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510(k) Data Aggregation
(238 days)
Cork Medical Products, LLC
The Nisus Touch Negative Pressure Wound Therapy Pump is indicated for use in patients who would benefit from negative pressure wound therapy particularly as the device may promote wound healing by the removal of excess exudates, infectious material, and tissue debris.
Cork Medical Products has developed a negative pressure wound therapy pump with the same intended use as its predicate device (K140022) but has the addition of an integrated touch screen. The Nisus Touch and Nisus pumps are nearly identical in appearance and utilize the same buttons to power the device and adjust pump settings; however, the Nisus Touch offers the alternative touch screen to easily maneuver between settings based on operator preference. Visual and audible alarms are consistent with the predicate device K140022 and alert the user when critical battery, pressure leakage, system blockage, and full canister occurs. Additionally, the Nisus Touch mechanical components and therapy application are identical to the Nisus pump. The intent of the new model is to appeal to users who encounter touch screens in daily technology and might feel navigation by touch screen is more simplistic.
The components included within the Cork Nisus Touch NPWT Pump are:
- Nisus Touch Negative Pressure Wound Therapy Pump
- Nisus Touch Pump Battery Charger
Accessory components are required to operate the device. Iniection molded components are sonically welded to form a canister designed to mate with the pump and collect excess exudates, infectious material, and tissue debris. The canister design was previously provided clearance within the Nisus NPWT system 510k application (K140022).
The Wound Kit comes in multiple iterations containing a minimum of one port pad, wound foam and peel and stick drape. These components are used in coniunction with the pump to ensure safe transfer of the wound debris to the canister. The NPWT Accessories were previously provided clearance on K132004. Our application for the Nisus Touch NPWT system includes no revisions to these previously cleared components.
This document describes the Nisus Touch Negative Pressure Wound Therapy Pump, a device that facilitates wound healing by removing exudates, infectious material, and tissue debris.
1. Table of Acceptance Criteria and Reported Device Performance:
The document does not explicitly present a table of acceptance criteria with numerical targets. Instead, it states that the device underwent "bench performance testing to establish basic functionality" and that "The testing results show the Nisus Touch NPWT pump functioned as expected."
Based on the "NONCLINICAL TESTS" section, here are the tests conducted and the general performance reported:
Test/Criteria Category | Specific Tests Conducted | Reported Performance / Conclusion |
---|---|---|
Functional Performance | Continuous Mode Low Pressure (40-mmHg) Test | Functioned as expected |
Continuous Mode Typical Pressure (125-mmHg) Test | Functioned as expected | |
Continuous Mode High Pressure (200-mmHg) Test | Functioned as expected | |
Intermittent Mode Test | Functioned as expected | |
Low Battery Test | Functioned as expected | |
Leakage Alarm Test | Functioned as expected | |
Blockage Alarm Test | Functioned as expected | |
Canister Full Alarm Test | Functioned as expected | |
Suction Capacity and Maximum Vacuum Pressures | Functioned as expected (while the predicate has 4 liters/minute suction and 220 mmHg max vacuum, the subject device has ~8-10 liters/minute suction and 200 mmHg max vacuum. The report implies these are acceptable). | |
Software Verification & Validation | Software V&V testing according to FDA guidance for "moderate" level of concern. | Documentation provided and aligned with guidance. |
Electrical Safety & EMC | Testing against IEC 60601-1, IEC 60601-1-6, IEC 60601-1-11, and IEC 60601-1-2. | System complies with the respective standards. |
Usability Engineering | Testing against IEC 62366:2007 (Application of usability engineering to medical devices). | Not explicitly stated "complies" but listed as "Additional non-clinical testing conducted," implying meeting requirements. |
2. Sample Size Used for the Test Set and Data Provenance:
The document refers to "bench performance testing" using "simulated wound exudate" and a "wound test bed fixture." No specific sample size (e.g., number of devices tested, number of simulated scenarios) is mentioned for this testing. The data provenance is from non-clinical bench testing, not from human subjects or clinical data. Therefore, there is no country of origin or retrospective/prospective classification in the typical sense.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts:
Not applicable. The ground truth for this device's performance was established through engineering specifications and bench testing against those specifications. No human expert consensus was used to establish ground truth for this type of performance testing.
4. Adjudication Method for the Test Set:
Not applicable. As the testing was bench performance testing against engineering specifications, there was no need for an adjudication method by human experts.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was Done:
No, an MRMC comparative effectiveness study was not done. The document explicitly states: "No clinical testing required to support this 510(k) submission. No clinical testing has been performed."
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was Done:
Given that this is a physical medical device (a negative pressure wound therapy pump) and not an AI/software algorithm intended for diagnostic or prognostic purposes, the concept of "standalone (algorithm only)" performance does not directly apply. The performance evaluated was the device's physical and software-controlled functionality.
7. The Type of Ground Truth Used:
The ground truth used for these non-clinical tests was based on engineering specifications and expected functional behavior of a negative pressure wound therapy pump, including adherence to established electrical safety, EMC, and usability standards. For example, alarms for leakage or blockage are expected to activate under specific simulated conditions according to design specifications.
8. The Sample Size for the Training Set:
Not applicable. This device is a physical medical device with integrated software for control, not a machine learning or AI algorithm that requires a "training set" in the context of learning data. The software within the device operates based on pre-programmed logic.
9. How the Ground Truth for the Training Set was Established:
Not applicable, as there is no "training set" for a machine learning algorithm. The software functionality is based on established engineering principles and medical device requirements.
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(294 days)
CORK MEDICAL PRODUCTS LLC
The Cork Medical Products Nisus Negative Pressure Wound Therapy System is indicated for use in patients who would benefit from negative pressure wound therapy particularly as the device may promote wound healing by the removal of excess exudates, infectious material, and tissue debris.
Cork Medical Products has developed a negative pressure wound therapy system. The Cork Medical Products Nisus Negative Pressure Wound Therapy System is indicated for use in patients who would benefit from negative pressure wound therapy particularly as the device may promote wound healing by the removal of excess exudates, infectious material, and tissue debris.
The components included within the Cork NPWT System are:
- Nisus Negative Pressure Wound Therapy Pump
- Nisus NPWT Canister 250-mL
- Nisus Pump Battery Charger
- Cork Medical Products NPWT Wound Dressing Kit – Medium
- Cork Medical Products NPWT Wound Dressing Kit - Large
This document is a 510(k) premarket notification for the "Cork Medical Products Nisus Negative Pressure Wound Therapy System." It details the device, its intended use, and a comparison to a predicate device to establish substantial equivalence.
Here's an analysis of the provided text in relation to your questions:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly state formal "acceptance criteria" for each performance test in a tabular format with corresponding reported performance metrics for the Cork Medical Products Nisus NPWT System. Instead, it states that "All biocompatibility test results were negative and passed the pre-defined test acceptance criteria," and that nonclinical tests were conducted "to ensure the Cork Medical Products Nisus Negative Pressure Wound Therapy System is substantially equivalent to the Genadyne A4 Wound Dressing Vacuum System Kit and A4-XLR8 Foam Dressing." This implies the acceptance criteria for the nonclinical tests were equivalence to the predicate device's performance characteristics.
The comparison table on pages 5 and 6 provides a direct comparison of technical data between the new device and the predicate device. This essentially serves as the 'performance' of both devices that the FDA used to determine substantial equivalence.
Here's a summarized table based on the provided "Predicate Product Comparison Table" and "Nonclinical Tests" section, inferring acceptance criteria as being substantially equivalent to the predicate:
Acceptance Criteria (Inferred: Substantially equivalent to Predicate Device) | Cork Medical Products Nisus NPWT System Performance | Predicate Device (Genadyne A4 Wound Dressing Vacuum System Kit) Performance | Study Type |
---|---|---|---|
PUMP - TECHNICAL DATA | Nonclinical Tests | ||
Suction Capacity | 4 liters / minute | 5 liters / minute | Head to head performance testing |
Maximum Vacuum Pressure | 220-mmHg | 230-mmHg | Head to head performance testing |
Power Requirements | 18 VDC, 2A | 24 VDC, 1A | Head to head performance testing |
Battery Type | Li-ion | Ni-MH | Comparison of specifications |
Dimensions | 151 x 108 x 71-mm (~6 x 4.3 x 2.8-inches) | 200 x 180 x 80-mm (~7.9 x 7.1 x 3.1-inches) | Comparison of specifications |
Weight | 0.575-kg (~1.27-lb) | 1.36-kg (~3-lb) | Comparison of specifications |
Reusable | Yes | Yes | Comparison of specifications |
Sterile | Non-sterile | Non-sterile | Comparison of specifications |
Compliance | IEC 60601-1:2005, 3rd Edition (AAMI ES 60601-1, CAN/CSA C22.2 No. 60601-1-08, EN 60601-1) | ||
IEC 60601-1-2:2007 | |||
IEC 60601-1-6:2010 / IEC 62366:2010 | |||
IEC 60601-1-11:2010 | UL 60601-1 | ||
CAN/CSA C22.2 No. 601-1-M90 | Comparison of specifications | ||
Storage & Shipping Conditions | -25°C (-13°F) without relative humidity control to 44°C (111°F) up to 93% relative humidity (non-condensing) | -18°C to +43°C (0°F to 110°F) | |
Relative Humidity 10% to 95% | |||
700 – 1060 mbar Atmospheric pressure | Comparison of specifications | ||
Environmental Conditions | Operating Temperature: 18°C to 34°C (65°F to 94°F) | ||
Operating Relative Humidity: 10% - 95% | |||
Operating Pressure: 700-hPA – 1060-hPA (10.15-atm – 15.37-atm) atmospheric pressure | 18°C to 34°C (65°F to 94°F) Relative Humidity 10% to 95% | ||
700 – 1060 mbar Atmospheric pressure | Comparison of specifications | ||
ACCESSORIES | |||
Canisters | 250-mL disposable canister | ||
Canister includes hydrophobic membrane filter and liquid solidifier | 800-mL disposable canister with a built-in hydrophobic shut off filter for overflow protection | Comparison of specifications | |
Wound Dressing Kit | Wound Foam: Reticulated polyether based polyurethane foam (A30M) | ||
Wound Drape: Transparent polyurethane film with adhesive backing | |||
Port Pad Assembly: Silicone port pad, Port Pad Skirt (Transparent polyurethane film with adhesive backing), Drainage tubing, Luer connector, Pinch clamp | K082676: | ||
Non-adherent gauze | |||
Anti-microbial gauze | |||
Transparent film dressing | |||
Silicone flat drain | |||
K092992: Polyurethane foam (A30M) | Comparison of specifications | ||
Sterilization | Individual kit components individually sterilized by Ethylene Oxide or Gamma Irradiation | (cleared on K132004) - implied similar sterilization | Comparison of specifications |
PERFORMANCE TESTS | Nonclinical Tests | ||
Continuous Mode Low Pressure (40-mmHg) Test | Passed (implied by "substantially equivalent") | (Performance of predicate device) | Head to head performance testing |
Continuous Mode Typical Pressure (125-mmHg) Test | Passed (implied by "substantially equivalent") | (Performance of predicate device) | Head to head performance testing |
Continuous Mode High Pressure (200-mmHg) Test | Passed (implied by "substantially equivalent") | (Performance of predicate device) | Head to head performance testing |
Intermittent Mode Test (high pressure: 125-mmHg, low pressure: 40-mmHg) | Passed (implied by "substantially equivalent") | (Performance of predicate device) | Head to head performance testing |
Leakage Alarm Test | Passed (implied by "substantially equivalent") | (Performance of predicate device) | Head to head performance testing |
Canister Full Alarm Test | Passed (implied by "substantially equivalent") | (Performance of predicate device) | Head to head performance testing |
Blockage Alarm Test | Passed (implied by "substantially equivalent") | (Performance of predicate device) | Head to head performance testing |
Operating Parameter Test | Passed (implied by "substantially equivalent") | (Performance of predicate device) | Head to head performance testing |
Storage & Shipping Parameter Test | Passed (implied by "substantially equivalent") | (Performance of predicate device) | Head to head performance testing |
Canister Real-Time Aging | Passed (implied by "substantially equivalent") | (Performance of predicate device) | Head to head performance testing |
Wound Dressing Kit Aging | Passed (implied by "substantially equivalent") | (Performance of predicate device) | Head to head performance testing |
BIOCOMPATIBILITY | |||
Cytotoxicity Test | Negative/Passed | (Implied standard biocompatibility) | ISO 10993 testing standards |
Intracuteneous Reactivity Test | Negative/Passed | (Implied standard biocompatibility) | ISO 10993 testing standards |
Sensitization Test | Negative/Passed | (Implied standard biocompatibility) | ISO 10993 testing standards |
2. Sample size used for the test set and the data provenance
- Sample size for nonclinical tests: Not explicitly stated for each test beyond "head to head performance testing," "Canister Real-Time Aging," and "Wound Dressing Kit Aging." For the biocompatibility tests, the sample size refers to the "wound foam and wound drape components" and "individual components included in the Cork Medical Products Wound Dressing Kit." Specific numbers are not provided.
- Data provenance: The tests were conducted internally by Cork Medical Products ("Cork Medical conducted head to head performance testing") and a Biocompatibility Risk Assessment was completed by "Nelson Laboratories." The data origin is thus from Cork Medical's testing and a third-party lab. No information about country of origin of the data or whether it was retrospective or prospective is mentioned, which is typical for premarket notifications focus on non-clinical engineering and bench testing.
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 negative pressure wound therapy system, not an AI/imaging device requiring expert interpretation for ground truth. The "ground truth" for its performance is derived from physical measurements (pressure, flow, alarm functionality) and standardized biocompatibility testing.
4. Adjudication method for the test set
Not applicable. As noted above, this device does not involve expert adjudication for establishing ground truth, as it's a mechanical/electrical device.
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 or imaging tool.
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.
7. The type of ground truth used
- Nonclinical Performance Tests: The "ground truth" for the nonclinical performance tests (e.g., pressure, alarms) was established through engineering and bench testing protocols using "simulated wound exudate" and a "wound test bed fixture." The implicit ground truth standard for these tests was the demonstrated performance of the legally marketed predicate device.
- Biocompatibility Tests: The ground truth was based on international standards, specifically ISO 10993 testing standards, with predefined acceptance criteria for cytotoxicity, intracutaneous reactivity, and sensitization.
8. The sample size for the training set
Not applicable. This device does not use machine learning or AI, and therefore does not have "training sets" in that context. Its performance is based on engineering design and testing, not learned data.
9. How the ground truth for the training set was established
Not applicable (as above).
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