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510(k) Data Aggregation
(239 days)
Biomed Diagnostics Incorporated
The InTray GC is a microbiological device intended to differentiate and support the growth of pathogenic Neisseria gonorrhoeae when incubated at 35°C for 24-72 hours. Inoculated samples can optionally be pre-incubated prior to transport when pre-incubated at 35°C for 24 hours. Subsequent transport, of the pre-incubated specimen under controlled room temperature (18 to 25°C), is supported out to 72 hours.
The InTray GC is a Modified Thayer-Martin medium within a sealed inner well. The inner seal covers the inner well containing agar and an additional sealed cavity containing a CO2 generating tablet. There is also an outer adhesive label seal with a window that does not fog up under 100% relative humidity. The user opens and inoculates the surface of the medium with the patient sample followed by resealing the outer adhesive label. High humidity within the InTray causes the tablet to generate CO2 thus providing adequate bacterial growth condition for the target pathogen. After incubation of the inoculated InTray, the bacterial growth can be observed through the window without opening the InTray and therefore not disturbing the established CO2 concentration. Observation of culture growth can be by eye, hand lens or microscope.
The provided text is a 510(k) summary for the InTray® GC device, a culture medium for pathogenic Neisseria spp. The document describes the device, its intended use, a comparison to a predicate device, and the non-clinical performance data used to demonstrate substantial equivalence.
Here's an analysis of the acceptance criteria and the study proving the device meets them, based on the provided text:
Acceptance Criteria and Device Performance
The core of the study is to demonstrate the InTray GC device's performance, particularly its newly claimed transport function, is acceptable and substantially equivalent to its predicate device (K993033). The primary metric for acceptance appears to be the recoverability of Neisseria gonorrhoeae after inoculation, transport simulation, and incubation.
Implied Acceptance Criteria and Reported Performance:
Acceptance Criteria (Implied) | Reported Device Performance |
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Recoverability of N. gonorrhoeae after transport: A decline in CFU/mL of ≤ 2 log10 between time zero (no transport) and the end of the experimental incubation (72-hour transport). This applies specifically to the transport claim. | "The results of the comparative assessment study showed that there was ≤2 log10 CFU/mL difference in N. gonorrhoeae recovery, for each strain, between time zero (no transport) and the experimental endpoint (72-hour transport) for the InTray GC device." |
Acceptable recovery performance compared to a legally marketed transport device: The InTray GC should perform comparably to established transport methods. | "Acceptable recovery performance was also achieved for the legally marketed transport device when time zero and the experimental endpoint of 24 hours were compared, demonstrating that sufficient viability of N. gonorrhoede was achieved using traditional transport and culture techniques." (This implicitly validates the recovery standard used, and by extension, the InTray GC's performance against that standard). "There was no difference between the performance of the predicate device and transported InTray GC device." (This confirms substantial equivalence for the transport function). |
Recovery via increased colony size for pre-incubated samples: For samples pre-incubated and then transported, there should be clear evidence of growth. | "The data from the transport simulation study showed that inoculated samples pre-incubated at 35℃ for 24 hours followed by transport at 18-25℃ for 72 hours, demonstrated recovery via increased colony size when compared to samples that were not pre-incubated." |
Maintenance of CO2 concentration and growth conditions: The device design allows for observation of growth without disturbing the CO2 concentration. | "After incubation of the inoculated InTray, the bacterial growth can be observed through the window without opening the InTray and therefore not disturbing the established CO2 concentration." (This is a design feature, confirmed by the successful growth data). |
Study Details:
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Sample size used for the test set and the data provenance:
- Transport Simulation Study:
- Sample Size: "Four InTray replicates were inoculated with approximately 20 colony forming units (CFU) for each experimental group outlined in the table below and the process was repeated with the five different AR isolate bank strains (N. gonorrhoeae strains 0165, 0202, 0175, 0181 & 0197) and N. gonorrhoeae strain ATCC 43069." This means for each of the 6 strains, there were 4 replicates per experimental group (A, B, C1, C2, C3). If considering only Group A for the 72-hour transport claim, that would be 6 strains * 4 replicates = 24 samples.
- Replicates for comparative assessment: "Multiple lots of variously aged InTray GC devices were used to test the six strains of N. gonorrhoeae, with 3 lots testing 5 strains (N=15 replicates) and two different lots testing one of the six strains (N=2 replicates)." This totals 17 replicates for the InTray GC in the comparative assessment. For the legally marketed transport device, "Three replicates of the legally marketed transport device were used to inoculate the same six N. gonorrhoeae strains". This totals 18 replicates for the comparator device.
- Data Provenance: The document does not explicitly state the country of origin for the data or whether it was retrospective or prospective. Given it's a 510(k) submission for a medical device's performance validation, it is almost certainly prospective laboratory-based study data, generated specifically for this submission by Biomed Diagnostics Inc. ("Biomed Diagnostics Inc. performed data analysis on the recoverability...").
- Transport Simulation Study:
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- The study focuses on the biological performance of the culture medium regarding the growth and recovery of N. gonorrhoeae. The "ground truth" here is the actual growth/recovery of bacteria, measured in CFU/mL. This is an objective, quantitative biological outcome by the device itself, rather than a subjective interpretation by human experts.
- Therefore, the study does not involve human experts establishing a "ground truth" in the same way an imaging AI study would use radiologists. The measurements are taken directly from laboratory cultures.
- The "experts" involved would be the laboratory personnel performing the inoculations, incubations, and CFU counts, who would be qualified microbiologists or lab technicians. Their specific number or qualifications are not detailed in the summary, as is typical for this type of performance study where method reproducibility rather than expert consensus is key.
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Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- No adjudication method (like 2+1, 3+1 for expert review) is mentioned or applicable. This is a laboratory performance study measuring bacterial growth, not a clinical study involving human interpretation of results requiring adjudication of discrepancies. The "ground truth" is measured objectively via CFU counts.
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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 MRMC comparative effectiveness study was done. This device is a culture medium, not an AI-assisted diagnostic tool interpreted by human readers. The comparative study was between the InTray GC device and a "legally marketed transport device" in terms of bacterial recovery, not human reader performance.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- This question is not applicable in the context of this device. The InTray GC is a biological culture medium, not an algorithm. Its performance is inherent in its ability to support bacterial growth.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- The ground truth used is objective quantitative microbiology data: colony forming unit (CFU/mL) counts of Neisseria gonorrhoeae strains, which indicate the viability and recovery of the bacteria under different transport and incubation conditions. Visual observation of "increased colony size" also serves as a qualitative ground truth for growth.
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The sample size for the training set:
- This is a device performance study, not a machine learning model. Therefore, there is no training set in the sense of data used to train an algorithm. The data presented is for validation testing.
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How the ground truth for the training set was established:
- Not applicable as there is no training set for an algorithm. The "ground truth" for the performance studies was established through controlled laboratory inoculation of specific N. gonorrhoeae strains and subsequent quantitative (CFU counts) and qualitative (colony size/presence of growth) assessment.
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