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510(k) Data Aggregation

    K Number
    K102165
    Date Cleared
    2011-01-19

    (170 days)

    Product Code
    Regulation Number
    886.5928
    Reference & Predicate Devices
    N/A
    Why did this record match?
    Applicant Name (Manufacturer) :

    CACHET PHARMACEUTICALS PVT. LTD.

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

    Sterile Saline Solution is indicated for rinsing and wetting of soft (hydrophilic) contact lenses.

    Device Description

    Sterile Saline Solution is a sterile, preservative free, buffered, isotonic, clear, colourless aqueous solution containing Sodium Chloride, Sodium Borate, Boric Acid and Nitrogen as Propellant. The solution is packaged in lacquered aluminum spray containers with caps. Each container is sealed with a tamper evident hologram seal at the junction of the container and the cap.

    AI/ML Overview

    Acceptance Criteria and Study Details for Cachet Pharmaceuticals Pvt. Ltd. Sterile Saline Solution

    This document describes the acceptance criteria and related study details for the Cachet Pharmaceuticals Pvt. Ltd. Sterile Saline Solution, based on the provided 510(K) premarket submission.

    1. Table of Acceptance Criteria and Reported Device Performance

    The submission focuses on demonstrating substantial equivalence to a predicate device rather than establishing new performance criteria. Therefore, the "acceptance criteria" are primarily framed around demonstrating equivalence in key characteristics and safety.

    Feature/CharacteristicPredicate Device (Blairex Sterile Saline Solution - P850045) Specification/Performance (Implicit Acceptance Criteria)Cachet Sterile Saline Solution Reported Performance
    Intended UseFor rinsing and wetting of soft (hydrophilic) contact lensesFor rinsing and wetting of soft (hydrophilic) contact lenses
    FormulationSodium Chloride, Sodium borate, Boric Acid, Purified WaterSodium Chloride, Sodium borate, Boric Acid, Purified Water
    PropellantNitrogenNitrogen
    PreservativeNoNo
    Sterility ClaimSterileSterile
    ToxicityNon-toxic, comparable to marketed solutionsNo evidence of toxicity demonstrated in cytotoxicity and eye irritation studies
    BacteriostasisBacteria (Staph. aureus, E. coli, P. aeruginosa, C. albicans, A. niger) no significant growthBacteria (Staph. aureus, E. coli, P. aeruginosa, C. albicans, A. niger) no significant growth and survive over designated period (supports 30-day discard statement)

    Note: The acceptance criteria are implicitly met by demonstrating that the Cachet Sterile Saline Solution is substantially equivalent to the predicate device in all critical aspects and adheres to relevant guidance documents.

    2. Sample Size and Data Provenance

    • Test Set Sample Size: Not explicitly stated as numerical sample sizes for individual tests. The studies are described as "a series of studies" and "a bacteriostasis study."
    • Data Provenance: Not explicitly stated in terms of country of origin for the specific test data. The submitter is Cachet Pharmaceuticals Pvt. Ltd. from India. The studies were conducted in accordance with FDA guidance documents. The studies appear to be prospective in nature, as they were conducted to support the premarket submission.

    3. Number of Experts and Qualifications for Ground Truth

    • Number of Experts: Not specified.
    • Qualifications of Experts: Not specified. The studies were conducted in accordance with "Micro Appendix C of the Premarket Notification 510 (K) Guidance Document for Contact Lens Care Products" and "FDA's May 1, 1997 Guidance for Industry, Premarket Notification 510 (K) Guidance Document for Contact Lens Care products," implying that relevant scientific and regulatory expertise was involved in designing and interpreting these tests, but specific expert qualifications are not detailed.

    4. Adjudication Method

    Not applicable. This submission is for a medical device (saline solution) and not an AI or diagnostic device that would typically involve expert adjudication of results. The "adjudication" is implicitly done through laboratory testing and comparison to established standards and predicate device characteristics.

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

    Not applicable. This is not a study comparing human reader performance with and without AI assistance, but rather a submission for a sterile saline solution.

    6. Standalone Performance Study

    Yes, a standalone performance was done in the sense that the device's performance was evaluated independently through a series of tests (toxicity, bacteriostasis) to demonstrate its safety and functionality compared to regulatory requirements and the predicate device. These tests evaluated the algorithm (the saline solution's formulation and properties) without human interpretation as a primary output.

    7. Type of Ground Truth Used

    • Toxicity: The ground truth for toxicity was established through in vitro (cytotoxicity) and in vivo (eye irritation) studies, where the outcome (e.g., cell viability, irritation levels) was measured and compared against established safety benchmarks and the predicate device's expected non-toxic profile.
    • Bacteriostasis: The ground truth for bacteriostasis was established by controlled laboratory experiments where the survival and growth of specific microorganisms (Staphylococcus aureus, Escherichia coli, Pseudomonas aeruginosa, Candida albicans, and Aspergillus niger) in the saline solution were directly measured and compared against acceptance criteria outlined in the relevant guidance document (Micro Appendix C).

    8. Sample Size for the Training Set

    Not applicable. This is not a machine learning or AI device that requires a training set. The "training" for such a device would be the extensive research and development that led to its formulation, which is not quantified in terms of a "training set" sample size in this context.

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

    Not applicable, as there is no "training set" in the context of this device. The ground truth for the device's properties (formulation, sterility, safety) is established through standard laboratory testing and adherence to regulatory guidance as detailed in section 7.

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    K Number
    K093367
    Date Cleared
    2010-09-10

    (316 days)

    Product Code
    Regulation Number
    886.5928
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    CACHET PHARMACEUTICALS PVT. LTD.

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

    Sterile Saline Solution is indicated for rinsing & wetting of soft (hydrophilic) contact lenses.

    Device Description

    Sterile Saline Solution is a sterile, preservative free, buffered, isotonic, clear, colourless aqueous solution containing Sodium Chloride, Sodium Borate and Boric Acid. The solution is packaged in plastic sterile single use twist open pods, reusable bottles with dropper tips and caps. Each bottle is closed with tamper resistant cap with a breakable ring, which must be broken in order to open the bottle.

    AI/ML Overview

    This document describes the premarket submission for Cachet Pharmaceuticals Pvt. Ltd.'s Sterile Saline Solution.

    Here's an analysis of the provided information regarding acceptance criteria and supporting studies:

    1. Table of Acceptance Criteria and Reported Device Performance

    Based on the provided text, the acceptance criteria are primarily focused on demonstrating substantial equivalence to existing legally marketed predicate devices and meeting specific safety and performance standards for contact lens care products.

    Acceptance Criteria CategorySpecific Criteria (Implicit/Explicit)Reported Device Performance
    Intended UseMust be for rinsing and wetting of soft (hydrophilic) contact lenses."Sterile Saline Solution is indicated for rinsing & wetting of soft (hydrophilic) contact lenses." This matches the predicate devices' broader indications for use (rinsing, wetting, cleaning, disinfecting, storing). The FDA clearance letter confirms the indication for use: "Sterile Saline Solution is indicated for rinsing and wetting of soft (hydrophilic) contact lenses."
    FormulationMust be comparable to predicate devices in its essential components."Sodium chloride, Sodium borate, Boric acid." This is compared favorably to the predicate devices which also contain Sodium chloride and Boric acid, with one also containing Sodium borate.
    PreservationMust be preservative-free (or equivalent to predicate's preservative status)."No" (preservative). This matches all predicate devices.
    SterilityMust be sterile."Sterile." This matches all predicate devices.
    ToxicityNon-toxic / no evidence of toxicity."A series of cytotoxicity and eye irritation studies of the Sterile Solution were undertaken. In these studies, there was no evidence of toxicity."
    BacteriostasisMust demonstrate no significant growth/survival of specified bacteria over the designed discard period for reclosable containers."A bacteriostasis study was conducted... The results show that Staphylococcus aureous, Escherichia coli, Pseudomonas aeruginosa, Candida albicans and Aspergillus niger have no significant growth and survive over the designed period. The data support the desire discard statement on label up to 30 days."
    Compliance with GuidanceMust meet guidelines set forth in FDA's May 1, 1997 Guidance for Industry, Premarket Notification 510 (K) Guidance Document for Contact Lens Care products."Sterile Saline Solution meets the guideline set forth in FDA's May 1, 1997 Guidance for Industry, Premarket Notification 510 (K) Guidance Document for Contact Lens Care products." The bacteriostasis study was explicitly conducted "in accordance with Micro Appendix C" of this document.
    Substantial EquivalenceOverall device must be substantially equivalent to legally marketed predicate device(s).The submission concludes: "The data provide in this 510 (K) submission concludes that Sterile Saline Solution is substantially equivalent to currently cleared Purilens Saline Solution -K002319, Lens Plus Rewetting Drops -K042562, Unisol- P790011 cleared for marketing under 510 (K) for rinsing and wetting of soft (hydrophilic) contact lenses." The FDA's letter (K093367) confirms this determination.

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

    • Sample Size for Test Set: The document does not explicitly state the sample sizes used for the cytotoxicity, eye irritation, or bacteriostasis studies.
    • Data Provenance: The document does not explicitly state the country of origin for the data or whether the studies were retrospective or prospective. Given the submitter is based in India, it is possible the studies were conducted there. The studies are described in a way that suggests they were prospectively conducted for the submission.

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

    This type of information is not applicable or not provided for this device. The Sterile Saline Solution is a chemical solution, not an imaging or diagnostic AI device that requires expert ground truth establishment for a test set. The "ground truth" for this device relates to established scientific and regulatory standards for sterility, non-toxicity, and inhibition of microbial growth, as determined by laboratory testing and specified protocols rather than expert consensus on interpretations of complex data like medical images.

    4. Adjudication Method for the Test Set

    This is not applicable or not provided. As explained above, the assessment criteria are based on objective laboratory tests against pre-defined thresholds, not on subjective interpretations requiring 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

    This is not applicable. The device is a sterile saline solution, not an AI-powered diagnostic or assistive technology that would involve human readers or MRMC studies.

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

    This is not applicable. The device is a physical product (saline solution), not an algorithm or AI system.

    7. The Type of Ground Truth Used

    The "ground truth" for this device's performance relies on:

    • Laboratory-based scientific testing: This includes cytotoxicity studies, eye irritation studies, and bacteriostasis studies conducted according to established protocols (e.g., Micro Appendix C of FDA Guidance).
    • Regulatory standards and guidance: Compliance with the FDA's "Guidance for Industry, Premarket Notification 510 (K) Guidance Document for Contact Lens Care products."
    • Chemical and physical properties: Assessed through the formulation details (components, preservative status, sterility claim).

    8. The Sample Size for the Training Set

    This is not applicable. As a physical product, there is no "training set" in the context of machine learning or AI algorithms. The development of the solution would involve formulation studies and pilot testing, but these are not considered "training sets" in the AI sense.

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

    This is not applicable for the same reasons as point 8. The "ground truth" for the development of the saline solution would have been established through a combination of pharmaceutical formulation science, existing knowledge of safe and effective ingredients for ophthalmic use, and preliminary laboratory testing to optimize the solution's properties.

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