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510(k) Data Aggregation
(279 days)
CALIBRA MEDICAL, INC.
The Finesse Insulin Delivery System is indicated for the subcutaneous, bolus delivery of physician prescribed insulins, in adult persons requiring such medications for the management of diabetes mellitus.
The Finesse Insulin Delivery System is intended for subcutaneous, bolus delivery of insulin for the management of diabetes mellitus in adult persons requiring insulin.
The Finesse Insulin Delivery System (IDS) is comprised of a sterile. nonpyrogenic, single-use, external, disposable, ambulatory, liquid medication, bolus dosing device (IDD); a single use, non-pyrogenic, sterile. syringe and needle (Fill Syringe); a reusable Inserter; and a Dose Count Card. The device is intended for subcutaneous delivery of clinicianprescribed medications, and is adhered to the skin for up to 72 hours with a biocompatible adhesive.
The Insulin Delivery Device (IDD) is a manual, user filled, positive displacement, bolus dosing pump. The Inserter is used to place the IDD on the skin and simultaneously implant the cannula into the subcutaneous tissues. The syringe and needle are for patient filling of the IDD with liquid medication prior to deployment on the body, and have a maximum capacity of 2ml. The Dose Count Card is utilized by the patient during the dosing session and provides for a written record of date, time and amount of Insulin delivery.
The Finesse IDS materials are biocompatible plastics, elastomers, and stainless steel.
The provided text is a 510(k) summary for the Finesse Personal Insulin Delivery Patch. It describes the device, its intended use, and its equivalence to a predicate device. However, it does not include a table of acceptance criteria, reported device performance metrics, or details about a study designed to prove the device meets specific acceptance criteria in the way typically found for AI/ML devices.
Instead, this submission primarily focuses on establishing "substantial equivalence" to previously cleared devices (K093065 and K100947) based on technological characteristics and intended use. The performance data mentioned are non-clinical and primarily relate to device reliability, usability, and biocompatibility, rather than clinical efficacy metrics or comparisons with human experts.
Therefore, most of the requested information regarding acceptance criteria and a study proving the device meets them (especially in the context of AI/ML performance) cannot be extracted from this document.
Here's what can be inferred and what is explicitly stated:
1. Table of Acceptance Criteria and Reported Device Performance
Not available in the provided document. The submission states, "No clinical performance data is required to validate the intended uses and user needs of the system. Design validation is completed by human factors simulated use and clinical evaluation testing."
The device relies on demonstrating "substantial equivalence" in its intended use, performance, safety, and effectiveness to its predicate devices.
2. Sample size used for the test set and the data provenance
- Test Set Sample Size: Not explicitly stated for any performance claims in the context of a "test set" for an algorithm. The document mentions "human factors and clinical evaluation studies" but does not give sample sizes.
- Data Provenance: Not specified.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable. This device is a manual insulin delivery system, not an AI/ML diagnostic tool that requires expert-established ground truth for its performance evaluation in the way a diagnostic algorithm would.
4. Adjudication method for the test set
Not applicable.
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 not an AI-assisted diagnostic tool for human readers.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This is a hardware device for drug delivery, not an algorithm. Its performance is inherent to its mechanical function.
7. The type of ground truth used
For the non-clinical performance data, the "ground truth" would be the engineering specifications, biocompatibility standards, and functional requirements for a mechanical insulin delivery system. For example:
- Compatibility and stability studies for insulin: Demonstrating chemical, physical, and microbiological stability within the device.
- Design verification studies: Demonstrating wear and mechanical reliability.
- Human factors and clinical evaluation studies: Demonstrating device performance and usability. (Details on how "performance and usability" were measured or what their "ground truth" criteria were are not provided).
8. The sample size for the training set
Not applicable. This is not an AI/ML device that requires a training set.
9. How the ground truth for the training set was established
Not applicable.
Summary of what is present:
-
Non-Clinical Performance Data (Section 10):
- "Compatibility and stability studies have been completed that demonstrate the chemical, physical, microbiological stability and biocompatibility of insulin in the Finesse Insulin Delivery device for the period of time specified in the labeling."
- "Design verification studies have been completed that demonstrate the wear and mechanical reliability of the device for the intended period of time."
- "Design verification studies have been completed that demonstrate the usability and reliability of the Inserter accessory."
- "Human factors and clinical evaluation studies have been completed that demonstrate device performance and usability."
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Clinical Performance Data (Section 11):
- "No clinical performance data is required to validate the intended uses and user needs of the system. Design validation is completed by human factors simulated use and clinical evaluation testing."
The basis of this 510(k) clearance is substantial equivalence to predicate devices K093065 and K100947, and the non-clinical studies confirm the device's functional integrity and safety. It explicitly states that clinical performance data was not required for this 510(k) submission, meaning the acceptance criteria were met through non-clinical testing and demonstration of equivalence.
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(83 days)
CALIBRA MEDICAL, INC.
The Finesse Insulin Delivery System is intended for the subcutaneous, bolus delivery of insulin for the management of diabetes mellitus in persons requiring insulin.
The Finesse Insulin Delivery System is a sterile, nonpyrogenic, single-use, external, disposable, ambulatory, insulin, bolus dosing system through which clinician-prescribed medications are delivered subcutaneously. The Finesse Insulin Delivery System is composed of a positive volume displacement drug delivery device with infusion cannula and integrated Inserter, and a drug delivery device filler. The device is adhered to the skin with a biocompatible adhesive.
The Finesse Insulin Delivery System has an integrated cannula and Inserter. The infusion cannula Inserter is used to place the cannula in the subcutaneous tissues. It contains an insertion needle located in the lumen of the infusion catheter cannula. A safety mechanism prevents premature actuation of the insertion needle mechanism to prevent injuries. Following cannula placement, the needle is retracted within the body of the Inserter to prevent sharps exposure. Once the needle is retracted, the Inserter automatically releases the Inserter from the drug delivery component.
The Finesse Insulin Delivery System materials are biocompatible plastics, elastomers, and stainless steel.
The provided text does not contain information about acceptance criteria or specific studies that prove the device meets these criteria in the typical format of a clinical or performance study. Instead, it describes general design verification and user studies without specific metrics or methodologies.
Here's a breakdown of the available information based on your requested points:
1. A table of acceptance criteria and the reported device performance
The document mentions "Design verification studies have been completed that demonstrate the wear and mechanical reliability of the device for the period of time specified in the device labeling" and "User studies have completed that demonstrate the readability and user comprehension of the labeling."
However, specific acceptance criteria (e.g., "device must deliver X +/- Y% of intended insulin dose") and quantitative performance results are NOT provided in this 510(k) summary.
2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
This information is NOT provided in the document.
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)
This information is NOT provided in the document. The studies mentioned are general "design verification" and "user studies," which typically don't involve expert establishment of ground truth in the same way a diagnostic device might.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This information is NOT provided in the document.
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 as the device is an insulin delivery system, not an AI-powered diagnostic device that involves human "readers."
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
This information is NOT applicable as the device is an insulin delivery system, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
This information is NOT provided in the document. The general nature of the studies ("compatibility and stability," "wear and mechanical reliability," "user comprehension") suggests that ground truth would be established through direct measurements, chemical analysis, mechanical testing, and user feedback, rather than expert consensus on diagnostic interpretations.
8. The sample size for the training set
This information is NOT provided in the document. The device is a mechanical/electronic system, not a machine learning algorithm that typically requires a "training set."
9. How the ground truth for the training set was established
This information is NOT applicable as the device is a medical device, not a machine learning algorithm.
Summary of what is available:
The 510(k) Summary for the Finesse Personal Insulin Delivery Patch (K100947) states that:
- Compatibility and stability studies were performed to demonstrate chemical, physical, microbiological stability, and biocompatibility of insulin in the device for the specified period.
- Design verification studies were completed to demonstrate the wear and mechanical reliability of the device for the specified period.
- User studies were completed to demonstrate the readability and user comprehension of the labeling.
The document indicates that these studies (without providing details like sample sizes, specific metrics, or methodologies) were sufficient for FDA to determine substantial equivalence based on the modified labeling for extended usage duration. The primary change from the predicate device (K093065) was this extended usage period (from an unspecified duration to 48-72 hours, consistent with insulin manufacturer labeling).
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(112 days)
CALIBRA MEDICAL, INC.
The Finesse Insulin Delivery System is intended for the subcutaneous, bolus delivery of insulin for the management of diabetes mellitus in persons requiring insulin.
The Finesse Insulin Delivery System is a sterile, nonpyrogenic, single-use, external, disposable, ambulatory, insulin, bolus dosing system through which clinician-prescribed medications are delivered subcutaneously. The Finesse Insulin Delivery System is composed of a positive volume displacement drug delivery device with infusion cannula and integrated Inserter, and drug delivery device filler. The device is adhered to the skin for up to 48 hours with a biocompatible adhesive. The Finesse Insulin Delivery System has an integrated cannula and Inserter. The infusion cannula Inserter is used to place the cannula in the subcutaneous tissues. It contains an insertion needle located in the lumen of the infusion catheter cannula. A safety mechanism prevents premature actuation of the insertion needle mechanism to prevent injuries. Following cannula placement, the needle is retracted within the body of the Inserter to prevent sharps exposure. Once the needle is retracted, the Inserter automatically releases the Inserter from the drug delivery component. The Finesse Insulin Delivery System materials are biocompatible plastics, elastomers, and stainless steel.
The provided text describes a 510(k) summary for the Finesse Personal Insulin Delivery Patch. It outlines the device description, intended use, technological characteristics, and non-clinical performance data. However, it explicitly states:
"No clinical performance data is required to validate the intended uses and user needs of the system. Design validation is completed by human factors simulated use testing."
This means that the document does not contain acceptance criteria in terms of clinical performance metrics (like sensitivity, specificity, accuracy, etc.) for the device itself or any study that proves the device meets such criteria through clinical trials. Instead, reliance is placed on conformance to consensus standards, FDA guidance, and human factors simulated use testing for design validation.
Therefore, many of the requested items in your prompt, particularly those related to clinical performance, a test set, ground truth, experts, and comparative effectiveness studies, cannot be extracted from this document.
Here's what can be extracted based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
Given the explicit statement that no clinical performance data is required and that design validation is completed by human factors simulated use testing, the acceptance criteria are primarily defined by adherence to a list of consensus standards and FDA guidance. The document does not provide specific quantitative performance metrics beyond this.
Acceptance Criteria (Primary Source) | Reported Device Performance (Primary Source) |
---|---|
Conformance to various ANSI/AAMI/ISO, USP, IEC, and ASTM standards (e.g., ISO 10993-1 for biocompatibility, ASTM F 88-07a for seal strength, ISO 11608-1 for pen-injectors) | "Data establishing conformance to the following consensus standards and FDA guidance is maintained in the design history file and establishes the substantial equivalence with the predicate devices. The conclusions drawn from the data support the equivalence, safety, and effectiveness of the system." |
Conformance to FDA Guidance documents (e.g., Guidance on the Content of Premarket Notification 510(k) Submissions for Piston Syringes) | "Data establishing conformance to the following consensus standards and FDA guidance is maintained in the design history file and establishes the substantial equivalence with the predicate devices. The conclusions drawn from the data support the equivalence, safety, and effectiveness of the system." |
Design validation by human factors simulated use testing | "Design validation is completed by human factors simulated use testing." (No specific performance metrics from this testing are detailed in the provided text.) |
2. Sample size used for the test set and the data provenance
Not applicable, as no clinical performance test set data is presented. The design validation was conducted through "human factors simulated use testing," but details on sample size, data provenance, or specific test outcomes are not provided.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable, as no clinical performance test set data requiring expert ground truth is presented.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable, as no clinical performance test set data requiring adjudication is presented.
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 an insulin delivery system, not an AI-powered diagnostic or assistive tool, and the document explicitly states no clinical performance data was required, let alone an MRMC study with AI.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This device is not an algorithm, but a physical medical device requiring human interaction.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
Not applicable for clinical performance data. The "ground truth" for the device's substantial equivalence and safety/effectiveness is based on its conformance to established consensus standards and FDA guidance, as well as the outcome of human factors simulated use testing.
8. The sample size for the training set
Not applicable, as this is a physical medical device and not an AI algorithm that undergoes training on a data set.
9. How the ground truth for the training set was established
Not applicable, as this is a physical medical device and not an AI algorithm.
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