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510(k) Data Aggregation
(43 days)
Airway Technologies d/b/a Airway Management
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(102 days)
(dba Springbok Analytics)
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(159 days)
Guangzhou Decheng Biotechnology Co., Ltd.
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(118 days)
Medtronic Sofamor Danek USA, Inc.
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(241 days)
(D.B.A.) FluidAI Medical
The Origin™ system is comprised of the Origin™ inline device and Origin™ App. The Origin™ system is indicated for use in conjunction with a compatible drainage system by a trained healthcare professional during postoperative recovery in a hospital setting. The Origin™ inline device is placed between the surgical drainage catheter and reservoir system to continuously measure the pH of drainage fluid to provide additional information on effluent characteristics. The device is not intended to diagnose or treat any clinical condition.
Origin™ is an inline biosensor system that is integrated between an off-the-shelf drainage catheter and reservoir system and is designed to monitor real-time changes in drained effluent characteristics. Origin™ system continuously monitors the pH of wound drainage. Origin™ App is a mobile application for displaying and analyzing data from the Origin™ inline device. Origin™ App is pre-installed on an Android mobile device supplied by FluidAI. The Origin™ inline device connects to Origin™ App via Bluetooth.
The provided FDA 510(k) clearance letter and summary document for the Origin™ system primarily focus on the non-clinical performance of the device, particularly its analytical performance in measuring pH. It does not describe a study involving human readers or multi-reader multi-case (MRMC) comparative effectiveness. Therefore, some of the requested information, particularly related to clinical studies, human expert involvement in ground truth establishment for a test set, and MRMC studies, is not present in the provided text.
However, based on the analytical performance studies described, we can extract the following information:
1. Acceptance Criteria and Reported Device Performance
The document implicitly defines acceptance criteria through the results presented. The "Overall" pH range for linearity, for example, is 0.1446 pH units from 5 to 9, and 0.1 pH units from 4-10 using buffer solutions. For precision, the "Within-Laboratory" precision (total) is 0.0922 SD (1.46% CV) for sample A (pH ~6.3) and 0.1650 SD (2.10% CV) for sample B (pH ~7.85).
Since the document presents the results of studies conducted to demonstrate that the device meets some internal performance goals, we can infer that the reported values met their pre-specified acceptance criteria for analytical performance. However, the specific numerical acceptance thresholds (e.g., "Max Deviation from Linearity must be
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(200 days)
JJGC Indústria e Comércio de Materiais Dentários S.A.
Zirconia Implants:
The Neodent Implant System is intended to be surgically placed in the bone of upper or lower jaw to provide support for prosthetic devices, such as artificial teeth, to restore chewing function. It may be used with single-stage or two-stage surgical procedures, for single or multiple unit restorations, and may be loaded immediately when good primary stability is achieved and with physiological occlusion loading. Multiple teeth applications can be rigidly splinted. The implants with length of 5 mm (short implants) may be used only with two-stage surgical procedures. The recommended healing time before loading is between 10 to 12 weeks.
Zi Transmucosal Cover Screw and Healing:
The Neodent Implant System is intended to be surgically placed in the bone of the upper or lower jaw to provide support for prosthetic devices, such as artificial teeth, to restore chewing function. It may be used with single-stage or two-stage surgical procedures, for single or multiple unit restorations, and may be loaded immediately when good primary stability is achieved and with physiological occlusal loading. Multiple teeth applications can be rigidly splinted.
Zi Transmucosal Provisional Coping:
The Neodent Implant System is intended for surgical procedures in maxilla or mandible, providing support for prosthetic devices such as artificial teeth, to restore chewing function. It may be used with single-stage or two-stage procedures, for single- or multi-unit restorations, and may be loaded immediately when good primary stability is achieved and with appropriate occlusal loading.
Zi Transmucosal Abutment Replacement Screw:
The Neodent Implant System is intended to be surgically placed in the bone of the upper or lower jaw to provide support for prosthetic devices, such as artificial teeth, to restore chewing function. It may be used with single-stage or two-stage procedures, for single or multiple unit restorations, and may be loaded immediately when good primary stability is achieved and with appropriate occlusal loading.
Zi Transmucosal Universal Base:
The Universal Ceramic Base Zi Transmucosal 5.0 is an abutment placed over Neodent Zi Transmucosal 5.0 Ceramic Implant System in order to provide support for custom-made prosthetic restorations, such as copings or crowns. It may be used for cement or screw-retained single unit restorations. All digitally designed copings and/or crowns to be used with the Neodent Zirconia Base Abutment System are intended to be sent to Straumann for manufacture at a validated milling center.
Zirconia Base for Bridge:
The Zirconia Base for Bridge is an abutment placed over Neodent Zirconia Implants in order to provide support for custom-made prosthetic restorations. It may be used for cement or screw-retained multi-unit restorations. All digitally designed copings and/or crowns to be used with the Neodent Zirconia Base Abutment System are intended to be sent to Straumann for manufacture at a validated milling center.
Zirconia Base C:
The Zirconia Base C is an abutment placed over Neodent Zirconia Implants in order to provide support for customized prosthetic restorations, such as copings or crowns. It may be used for single-unit restorations that are screw- or cement-retained in esthetic areas over implants installed in the maxilla or mandible. All copings and/or crowns digitally designed for use with the Titanium Base C are to be designed using Sirona inLab software or Sirona CEREC Software and manufactured using a Sirona CEREC or inLab MC X or MC XL milling unit.
This premarket notification includes new ceramic devices into Neodent Implant System, which are compatible with Zirconia Implant System. The Zirconia Implants and Abutments proposed on this submission are similar to devices already cleared in previous submissions of Neodent Implant System – Zirconia Implant System, according to predicate devices described above. This submission intends to expand the portfolio with new solutions and diameter, in order to provide more treatment options to the customers.
The Zirconia Implants are manufactured in Zirconia Y-TZP and are available in Bone Level (BL) or Tissue Level (TL or Transmucosal) configurations. The Zirconia Implants (BL) are available in a diameter of 5.0 mm and lengths in a range of 8 to 13 mm. The Zi Transmucosal Implants (TL) are available in a diameter of 5.0 mm and lengths in a range of 5 to 11.5 mm.
The Zi Transmucosal Healing and Cover Screw are temporary abutments manufactured in PEEK and used during the healing phase. They are compatible with the Zi Transmucosal Implants Ø5.0. The Zi Transmucosal Healing Abutment is available in the heights of 2 and 3.5mm.
The Zi Transmucosal Provisional Coping is a temporary abutment made of polycarbonate (PC) and has a double function: used for molding procedures or production of provisional restoration.
The Zi Transmucosal Abutment Replacement Screw is a prosthetic component manufactured in titanium alloy and used to fix the fix the Zi Transmucosal Base to the Zi Transmucosal Implant.
The Zi Transmucosal Universal Base is a two-piece abutment of base and top-half prosthetic structure to provide support for customized single-unit restorations over Zi Transmucosal Implant (TL). The base is manufactured in Zirconia Y-ZTP and used with a patient-specific top-half prosthetic structure. The two-piece abutment has a cementable portion of 4mm and is available with gingival heights of 0.3, 1.0 and 1.5 mm. The top-half prosthetic structure to be used with Zi Transmucosal Universal Base must be designed and milled in a Straumann Validated Milling center, using the following restoration materials and dimensions:
Material: IPS e.max CAD HT, Associated Material 510(k): K132209, Minimum wall thickness: 0.9 mm, Maximum angulation: 30°
Material: IPS e.max CAD LT, Associated Material 510(k): K132209, Minimum wall thickness: 0.9 mm
Material: N!ce, Associated Material 510(k): K171773, Minimum wall thickness: 1.0 mm
Material: IVOCLAR Multilink cement, Associated Material 510(k): K130436, Minimum wall thickness: N/A
Material: Zirconia N!ce® LT, Associated Material 510(k): K222836, Minimum wall thickness: 0.4 mm
Material: Zirconia N!ce® HT, Associated Material 510(k): K222836, Minimum wall thickness: 0.4 mm
Material: Zirconia N!ce® XT, Associated Material 510(k): K222836, Minimum wall thickness: 0.4 mm
Material: PMMA N!ce, Associated Material 510(k): K071548, Minimum wall thickness: 0.7 mm
Material: Panavia—Kuraray Cement, Associated Material 510(k): K150704, Minimum wall thickness: N/A, Maximum angulation: N/A
The Zi Base for Bridge is a two-piece abutment of base and top-half prosthetic structure to provide support for customized multi-unit restorations over Zirconia Implants (BL). The base is manufactured in Zirconia Y-ZTP and used with a patient-specific top-half prosthetic structure. The two-piece abutment has a cementable portion of 4mm and is available with gingival heights of 1.5, 2.5 and 3.5 mm. The top-half prosthetic structure to be used with Zi Base for Bridge must be designed and milled in a Straumann Validated Milling center, using the following restoration materials and dimensions:
Material: Zirconia N!ce® LT, Associated Material 510(k): K222836, Minimum wall thickness: 0.4 mm, Maximum angulation: 30°
Material: Zirconia N!ce® HT, Associated Material 510(k): K222836, Minimum wall thickness: 0.4 mm
Material: Zirconia N!ce® XT, Associated Material 510(k): K222836, Minimum wall thickness: 0.4 mm
Material: PMMA N!ce, Associated Material 510(k): K071548, Minimum wall thickness: 0.7 mm
Material: Panavia—Kuraray Cement, Associated Material 510(k): K150704, Minimum wall thickness: N/A, Maximum angulation: N/A
The Zi Base C is a two-piece abutment of base and top-half prosthetic structure to provide support for customized single-unit restorations over Zirconia Implants (BL). The base is manufactured in Zirconia Y-ZTP and used with a patient-specific top-half prosthetic structure. The two-piece abutment has a cementable portion of 4mm and is available with gingival heights of 1.5, 2.5, 3.5 and 4.5 mm. The top-half prosthetic structure to be used with Zi Base C must be designed and milled in a Sirona InLab Validated Workflow, using the following restoration materials and dimensions:
Material: IPS e.max CAD, Associated Material 510(k): K132209, Minimum wall thickness: 0.9 mm, Maximum angulation: 20°
Material: IVOCLAR Multilink cement, Associated Material 510(k): K130436, Minimum wall thickness: N/A, Maximum angulation: N/A
All these abutments have an internal connection with the implants (ZiLock) and the prosthetic platform is identical for all subject devices described in this submission. They are intended for single use and provided sterile via Ethylene Oxide method, along with undergoing moist heat sterilization after end-user customization.
The provided FDA 510(k) clearance letter and its associated summary for the Neodent Implant System - Zirconia Implant System contain extensive information about the device, its intended use, and comparisons to predicate devices. However, it does not include specific acceptance criteria with numerical thresholds directly stated within the tables, nor does it detail a study that directly proves the device meets such criteria in terms of performance metrics like sensitivity, specificity, or image quality assessments.
Instead, the submission focuses on demonstrating substantial equivalence to predicate devices through various tests, implying that if the new device performs similarly to or better than previously cleared devices, it meets the necessary standards. The performance testing section describes the types of tests conducted (e.g., dynamic fatigue, torsion, insertion, pull-out, and software validation), but it does not present clear quantitative acceptance criteria or the specific performance results in a comparative table format.
Therefore, many of the requested fields cannot be directly extracted from the provided text as they pertain more to the performance evaluation of AI/software in interpreting medical images, which is not the primary focus of this dental implant submission.
Here's an attempt to answer the questions based on the available information, noting where information is not explicitly provided in the document:
Acceptance Criteria and Device Performance Study for Neodent Implant System - Zirconia Implant System
The FDA 510(k) summary for the Neodent Implant System - Zirconia Implant System focuses on demonstrating substantial equivalence to predicate devices through a combination of bench testing, software validation, MRI compatibility, biocompatibility, and sterilization validation. It does not present specific quantitative acceptance criteria or performance metrics directly from a comparative study in the way one might expect for an AI/software-based medical device (e.g., sensitivity, specificity thresholds). Instead, the "acceptance criteria" are implicitly met by demonstrating that the proposed devices perform at a level substantially equivalent to legally marketed predicate devices under standardized testing conditions.
1. A table of acceptance criteria and the reported device performance
As mentioned, explicit numerical acceptance criteria and reported device performance in a comparative table (e.g., for diagnostic accuracy) are not provided in this 510(k) summary. The summary indicates that tests were conducted according to relevant ISO standards and FDA guidance, and the results demonstrated that the subject devices exhibit a level of performance substantial equivalent to the predicate and reference devices.
Below is a conceptual table based on the types of tests mentioned, noting that specific numerical acceptance criteria and performance data are not detailed in the provided text.
Acceptance Criteria Category (Implicit) | Standard/Guidance | Reported Device Performance (Summary) |
---|---|---|
Dynamic Fatigue Strength | ISO 14801, FDA Guidance (Class II Special Controls) | Demonstrated a level of performance substantial equivalent to predicate and reference devices in identical conditions. |
Torsion Strength | Not specified | Adequate torsion strength in accordance with recommended IFU installation torque. |
Insertion Torque | Not specified | Evaluated insertion torque in sawbones material (Bone type I, II, III, IV). (Specific values not given). |
Implant Surface Area & Pull-Out Strength | Not specified | Greater surface area compared to reference devices; higher resistance values in Pull Out Test. |
Software Validation (Sirona Digital Workflow) | Not specified | Accuracy requirement was met; critical design parameters (min wall thickness, max angulation) respected and monitored. |
MRI Compatibility | K182620, FDA Guidance | MR conditional labeling from K182620 is applicable; safe for scanning under previously established parameters. |
Biocompatibility | ISO 10993-1, ISO 10993-18, ISO 10993-5, FDA Guidance | Subject devices are equivalent in material and manufacturing processes to predicates; no new issues raised; no additional testing required. |
Sterilization Validation (Ethylene Oxide) | ISO 11135:2014 | Validated to a Sterility Assurance Level (SAL) of 1x10⁻⁶; residuals below max allowable limits per ISO 10993-7. |
Sterilization Validation (Moist Heat) | ISO 17665-1 | Validated using parameters described in IFU. |
Endotoxin Test | ANSI/AAMI ST72:2011, ISO 11737-3, US Pharmacopeia chapter 85 | Results |
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(90 days)
Bruker Daltonics GmbH & Co. KG
The MBT Sepsityper is a qualitative in vitro diagnostic device consisting of an MBT-CA (Sepsityper) software extension and a reagent kit (MBT Sepsityper Kit US IVD) for use in conjunction with other clinical and laboratory findings to aid in the early diagnosis of bacterial and yeast infections from positively flagged blood cultures using the MALDI Biotyper CA System.
The MBT Sepsityper Kit US IVD is a disposable blood culture processing device that includes associated reagents that are intended to concentrate and purify microbial cells from blood culture samples identified as positive by a continuous monitoring blood culture system and confirmed to demonstrate the presence of a single organism as determined by Gram stain. This sample preparation manual method is performed by laboratory health professionals in a clinical diagnostic setting. Subculturing of positive blood cultures is necessary to recover organisms for identification of organisms not identified by the MBT-CA System, for susceptibility testing and for differentiation of mixed growth.
Positive MBT Sepsityper results do not rule out co-infection with organisms that may not be detected by the MBT-CA System. Results of the MBT Sepsityper should not be used as the sole basis for diagnosis, treatment, or other patient management decisions. Results of the MBT Sepsityper should be correlated with Gram stain results and used in conjunction with other clinical and laboratory findings to aid in the diagnosis of bacterial and yeast bloodstream infections.
Organisms recovered from positive blood culture bottles that are suitable for identification using the MBT Sepsityper Kit US IVD and MBT-CA Systems are listed in the MALDI Biotyper CA System Package Insert Reference Library.
The MALDI Biotyper CA System uses MALDI (matrix-assisted laser desorption/ionization) TOF (time of flight) mass spectrometry technology for the identification of organisms isolated from clinical samples. Identification can be performed from an isolated colony or from a cell extract. The sample material is transferred to a target plate, dried and overlaid with a matrix. The MBT FAST Shuttle US IVD is an optional hardware tool that may be used for drying the samples deposited on the MALDI target plate under controlled conditions.
The MALDI process transforms the proteins and peptides from the isolated microorganisms into positively charged ions. This is achieved by irradiating the matrix-sample composite with a UV laser. The matrix absorbs laser energy and transfers protons to the intact proteins or peptides in the gas phase. These ions are electrostatically accelerated and arrive in the flight tube at a mass-dependent speed. Because different proteins/peptides have different masses, ions arrive at the detector at different times (time of flight). The MBT-CA System measures the time (in the nanosecond range) between pulsed acceleration and the corresponding detector signal of the ions, and the time is converted into an exact molecular mass.
The highly abundant microbial ribosomal proteins result in a mass spectrum with a characteristic mass and intensity distribution pattern. This pattern is species-specific for many bacteria and yeasts and can be used as a 'molecular fingerprint' to identify a test organism. The spectrum of the unknown test organism, acquired through the software MBT Compass HT CA of the MBT-CA System, is electronically transformed into a peak list. Using a biostatistical algorithm, this peak list is compared to reference peak lists of organisms in the MBT-CA Reference Library and a log(score) between 0.00 and 3.00 is calculated. The higher the log(score), the higher the degree of similarity to a given organism in the MBT-CA Reference Library. The log(score) ranges reflect the probability of organism identification.
The FDA 510(k) submission document focuses on demonstrating substantial equivalence to an existing predicate device rather than presenting a traditional acceptance criteria study for a new device. Therefore, the "acceptance criteria" discussed are largely driven by proving that the new components (MBT Compass HT CA software and MBT FAST Shuttle US IVD) maintain or improve the performance and safety established by the predicate device.
Here's an analysis of the provided text to fulfill your request:
Acceptance Criteria and Reported Device Performance
The concept of "acceptance criteria" in this context isn't a single set of predefined thresholds for a novel device's performance against a clinical gold standard (e.g., sensitivity/specificity targets). Instead, it's about demonstrating that the new components do not negatively impact the established performance of the predicate device and potentially offer improvements (like accelerated drying time). The "reported device performance" is presented as evidence that these conditions are met.
Table 1: Acceptance Criteria (Implied) and Reported Device Performance
Acceptance Criteria (Implied from Study Design) | Reported Device Performance |
---|---|
MBT FAST Shuttle US IVD: | |
Safety and Compliance: Meets EMC, Electrical, Mechanical, and Thermal standards. | Complies with IEC 61326-1, IEC 61326-2-6, IEC 60601-1-2 regarding EMC. Complies with IEC 61010-1, IEC 61010-2-010, IEC 61010-2-101 and national versions (UL, CAN/CSA) for safety. |
Repeatability of Microorganism Identification: High percentage of correct identifications across different preparation methods and workflows. | MBT Workflow: Overall average 96.67% correct ID. Sepsityper Workflow: Overall average 100% correct ID. (Table 3) |
Reproducibility of Microorganism Identification: Consistent correct identification across sites, FAST Shuttle units, operators, and days. | Site-to-Site: MBT: 96.9% correct; Sepsityper: 89.1% correct. (Table 4) |
FAST Shuttle-to-FAST Shuttle: MBT: 95.6% correct; Sepsityper: 98.3% correct. (Table 5) | |
Operator-to-Operator: MBT: 98.3% correct; Sepsityper: 98.9% correct. (Table 6) | |
Day-to-Day: MBT: 98.2% correct; Sepsityper: 98.9% correct. (Table 7) | |
Equivalence of Drying Methods (FAST Shuttle vs. Air-drying): No significant difference in log(score) results. | Mean log(scores) for air-dried (2.32 ± 0.25) and MBT FAST Shuttle dried (2.34 ± 0.28) samples were very similar across all methods and study sites. (Table 8) Differences in means were minimal (e.g., -0.02). |
Accelerated Drying Time: Significantly shorter drying time with MBT FAST Shuttle. | MBT FAST Shuttle drying times (average 7.63 minutes) were significantly shorter than air drying times (average 17.59 minutes). (Table 9) |
MBT Compass HT CA Software: | |
Software Verification & Validation: Meets software standards and requirements with established traceability. | Conducted and documented in accordance with 2023 FDA guidance. Includes code review, unit level, and system level testing. |
Cybersecurity: Vulnerability and penetration testing conducted, controls implemented and verified. | Conducted and documented in accordance with 2023 FDA guidance. All appropriate controls implemented and verified. |
Analytical Performance (Low Confidence Results as Final): Low confidence results (DT/eDT) show no significant difference in species identification compared to the Ext method. | Of 1,670 yellow log(scores), 1,269 showed high-confidence species ID after Ext. Only 7 samples (0.55%) showed a different result with Ext, which were justified by polyphasic taxonomic rules or library improvement. |
IDealTune Functionality: Improves and maintains mass spectrometer performance, reducing need for manual tune-ups. | High BTS-QC passing rates (99% and 100%) observed over 14-17 months, with only 9-24 IDealTune adjustments. (Table 10) Confirmed no manual tune-ups needed for over a year with IDealTune. |
Study Details
Based on the provided text:
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Sample sizes used for the test set and the data provenance:
- MBT FAST Shuttle - Repeatability: 120 mass spectra (presumably from 12 bacterial/yeast strains * 10 repeats * 2 runs across DT, eDT, Ext, Sepsityper workflows as indicated in Table 3 headers, although the text says "each out of 2 runs" for "each workflow/method" - suggesting 10 per method/workflow per run).
- MBT FAST Shuttle - Reproducibility (Site-to-Site): 2700 samples for MBT workflow (900 samples per study site * 3 sites) and 1350 samples for Sepsityper workflow (450 samples per study site * 3 sites). The document mentions "10 microorganisms" used per study site.
- MBT FAST Shuttle - Reproducibility (Device-to-device): 1080 samples for MBT workflow (360 samples per MBT FAST Shuttle * 3 shuttles) and 540 samples for Sepsityper workflow (180 samples per MBT FAST Shuttle * 3 shuttles).
- MBT FAST Shuttle - Reproducibility (Operator-to-operator): 900 samples for MBT workflow (450 samples per operator * 2 operators) and 450 samples for Sepsityper workflow (225 samples per operator * 2 operators).
- MBT FAST Shuttle - Reproducibility (Day-to-day): 900 samples for MBT workflow (180 samples per day * 5 days) and 450 samples for Sepsityper workflow (90 samples per day * 5 days).
- MBT FAST Shuttle - Method Comparison (Drying): 279 mass spectra for air-dried and 279 mass spectra for MBT FAST Shuttle dried from three study sites (93 mass spectra per site per drying method). Ten (10) microorganisms and a blood culture, each spotted in triplicates.
- MBT Compass HT CA - Low Confidence Results: 15,270 spectra in total, with 1,670 yellow log(scores) re-analyzed.
- MBT Compass HT CA - IDealTune: Data collected from 133 BTS-QC runs at Site 1 (over 17 months) and 76 BTS-QC runs at Site 2 (over 14 months).
Data Provenance: The studies were performed at multiple sites (at least 3 for reproducibility studies), and one study explicitly mentions that microorganisms were shipped to both US study sites. This implies the data is, at least in part, prospectively collected in a multi-center setting for verification/validation. The "low confidence results" study was a retrospective non-interventional validation using data from previous clearances.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- The document does not specify the number or qualifications of experts used to establish ground truth for most of these performance studies. The studies primarily focus on performance consistency and equivalence compared to established methods using what appears to be common laboratory standards (e.g., identity confirmed organisms, BTS quality checks).
- For the "low confidence results" study, it states: "Isolates from clinical routine were used to compare the results of the MBT-CA System against a gold standard (16S sequencing)." This suggests the ground truth was established by 16S sequencing, a molecular method, rather than solely by human experts, and then potentially interpreted by experts.
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Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- No adjudication method involving multiple human readers for conflict resolution is mentioned or appears to be applicable given the nature of the device (mass spectrometry-based organism identification). The performance is assessed on the agreement with an expected identification or log(score) thresholds.
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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 or human-in-the-loop comparative effectiveness study with human readers assisting or being assisted by AI is described in this document. The device is a "clinical mass spectrometry microorganism identification and differentiation system," not an AI-assisted diagnostic imaging tool.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Yes, the performance validation studies of the MBT FAST Shuttle US IVD and MBT Compass HT CA software are essentially standalone performance evaluations of these components within the overall MALDI Biotyper CA System. The "outputs" (identification results, log(scores)) are generated by the system (including the hardware, software, and reference library) without direct human interpretation of the raw mass spectra. Human involvement is in sample preparation and operating the system, but the core identification is algorithmic.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc):
- For the analytical performance of organism identification, the ground truth appears to be based on:
- Reference strains/known microorganisms: Used in repeatability and reproducibility studies.
- 16S sequencing: Explicitly stated as the "gold standard" for comparing results in the "low confidence results" study.
- Internal quality control standards: Like the Bacterial Test Standard (BTS) for IDealTune validation.
- This is primarily laboratory-based "gold standard" ground truth (molecular methods, established reference cultures), rather than expert consensus on clinical cases.
- For the analytical performance of organism identification, the ground truth appears to be based on:
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The sample size for the training set:
- This document describes the validation of new components for an existing system. It does not provide details about the training set size for the underlying MALDI Biotyper CA System's reference library or analytical algorithms. The "reference library" (which acts as a form of "training data" for identifying unknown spectra) is mentioned as being continually updated, but its size is not specified.
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How the ground truth for the training set was established:
- Similar to the above, the document does not detail how the ground truth was established for the training data (the reference library) of the overall MALDI Biotyper CA System. However, standard practice for building such libraries involves:
- Well-characterized bacterial and yeast strains: Often from culture collections, with identity confirmed by a variety of methods including 16S rRNA gene sequencing, traditional biochemical tests, and possibly whole-genome sequencing.
- Internal validation and verification: Ensuring the spectral patterns are consistent and representative for each species.
- Similar to the above, the document does not detail how the ground truth was established for the training data (the reference library) of the overall MALDI Biotyper CA System. However, standard practice for building such libraries involves:
In summary, this 510(k) submission successfully demonstrates substantial equivalence by showing that the new components (MBT Compass HT CA software and MBT FAST Shuttle US IVD) maintain the safety and effectiveness of the predicate device, and in some cases, enhance usability (faster drying time, improved instrument maintenance) without introducing new risks or compromising diagnostic accuracy. The studies presented are analytical validations focusing on performance characteristics relevant to microorganism identification in a laboratory setting.
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(54 days)
DeepHealth, Inc.
Saige-Dx analyzes digital breast tomosynthesis (DBT) mammograms to identify the presence or absence of soft tissue lesions and calcifications that may be indicative of cancer. For a given DBT mammogram, Saige-Dx analyzes the DBT image stacks and the accompanying 2D images, including full field digital mammography and/or synthetic images. The system assigns a Suspicion Level, indicating the strength of suspicion that cancer may be present, for each detected finding and for the entire case. The outputs of Saige-Dx are intended to be used as a concurrent reading aid for interpreting physicians on screening mammograms with compatible DBT hardware.
Saige-Dx is a software device that processes screening mammograms using artificial intelligence to aid interpreting radiologists. By automatically detecting the presence or absence of soft tissue lesions and calcifications in mammography images, Saige-Dx can help improve reader performance, while also reducing reading time. The software takes as input a set of x-ray mammogram DICOM files from a single digital breast tomosynthesis (DBT) study and generates finding-level outputs for each image analyzed, as well as an aggregate case-level assessment. Saige-Dx processes both the DBT image stacks and the associated 2D images (full-field digital mammography (FFDM) and/or synthetic 2D images) in a DBT study. For each image, Saige-Dx outputs bounding boxes circumscribing any detected findings and assigns a Finding Suspicion Level to each finding, indicating the degree of suspicion that the finding is malignant. Saige-Dx uses the results of the finding-level analysis to generate a Case Suspicion Level, indicating the degree of suspicion for malignancy across the case. Saige-Dx encapsulates the finding and case-level results into a DICOM Structured Report (SR) object containing markings that can be overlaid on the original mammogram images using a viewing workstation and a DICOM Secondary Capture (SC) object containing a summary report of the Saige-Dx results.
Here's a breakdown of the acceptance criteria and the study that proves the device meets them, based on the provided FDA 510(k) clearance letter for Saige-Dx:
1. Table of Acceptance Criteria and Reported Device Performance
The provided document indicates that the primary endpoint of the standalone performance testing was to demonstrate non-inferiority of the subject device (new Saige-Dx version) to the predicate device (previous Saige-Dx version). Specific quantitative acceptance criteria (e.g., AUC, sensitivity, specificity thresholds) are not explicitly stated in the provided text. However, the document states:
"The test met the pre-specified performance criteria, and the results support the safety and effectiveness of Saige-Dx updated AI model on Hologic and GE exams."
Acceptance Criteria (Not explicitly quantified in source) | Reported Device Performance |
---|---|
Non-inferiority of subject device performance to predicate device performance. | "The test met the pre-specified performance criteria, and the results support the safety and effectiveness of Saige-Dx updated AI model on Hologic and GE exams." |
Performance across breast densities, ages, race/ethnicities, and lesion types and sizes. | Subgroup analyses "demonstrated similar standalone performance trends across breast densities, ages, race/ethnicities, and lesion types and sizes." |
Software design and implementation meeting requirements. | Verification testing including unit, integration, system, and regression testing confirmed "the software, as designed and implemented, satisfied the software requirements and has no unintentional differences from the predicate device." |
2. Sample Size for the Test Set and Data Provenance
- Sample Size for Test Set: 2,002 DBT screening mammograms from unique women.
- 259 cancer cases
- 1,743 non-cancer cases
- Data Provenance:
- Country of Origin: United States (cases collected from 12 diverse clinical sites).
- Retrospective or Prospective: Retrospective.
- Acquisition Equipment: Hologic (standard definition and high definition) and GE images.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
The document mentions: "The case collection and ground truth lesion localization processes of the newly collected cases were the same processes used for the previously collected test dataset (details provided in K220105)."
- While the specific number and qualifications of experts for the ground truth of the current test set are not explicitly detailed in this document, it refers back to K220105 for those details. It implies that a standardized process involving experts was used.
4. Adjudication Method for the Test Set
The document does not explicitly describe the adjudication method (e.g., 2+1, 3+1) used for establishing ground truth for the test set. It states: "The case collection and ground truth lesion localization processes of the newly collected cases were the same processes used for the previously collected test dataset (details provided in K220105)." This suggests a pre-defined and presumably robust method for ground truth establishment.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- Was it done? Yes.
- Effect Size: The document states: "a multi-reader multi-case (MRMC) study was previously conducted for the predicate device and remains applicable to the subject device." It does not provide details on the effect size (how much human readers improve with AI vs. without AI assistance) within this document. Readers would need to refer to the K220105 submission for that information if it was presented there.
6. Standalone (Algorithm Only) Performance Study
- Was it done? Yes.
- Description: "Validation of the software was conducted using a retrospective and blinded multicenter standalone performance testing under an IRB approved protocol..."
- Primary Endpoint: "to demonstrate that the performance of the subject device was non-inferior to the performance of the predicate device."
7. Type of Ground Truth Used
- The ground truth involved the presence or absence of cancer, with cases categorized as 259 cancer and 1,743 non-cancer. The mention of "ground truth lesion localization processes" implies a detailed assessment of findings, likely involving expert consensus and/or pathology/biopsy results to confirm malignancy. Given it's a diagnostic aid for cancer, pathology is the gold standard for confirmation.
8. Sample Size for the Training Set
- Training Dataset: 161,323 patients and 300,439 studies.
9. How the Ground Truth for the Training Set Was Established
- The document states: "The Saige-Dx algorithm was trained on a robust and diverse dataset of mammography exams acquired from multiple vendors including GE and Hologic equipment."
- While it doesn't explicitly detail the method of ground truth establishment for the training set (e.g., expert consensus, pathology reports), similar to the test set, for a cancer detection AI, it is highly probable that the ground truth for the training data was derived from rigorous clinical assessments, including follow-up, biopsy results, and/or expert interpretations, to accurately label cancer and non-cancer cases for the algorithm to learn from. The implied "robust and diverse" nature of the training data suggests a comprehensive approach to ground truth.
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(129 days)
Okapi Medical LLC dba Resivant Medical
CUTIVA™ Topical Skin Adhesive (RM1700) is intended for topical application only, to hold closed easily approximated skin edges of wounds from surgical incisions, including punctures from minimally invasive surgery, and simple, thoroughly cleansed trauma-induced lacerations. CUTIVA™ Topical Skin Adhesive (RM1700) should be used in conjunction with, but not in place of, deep dermal stitches.
The CUTIVA™ PLUS Skin Closure System (RM1739) is intended for topical application only to hold closed easily approximated skin edges of wounds from surgical incisions, including punctures from minimally invasive surgery, and simple, thoroughly cleansed, trauma-induced lacerations. CUTIVA™ PLUS Skin Closure System (RM1739) should be used in conjunction with, but not in place of, deep dermal stitches. Additionally, the adjunct wound closure device component maintains temporary skin edge alignment along the length of the wound during the application of the liquid adhesive.
CUTIVA™ Topical Skin Adhesive (RM1700) and the CUTIVA™ PLUS Skin Closure System (RM1739) are skin closure devices that are comprised of a 2-octyl cyanoacrylate liquid adhesive formulation. The liquid adhesive is supplied sterile within a single use dispensing applicator, which is used to deliver the adhesive to the skin. The CUTIVA™ PLUS Skin Closure System (RM1739) also incorporates a self-adhering mesh component that is applied to the wound prior to the application of the liquid adhesive to align the skin edges. The liquid adhesive is then applied to the mesh with the adhesive applicator to complete the device application.
Once applied, the liquid adhesive polymerizes to form a thin film with strong bonding and tensile properties. CUTIVA™ Topical Skin Adhesive (RM1700) and the CUTIVA™ PLUS Skin Closure System (RM1739) provide a physical barrier to microbial penetration as long as the adhesive film remains intact. In vitro studies have been performed to demonstrate the microbial barrier properties of CUTIVA™ Topical Skin Adhesive (RM1700) and the CUTIVA™ PLUS Skin Closure System (RM1739) for 72 hours after device application. No clinical studies have been performed and no clinical benefit associated with the in vitro microbial barrier performance of the device has been demonstrated.
This FDA 510(k) clearance letter pertains to a topical skin adhesive, not an AI/ML medical device. Therefore, much of the requested information (e.g., sample size for test set, number of experts, adjudication method, MRMC study, standalone performance, training set size, ground truth for training set) is not applicable or cannot be extracted from this document, as these concepts are specific to the validation of AI/ML algorithms, not traditional medical devices like skin adhesives.
However, I can provide the available information regarding acceptance criteria and the study that supports the device, focusing on what is relevant for a non-AI/ML medical device.
Device Name: CUTIVA™ Topical Skin Adhesive (RM1700); CUTIVA™ PLUS Skin Closure System (RM1739)
1. Table of Acceptance Criteria and Reported Device Performance
Given this is a 510(k) for a traditional medical device (topical skin adhesive) and not an AI/ML algorithm, the "acceptance criteria" discussed are typically related to biocompatibility, physical properties, and safety, assessed against recognized standards. The document primarily focuses on biocompatibility testing as a "performance data" highlight for the labeling change.
Acceptance Criteria Category | Specific Criteria (Implied/Directly Stated) | Reported Device Performance |
---|---|---|
Microbial Barrier Properties | In vitro demonstration of microbial barrier properties for 72 hours. | In vitro studies demonstrated microbial barrier properties for 72 hours after device application. (Note: No clinical benefit associated with this in vitro performance has been demonstrated.) |
Biocompatibility (Systemic Toxicity) | No evidence of systemic toxicity from the test article following subcutaneous implantation in rats (per ISO 10993-11:2017). | The "Subacute Systemic Toxicity (Implant Method) in Rats (ISO 10993-11:2017)" study demonstrated: |
- No evidence of systemic toxicity.
- Microscopically, the test article caused a minimal or no reaction.
- Worst-case exposure conditions were created by implanting the maximum dose. |
| Biocompatibility (Reaction) | Minimal or no local reaction at the implantation site. | Microscopically, the test article was classified as causing a minimal or no reaction. |
| Substantial Equivalence | The device is substantially equivalent to a legally marketed predicate device. | Both CUTIVA™ Topical Skin Adhesive (RM1700) and CUTIVA™ PLUS Skin Closure System (RM1739) were found substantially equivalent to their respective predicate devices (K234114) since they are the same devices with only packaging insert modifications. |
2. Sample Size for the Test Set and Data Provenance
- Sample Size for Test Set: Not explicitly stated in terms of human subjects or a "test set" for performance evaluation in the context of an AI/ML algorithm. For the biocompatibility study, it involved "test animals" (rats), but the exact number is not provided.
- Data Provenance: The biocompatibility study was performed in accordance with ISO 10993-11:2017 standards, implying a controlled laboratory study. The country of origin is not specified, but the study method adheres to international standards. It is a prospective animal study for biocompatibility.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
- Not applicable in the context of this device. The ground truth for biocompatibility studies is typically derived from established biological assays and pathological analysis by trained professionals (e.g., toxicologists, histopathologists), not from "experts" establishing ground truth in an image-reading or diagnostic context.
4. Adjudication Method for the Test Set
- Not applicable for this type of device and study. Adjudication methods like 2+1 or 3+1 are used for human reader consensus in diagnostic studies, which is not relevant here.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- Not applicable. This is a traditional medical device (skin adhesive), not an AI/ML algorithm requiring an MRMC study to assess human reader improvement.
6. Standalone Performance Study (Algorithm Only)
- Not applicable. This is a traditional medical device, not an algorithm.
7. Type of Ground Truth Used
- For Microbial Barrier Properties: In vitro laboratory testing results, comparing microbial penetration with and without the adhesive.
- For Biocompatibility: Histological examination and physiological observations on test animals (rats) to determine systemic toxicity and local tissue reaction, based on the criteria of ISO 10993-11:2017.
8. Sample Size for the Training Set
- Not applicable. This is a physical device, not an AI/ML algorithm that requires a training set.
9. How the Ground Truth for the Training Set Was Established
- Not applicable. As there is no AI/ML algorithm, there is no training set and thus no ground truth to establish for it.
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(117 days)
Daxor Corporation
The Daxor BVA-200 is an automated system that is used to measure/calculate the red cell mass (mL), plasma volume (mL) and total blood volume (mL), along with the related deviations from ideal values by amount (mL) and percentage (%) in adults. In addition, the Normalized Hematocrit (%) and Albumin Transudation Rate (%/min) are calculated. It is an in vitro medical device composed of a microprocessor, software, touchscreen, and gamma counter and accessory convenience kit.
The Daxor BVA-200 is intended to calculate human blood volumes by the method of tracer diffusion (Indicator dilution technique) with I-131 as the tracer after injection of I-131 Human Serum Albumin. The Daxor BVA-200 provides a Quantitative Assessment of total blood and plasma volumes using an automated system.
Data inputs to the software come from the measured characteristics of patient venous whole blood samples collected in K3EDTA vacutainer tubes (hematocrit and tracer concentration) and tracer calibration standards. The patient blood samples and the calibration standards are measured in a gamma counter, whose output is automatically input to this calculation program. The package also calculates the patient expected (or ideal) blood volume from physical parameters. Hyper- or hypovolemia, and associated red cell volumes are reported, with statistics showing the quality of the results.
For in vitro diagnostic use in a Clinical Laboratory setting and operated by laboratory technicians.
Rx use only.
The Daxor BVA-200 is an automated system that is used to calculate the red cell mass, plasma volume and total blood volume. It is an in vitro medical device composed of a microprocessor, software, touchscreen, and gamma counter. The accessory convenience kit includes single-use whole blood cartridges and protective sleeves.
The Daxor BVA-200 is designed to calculate human blood volume, using the method of tracer dilution, utilizing tagged serum albumin (I-131, resulting in "I-HSA"). Data inputs to the software come from the measured characteristics of patient blood samples (hematocrit and tracer concentration) and tracer calibration standards. The package also calculates the patient expected (or ideal) blood volume from physical parameters. Hyper- or hypovolemia, and associated red cell volumes, are reported, with statistics showing the quality of the results.
The patient blood samples and the calibration standards are measured in a gamma counter, whose output is automatically input to this calculation program.
The BVA-200 has a touchscreen for operator interaction, and provides clear instructions and prompts for the steps necessary for performing the test.
Here's a breakdown of the acceptance criteria and study information for the Daxor Blood Volume Analyzer (200), based on the provided FDA 510(k) clearance letter.
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly state "acceptance criteria" in a tabulated format. However, it provides performance metrics from a clinical comparison study and precision, linearity, carryover, and stability studies. The implicit acceptance criteria are that the device performance should be substantially equivalent to the predicate device and demonstrate acceptable precision and linearity.
Implicit Acceptance Criteria and Reported Device Performance for BVA-200 (vs. BVA-100)
Measure | Acceptance Criteria (Implicit, based on substantial equivalence) | Reported Device Performance (vs. Predicate BVA-100) |
---|---|---|
Clinical Comparison (Regression Analysis) | Strong correlation, slope near 1, intercept near 0, narrow 95% CI covering 1 for slope and 0 for intercept. | |
TBV (Total Blood Volume) | - | Passing-Bablok Slope: 1.031 (95% CI: 1.014 to 1.049), Intercept: -138 (-235 to -59), Pearson r: 0.99 |
Deming Slope: 1.033 (95% CI: 1.017 to 1.050), Intercept: -153 (-241 to -69), Pearson r: 0.99 | ||
RCV (Red Cell Volume) | - | Passing-Bablok Slope: 1.016 (95% CI: 1.002 to 1.030), Intercept: -25 (-50 to 2), Pearson r: 0.99 |
Deming Slope: 1.024 (95% CI: 1.008 to 1.040), Intercept: -37 (-68 to -10), Pearson r: 0.99 | ||
PV (Plasma Volume) | - | Passing-Bablok Slope: 1.033 (95% CI: 1.016 to 1.051), Intercept: -99 (-155 to -46), Pearson r: 0.99 |
Deming Slope: 1.029 (95% CI: 1.014 to 1.046), Intercept: -83 (-138 to -32), Pearson r: 0.99 | ||
nHct (Normalized Hematocrit) | - | Passing-Bablok Slope: 1.007 (95% CI: 0.982 to 1.032), Intercept: -0.19 (-1.18 to 0.77), Pearson r: 0.98 |
Deming Slope: 1.022 (95% CI: 0.999 to 1.047), Intercept: -0.76 (-1.71 to 0.21), Pearson r: 0.98 | ||
Precision (Total Precision %CV) | (Implicitly) Low %CV, indicating high precision. | All total precision %CV results were below 3.6%. |
Linearity | (Implicitly) Strong correlation with expected values, low bias, and CV for repeatability ≤5%, max deviation from linearity ≤8%. | Global Slope near 1 (range 1.00-1.02), Mean Bias Percent low (range 0.37-0.41). |
For contrived samples (2000-18000 ml): CV for repeatability ≤5%, Max deviation from linearity ≤8%. | ||
Carryover | No carryover observed. | No carryover observed. |
Sample Stability | Impervious to temperature/humidity, decay matches I-131, withstands shipping, non-level operation up to 15 degrees, settling does not affect readings, stability for 4 days (refrigerated/room temp). | All stated conditions were met. "No significant differences were observed, nor was there any significant drift of measurements observed." |
Handling (Cartridge drop test) | Performance criteria still met after drop. | None of the average measured parameters differed from pre-drop by more than 2.7%. |
Handling (Shipping & Handling) | Resistance to breakage and radio-emission stability. Sample and device integrity maintained. | None of the average measured parameters differed from pre-ship by more than 3.1%. |
Handling (Tilt position) | Stable measurement at non-level positioning up to 15 degrees. | None of the average measured parameters differed from pre-ship by more than 3.1%. |
Interference (Hemolysis) | Results not affected by hemolysis. | Partial hemolysis: -0.72% ± 0.77% difference from baseline. Gross hemolysis: -0.14% ± 2.16% difference from baseline. |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size for Test Set: 319 unique, independent, comparable measurements.
- Data Provenance:
- Blood derived from patients undergoing blood volume measurement with the BVA-100 (predicate device) as part of their clinical treatment or as part of a research study.
- The document implies the data is retrospective for the clinical comparison, as it used blood derived from patients undergoing measurement with the predicate device.
- For precision, linearity, sample stability, handling, and interference studies, contrived samples and venous whole blood samples from male and female volunteers were used. No specific country of origin is mentioned.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
The document does not mention the use of experts to establish ground truth for the test set in the context of a reader study or image interpretation. The ground truth for the clinical comparison study was established by the predicate device (Daxor BVA-100) measurements.
4. Adjudication Method for the Test Set
Not applicable. The ground truth for the clinical comparison was based on measurements from the predicate device, not expert adjudication of subjective assessments.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No, an MRMC comparative effectiveness study was not done. This device is a quantitative measurement system, not an AI software intended for interpretation by human readers. The clinical study focused on comparing the performance of the new device (BVA-200) to its predicate (BVA-100) on quantitative measurements.
6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done
Yes, the studies performed focused on the standalone performance of the BVA-200. The device is an automated system that measures and calculates blood volumes. The performance data presented (clinical comparison, precision, linearity, stability, etc.) represents the device's output independently, without human interpretation as part of a "human-in-the-loop" workflow being evaluated.
7. The Type of Ground Truth Used
The ground truth for the primary clinical comparison study was the measurements obtained from the predicate device, the Daxor BVA-100. For other studies (precision, linearity, stability, etc.), the ground truth was based on known properties of contrived samples or established physical/biological principles (e.g., known decay rate of I-131).
8. The Sample Size for the Training Set
The document does not provide information on a training set sample size. This suggests that the BVA-200, similar to its predicate BVA-100, is likely based on established physiological and radiological principles (indicator dilution technique, I-131 decay) rather than a machine learning model that requires a distinct "training set." The software performs calculations based on these principles and measured inputs, not through a learned model from a training set.
9. How the Ground Truth for the Training Set Was Established
Not applicable, as a "training set" in the context of machine learning is not implied or described in the document for this device.
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