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510(k) Data Aggregation
(90 days)
Wart Freeze (private label trade mark: Wart Freezer, Cryogenic Wart Remover) is indicated for the removal of common and plantar warts.
The product is indicated for the removal of common and plantar warts.
Wart Freeze is a private label (private label trade mark: Wart Freezer, Cryogenic Wart Remover) over the counter cryosurgery product for the treatment of common and plantar warts. The device consists of the following:
- A pressurised dispenser (canister) containing as ingredient 38ml dimethylether (DME) with a . polypropylene applicator that is permanently attached (fixed) to the dispenser. The gas does not harm the ozone layer. The applicator is used to administer the cryogen directly to the wart. The applicator is cleaned after each use.
- Disposable 70% alcohol cleansing swabs for cleaning the applicator after each use .
- Instruction for use .
The Wart Freeze (private label trade mark: Wart Freezer, Cryogenic Wart Remover) is a 21. cryosurgical system comprised of a dispenser containing as ingredient, dimethylether (DME), and a permanently attached (fixed) applicator to apply the cryogen directly to the wart.
The provided document is a 510(k) summary for a medical device called "Wart Freeze," which is an over-the-counter cryosurgery product for wart removal. The document focuses on establishing substantial equivalence to a predicate device (K101049) and demonstrating the safety and effectiveness of the modified device.
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly present a table of "acceptance criteria" in the typical sense of numerical thresholds for clinical performance. Instead, it demonstrates performance through comparative laboratory testing and characterization against a predicate device and established safety standards. The primary acceptance criterion here is substantial equivalence to the predicate device, especially in terms of functionality, safety, and indications for use.
| Acceptance Criterion (Implicit) | Reported Device Performance |
|---|---|
| Cryogen Delivery & Application Effectiveness | |
| - Ability to deliver cryogen to wart | - Device applies cryogen directly to the wart via a permanently attached applicator. |
| - Comparable effectiveness to predicate devices | - Comparative laboratory testing using a phantom skin model indicated that the various competitor products (including the predicate) are similar in effectiveness. |
| - Consistent cold generation | - Applicator surface at the tip reaches -50 °C. The effectiveness of predicates is stated to be identical. |
| - Appropriate freeze time (dose-technique related) | - 3-short presses resulted in a freeze time of 1.31 seconds. - 3-long presses resulted in a freeze time of 1.99 seconds. |
| - Maximum acceptable concentration of DME administered | - Maximum acceptable concentration of DME administered was 0.37 mg/ml during both dose techniques, ensured by a safety (dose) valve. |
| Biocompatibility | |
| - Applicator material safety | - Biocompatibility testing (ISO 10993:5 Tests for in vitro cytotoxicity) performed on the polypropylene applicator in contact with cryogen. - The applicator material was found to be non-lysic. |
| Chemical Residuals/Leachables | |
| - Absence of harmful chemical residuals/leachables | - Laboratory testing concluded no chemical residuals in dimethylether/polypropylene extracts, indicating no leachable components between the applicator and cryogen. |
| Cryogen Safety (Dimethylether - DME) | |
| - Non-toxic by inhalation | - DME inhalation studies (by suppliers), including US National Toxicological Programme (NTP) acute toxicity studies (LC50) on mouse and rabbit. - Concluded DME did not produce acute toxicity in animal models or bacteria (Ames Salmonella Typhimiurium). - Developmental toxicity studies in animal models showed no significant toxic effect on mice or rabbit pups. - DME received a ranking of "not acutely toxic" by the NTT. - Current exposure limits (1000 ppm or 0.1% DME for 8-hour daily life-time exposures) are significantly higher than typical consumer product exposures (~100 ppm for short periods <15 min/day), which are far below levels to induce CNS effects. |
| Ease of Use/Safety Features | |
| - Incorporates safety mechanisms | - Design incorporates a safety valve. - Dispenser requires being held upside down and actuated 3 times before cryogen is administered. - Predicate device has identical safety valve mechanism. |
| Intended Use | |
| - Indicated for common and plantar warts (OTC for adults and children 4+) | - Device is indicated for the removal of common and plantar warts, OTC, for adults and children 4 years of age and older. - Predicate device has identical intended use. |
2. Sample Size Used for the Test Set and Data Provenance
The testing conducted for this device appears to be all laboratory-based or pre-clinical studies, not a human clinical trial test set in the traditional sense.
- Comparative laboratory testing: Involved "predicate devices using a phantom skin model." The sample size (number of phantom skin models or tests) is not specified.
- Applicator temperature laboratory test: Used "infrared camera technology." Sample size (number of tests/measurements) is not specified.
- Dose technique testing: Used "infrared (IR) camera technology." Sample size (number of tests/measurements for each dose technique) is not specified.
- Biocompatibility testing: Performed "in line with ISO 10993:5 Tests for in vitro cytotoxicity." While "testing was performed," the specific sample size (e.g., number of cell cultures, replicates) is not detailed.
- Chemical residual testing: "Laboratory testing was conducted." Sample size (number of extractions, analyses) is not specified.
- Inhalation studies on dimethylether: "Conducted by the suppliers." The US National Toxicological Programme (NTP) conducted "acute toxicity studies (LC50)" and "developmental toxicity studies" on mouse and rabbit models. The exact number of animals is not specified in this summary.
Data Provenance: All data appears to be from laboratory studies and existing toxicological literature/supplier data, not human patient data. There is no mention of country of origin for the studies, but the NTP study suggests US involvement for those specific studies.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
Since this is not a human clinical study with a "test set" of patient cases requiring expert interpretation for ground truth, this information is not applicable. The "ground truth" for the laboratory tests was derived from physical measurements (temperature, concentration, freeze time) or established scientific methods (cytotoxicity assays, toxicology studies).
4. Adjudication Method for the Test Set
As there is no human-interpreted test set for this device, an adjudication method is not applicable.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, What was the Effect Size of How Much Human Readers Improve with AI vs. Without AI Assistance?
This is not an AI/CAD device. No MRMC study was performed, and this question is not applicable.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
This is not an algorithm-based device. No standalone performance study of an algorithm was done, and this question is not applicable.
7. The Type of Ground Truth Used
The "ground truth" in this context refers to the verifiable outcomes or measurements from the laboratory and pre-clinical studies:
- Quantitative Measurements: Applicator temperature (-50 °C), freeze times (1.31s, 1.99s), DME concentration (0.37 mg/ml), stated exposure limits (1000 ppm).
- Standardized Assay Results: Biocompatibility (non-lysic via ISO 10993:5), chemical residuals (none detected).
- Toxicological Study Endpoints: Acute toxicity (no acute toxicity in animal models/bacteria, "not acutely toxic" ranking), developmental toxicity (no significant toxic effect in animal models).
- Comparative Assessment: Functional similarity to predicate devices based on phantom skin model behavior.
8. The Sample Size for the Training Set
This device did not involve machine learning or AI; therefore, there is no "training set." All reported studies are for performance evaluation or characterization.
9. How the Ground Truth for the Training Set Was Established
As there is no training set, this question is not applicable.
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(435 days)
Wart Freeze is indicated for the removal of common and plantar. The wart remover product is intended to be used in adults and children 4 years of age and over.
Wart Freeze is an over the counter cryosurgical product to remove common and plantar warts. The device consists of the following: Pressurized canister with the cryogen liquid dimethyl ether (DME), a dose valve which expels a specific quantity of the cryogen onto the wart, a polypropylene reusable applicator, 70% alcohol disposable cleansing swabs, Protective plasters (bandages).
The provided text describes a 510(k) Pre-market Notification for the "Wart Freeze" device. This is a submission to demonstrate substantial equivalence to previously cleared devices, not typically a full clinical study with acceptance criteria and performance metrics in the way a novel AI/software medical device would be.
Therefore, many of the requested elements for a detailed AI/software device study (such as MRMC studies, sample sizes for training/test sets, expert qualifications for ground truth establishment, etc.) are not applicable or not provided in this type of regulatory document.
However, I can extract information related to the device's pre-clinical testing, which serves as a form of "acceptance criteria" and "study" for this specific type of device.
Here's the breakdown based on the provided text:
1. A table of acceptance criteria and the reported device performance
Since this is a traditional 510(k) for a cryosurgical device, the "acceptance criteria" are not reported as specific numerical performance metrics (like sensitivity, specificity) but rather as successful completion of various functionality and safety tests demonstrating equivalence to predicate devices. The performance is "reported" as supporting the safety and effectiveness.
| Acceptance Criteria (What was tested) | Reported Device Performance (Outcome) |
|---|---|
| Comparative testing with predicate devices using a phantom skin model | Supports safety and effectiveness; suggests similar performance to predicates. |
| Applicator temperature test | Successfully determined the degree of cold generated by the cryogen on the applicator. |
| Dose technique test (dispensing freeze time) | Determined dispensing freeze time for two potential techniques; subsequent testing showed no difference in effectiveness between techniques. |
| Maximum allowable concentration of DME | Successfully determined. |
| Biocompatibility testing (cryogen & applicator material) | Determined safety of cryogen and applicator material. |
| Safety test (chemical residuals, leachable/degradable components) | Successfully identified any potential chemical residuals. |
| Label comprehension study | Ensured instructions for use and package label were clear and understandable for safe and effective use. |
2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Sample Size for Test Set: Not explicitly stated for each test. For the "phantom skin test model," no sample size (number of tests or phantoms) is provided. No human subjects test set is mentioned.
- Data Provenance: Not explicitly stated. The manufacturer is Koninklijke Utermöhlen NV, located in the Netherlands. The 510(k) submission was made to the FDA in the USA. Given the nature of pre-clinical bench testing, the data would likely originate from laboratory settings where the tests were performed.
- Retrospective/Prospective: These pre-clinical tests are prospective in nature, as they are specifically conducted to evaluate the device.
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)
- Not applicable. This is a physical device undergoing pre-clinical bench and lab tests. There is no mention of human experts establishing "ground truth" for a test set in the context of diagnostic accuracy, image interpretation, or clinical outcomes. The "ground truth" for these tests would be objective measurements (e.g., temperature readings, concentrations, visual inspection for clarity of labels).
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable. Adjudication methods like 2+1 or 3+1 typically apply to clinical studies where multiple experts evaluate ambiguous cases or determine ground truth in a consensus-driven manner for diagnostic accuracy studies. This document describes bench and lab testing of a physical 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 is a cryosurgical device for wart removal, not an AI/software device. No MRMC study or AI assistance is mentioned.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not applicable. This is a physical cryosurgical device, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- The "ground truth" for the pre-clinical tests varied by test type:
- Comparative testing: Performance against predicate devices on a phantom skin model.
- Temperature test: Direct measurement of temperature.
- Dose technique test: Measurement of freeze time and assessment of "effectiveness" (likely through simulated application or efficacy on phantom models).
- DME concentration: Chemical analysis.
- Biocompatibility/Safety: Standardized ISO or similar biocompatibility tests for materials and chemical component analysis for safety.
- Label comprehension: Survey results on public understanding of the instructions.
8. The sample size for the training set
- Not applicable. This is not an AI/machine learning device that requires a training set.
9. How the ground truth for the training set was established
- Not applicable. This is not an AI/machine learning device.
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