-established ground truth is not applicable to this document. The "device" in this context is a physical examination glove, not an AI-powered diagnostic tool.

    The acceptance criteria and performance are related to the physical properties and barrier efficacy of the gloves, not to analytical or diagnostic performance of an algorithm.

    However, I can extract the relevant acceptance criteria and reported performance for the physical glove testing:


    Acceptance Criteria and Reported Device Performance

    As the device is a physical medical glove and not an AI/software device, the acceptance criteria and performance relate to its physical and chemical barrier properties.

    Table of Acceptance Criteria and Reported Device Performance:

    Test PerformedMethodologyAcceptance CriteriaReported Device Performance (Result)
    Physical Properties
    Freedom From HolesASTM D6319-19, ASTM D5151-19Meet requirement inspection level G-I, AQL 2.5 (ISO2859-1)Pass
    Dimension - LengthASTM D6319-19Minimum 220mm for size XS-S; Minimum 230mm for size M-XXLPass
    Dimension - WidthASTM D6319-19XS: 70±10mm; S: 80±10mm; M: 95±10mm; L: 110±10mm; XL: 120±10mm; XXL: 130±10mmPass
    Dimension - ThicknessASTM D6319-19Finger: 0.05mm (min); Palm: 0.05mm (min)Pass
    Physical properties (Tensile Strength)ASTM D6319-19, ASTM D412-16Min 14MPa (Before aging & After aging)Pass
    Physical properties (Ultimate Elongation)ASTM D6319-19, ASTM D412-16Min 500% (Before aging); Min 400% (After aging)Pass
    Powder ResidueASTM D6319-19, ASTM D6124-06Not more than 2 mg per glovePass
    Biocompatibility
    Skin IrritationISO10993-23:2021Not a primary skin irritantPass
    Skin SensitizationISO10993-10:2021Not a contact sensitizerPass
    Acute Systemic ToxicityISO 10993-11:2017No acute systemic toxicityPass
    Permeation Testing
    Chemotherapy Drug, Fentanyl, Gastric AcidASTM D6978-05Minimum Breakthrough Detection Time (minutes) - Specific values for each substanceSee detailed tables below

    Detailed Permeation Performance (Minimum Breakthrough Detection Time in minutes):

    (Light Blue Glove)

    Chemotherapy DrugMinimum Breakthrough Detection Time (minutes)
    Bendamustine HCl, 5 mg/ml>240
    Bortezomib, 1 mg/ml>240
    Busulfan, 6 mg/ml>240
    Carboplatin, 10 mg/ml>240
    Carmustine, 3.3 mg/ml16.6
    Carfilzomib, 2 mg/ml>240
    Cetuximab (Erbitux), 2 mg/ml>240
    Chloroquine, 50mg/ml>240
    Cisplatin, 1 mg/ml>240
    Cladribine, 1.0 mg/ml>240
    Cyclophosphamide, 20 mg/ml>240
    Cyclosporin A,100mg/ml>240
    Cytarabine HCl, 100 mg/ml>240
    Cytovene, 10 mg/ml>240
    Dacarbazine, 10 mg/ml>240
    Daunorubicin HCl, 5 mg/ml>240
    Decitabine, 5 mg/ml>240
    Docetaxel, 10 mg/ml>240
    Doxorubicin HCl, 2 mg/ml>240
    Epirubicin HCl, 2 mg/ml>240
    Etoposide, 20 mg/ml>240
    Fludarabine, 25 mg/ml>240
    Fluorouracil, 50 mg/ml>240
    Gemcitabine HCl, 38 mg/ml>240
    Idarubicin HCl, 1 mg/ml>240
    Ifosfamide, 50 mg/ml>240
    Irinotecan HCl, 20 mg/ml>240
    Mechlorethamine HCl, 1 mg/ml>240
    Melphalan HCl, 5 mg/ml>240
    Methotrexate, 25 mg/ml>240
    Mitomycin-C, 0.5 mg/ml>240
    Mitoxantrone HCl, 2 mg/ml>240
    Oxaliplatin, 2 mg/ml>240
    Paclitaxel, 6 mg/ml>240
    Retrovir, 10 mg/ml>240
    ThioTEPA, 10 mg/ml44.9
    Trisenox, 1 mg/ml>240
    Vidaza (Azacitidine),25 mg/ml>240
    Vincristine Sulfate, 1 mg/ml>240
    Fentanyl Citrate Injection, 100mcg/2ml>240
    Simulated Gastric Acid>240

    Warning: Do not use Light Blue glove with Carmustine (16.6 minutes) and ThioTEPA (44.9 minutes).

    (Dark Blue Glove)

    Chemotherapy DrugMinimum Breakthrough Detection Time (minutes)
    Bendamustine HCl, 5 mg/ml>240
    Bortezomib, 1 mg/ml>240
    Busulfan, 6 mg/ml>240
    Carboplatin, 10 mg/ml>240
    Carmustine, 3.3 mg/ml21.5
    Carfilzomib, 2 mg/ml>240
    Cetuximab (Erbitux), 2 mg/ml>240
    Chloroquine, 50mg/ml>240
    Cisplatin, 1 mg/ml>240
    Cladribine, 1.0 mg/ml>240
    Cyclophosphamide, 20 mg/ml>240
    Cyclosporin A,100mg/ml>240
    Cytarabine HCl, 100 mg/ml>240
    Cytovene, 10 mg/ml>240
    Dacarbazine, 10 mg/ml>240
    Daunorubicin HCl, 5 mg/ml>240
    Decitabine, 5 mg/ml>240
    Docetaxel, 10 mg/ml>240
    Doxorubicin HCl, 2 mg/ml>240
    Epirubicin HCl, 2 mg/ml>240
    Etoposide, 20 mg/ml>240
    Fludarabine, 25 mg/ml>240
    Fluorouracil, 50 mg/ml>240
    Gemcitabine HCl, 38 mg/ml>240
    Idarubicin HCl, 1 mg/ml>240
    Ifosfamide, 50 mg/ml>240
    Irinotecan HCl, 20 mg/ml>240
    Mechlorethamine HCL, 1 mg/ml>240
    Melphalan HCl, 5 mg/ml>240
    Methotrexate, 25 mg/ml>240
    Mitomycin-C, 0.5 mg/ml>240
    Mitoxantrone HCl, 2 mg/ml>240
    Oxaliplatin, 2 mg/ml>240
    Paclitaxel, 6 mg/ml>240
    Retrovir, 10 mg/ml>240
    ThioTEPA, 10 mg/ml17.9
    Trisenox, 1 mg/ml>240
    Vidaza (Azacitidine),25 mg/ml>240
    Vincristine Sulfate, 1 mg/ml>240
    Fentanyl Citrate Injection, 100mcg/2ml>240
    Simulated Gastric Acid>240

    Warning: Do not use Dark Blue glove with Carmustine (21.5 minutes) and ThioTEPA (17.9 minutes).


    Regarding the other requested information (which is not applicable to this physical device):

    • 2. Sample size(s) used for the test set and the data provenance: Not explicitly stated as "sample size" in a statistical sense for AI. Testing involves physical samples of gloves manufactured for the purpose of meeting ASTM standards. Data provenance is implied to be from laboratory testing according to the listed ASTM and ISO standards.
    • 3. Number of experts used to establish the ground truth...: Not applicable. Ground truth for physical properties and chemical permeation is established by standardized laboratory testing procedures (e.g., measuring dimensions, tensile strength, or breakthrough time), not by expert consensus on images or medical data.
    • 4. Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable. Adjudication is not relevant for objective laboratory measurements.
    • 5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done...: Not applicable. This is a physical product, not an AI or imaging device that would involve human readers.
    • 6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable. There is no algorithm.
    • 7. The type of ground truth used (expert consensus, pathology, outcomes data, etc): The "ground truth" for this device is based on objective measurements and established physical/chemical standards (e.g., ASTM, ISO), not expert medical interpretation or clinical outcomes data in the context of an AI device.
    • 8. The sample size for the training set: Not applicable. There is no training set as this is not an AI/ML device.
    • 9. How the ground truth for the training set was established: Not applicable. There is no training set.
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