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510(k) Data Aggregation
(75 days)
MEDI-TECH INTL. CORP.
Medi-Tech International Corporations Easy-View Mitts are intended to be utilized as a patient safety device when patients are assessed at risk of disrupting life-saving treatments or could cause self-injury.
The Medi-Tech International Corp. Protective Restraint is a protective restraint device which is intended for medical purposes to control the movement of a patient's hand or finger movements thereby enabling examination or protection of the patient or others. Device Design Materials Used/Physical Properties: The Medi-Tech Protective Restraint is designed similar to those marketed by other manufacturers. Primarily comprised of cotton and polyester material and polyester fiber filling.
The Medi-Tech International Corp. Protective Restraint (Easy-View Mitts, Model #MTRM281) is a protective restraint device intended to control the movement of a patient's hand or finger movements to enable examination or protection of the patient or others, particularly when patients are at risk of disrupting life-saving treatments or causing self-injury.
Here's an analysis of the acceptance criteria and study:
1. Table of Acceptance Criteria and Reported Device Performance
Test Category | Acceptance Criteria | Reported Device Performance |
---|---|---|
Safety | The flap opens easily to view the back of the hand; the wrist strap does not compromise circulation. | Result: The flap opens easily to view the back of the hand. The wrist strap, when secured properly, did not compromise circulation. |
Effectiveness | The inspection flap performs as intended to allow visualization of the hand when closed. | Result: The inspection flap performs as intended to allow the visualization of the hand. |
Function | The strength of the strap limits movement to the extent necessary for treatment, examination, and to prevent self-injury or injury to others, equivalent to the predicate device. | Result: The strength of the strap of the MTRM281 mitt was compared to the predicate device strap and provided similar results, indicating it limits movement as intended. |
Physical Integrity & Performance (Bench Testing) | Satisfy functional requirements equivalent to the predicate device for: Fiber Content, Tearing Resistance, Shear Strength, Peel Strength, Breaking Strength, Failure in Sewn Seams, Pilling Resistance, Dimensional Stability, Appearance, Labeling Compliance, Defects, Workmanship, Sharp Edges/Points, Functionality, Colorfastness (Accelerated Laundering, Chlorine Bleach, Non-Chlorine Bleach, Perspiration, Burnt Gas Fumes). | Result: All listed bench tests (FIBER CONTENT (ATTCC 20A), TEARING RESISTANCE OF FABRICS (ELMENDORF) (ASTM D 1424), SHEAR STRENGTH OF HOOK & LOOP TOUCH FASTENERS (ASTM D 5169), PEEL STRENGTH OF HOOK & LOOP TOUCH FASTENERS (ASTM D 5170), BREAKING STRENGTH (ASTM D 5034), FAILURE IN SEWN SEAMS OF WOVEN APPAREL FABRICS (ASTM D 1683), PILLING RESISTANCE: RANDOM TUMBLE (ASTM D 3512), DIMENSIONAL STABILITY TO WASHING (AATCC 150), APPEARANCE AFTER WASHING (VISUAL), F.P. & L. ACT (16 CFR500 OR NIST UNIFORM LAWS & REGULATIONS HANDBOOK 130), COUNTRY OF ORIGIN MARKING (19 CFR 134.11), USE LABELING (VISUAL), CARE INSTRUCTIONS (16 CFR 423), DEFECTS (VISUAL CHECK), WORKMANSHIP (VISUAL CHECK), SHARP EDGES/SHARP POINTS (16 CFR 1500.48 SHARP POINT, 16 CFR 1500.49 SHARP EDGES), FUNCTIONALITY (ITS-M0061), COLORFASTNESS TO ACCELERATED LAUNDERING (AATCC 61), COLORFASTNESS TO CHLORINE BLEACH (AATCC/ASTM TS-001), COLORFASTNESS TO NON-CHLORINE BLEACH (AATCC/ASTM TS-001), COLORFASTNESS TO PERSPIRATION (AATCC 15), COLORFASTNESS TO BURNT GAS FUMES (AATCC 23)) were performed. The bench test results demonstrated that the device satisfies all functional requirements and is as safe, as effective, and performs as well as the predicate device. |
2. Sample size used for the test set and the data provenance
- Sample Size:
- Non-Clinical Data: One individual, Marilyn Geiger, Medi-Tech International Corporation's Product Manager, was used for the "Non-Clinical Data" tests (Safety, Effectiveness, Function).
- Bench Testing: The document does not specify the number of units or samples tested for each of the bench tests (e.g., how many fabric swatches for tearing resistance, how many mitts for seam failure). The tests were performed by Intertek testing facility.
- Data Provenance: Retrospective, as these tests were conducted to demonstrate substantial equivalence to an already marketed device (J.T. Posey Company Protective Restraint K963413). The document doesn't specify country of origin for the data beyond the testing facility (Intertek) being utilized.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Non-Clinical Data: One "expert" (Marilyn Geiger, Product Manager) conducted the tests and reported the results. Her specific qualifications beyond being the company's Product Manager are not detailed in the provided text. No independent expert consensus was explicitly stated.
- Bench Testing: The testing was performed by Intertek, a third-party testing facility. While not explicitly stated as "experts," Intertek is a recognized testing institution, implying their personnel are qualified to conduct the specified ASTM and AATCC tests. No ground truth was established by human consensus for these physical tests; they are objective measurements against established standards.
4. Adjudication method for the test set
- Non-Clinical Data: No explicit adjudication method (like 2+1 or 3+1) is mentioned. The testing appears to have been observed and reported by a single individual (Marilyn Geiger).
- Bench Testing: The concept of "adjudication" as typically applied to clinical or image-based studies doesn't apply directly here. The bench tests involve objective measurements and visual inspections against defined criteria and standards. The results would be objectively determined by the testing equipment and qualified technicians at Intertek.
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
- No MRMC comparative effectiveness study was done. This device is a physical protective restraint and not an AI-assisted diagnostic or therapeutic tool. Therefore, the concept of human readers improving with or without AI assistance is not applicable.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
- No standalone algorithm performance study was done, as this is a physical medical device, not a software algorithm or AI.
7. The type of ground truth used
- Non-Clinical Data (Safety, Effectiveness, Function): The ground truth was based on observational assessment and comparison to the predicate device by the Product Manager. The "ground truth" was essentially the subjective judgment that the device performed "as intended" and "similar" to the predicate.
- Bench Testing: The ground truth was based on objective physical measurements against established industry standards (e.g., ASTM, AATCC) and visual inspections for compliance with design specifications (e.g., labeling, workmanship, sharp edges). The predicate device served as a comparative benchmark for several functional and material properties (e.g., strap strength, material composition).
8. The sample size for the training set
- No specific training set in the context of machine learning or AI is mentioned, as this is a physical medical device. The "training" for such a device would typically involve design, engineering, and manufacturing processes, not data-driven algorithm training.
9. How the ground truth for the training set was established
- Not applicable, as there is no training set in the context of AI/ML for this device. The design and development of the device would have been guided by engineering principles, material science, and regulatory requirements, and benchmarked against existing devices.
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(186 days)
MEDI-TECH INTL. CORP.
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