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510(k) Data Aggregation

    K Number
    K172689
    Date Cleared
    2017-11-29

    (84 days)

    Product Code
    Regulation Number
    878.4810
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Merz North America, Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The DESCRIBE PFD Patch is indicated for use as an accessory to laser tattoo removal procedures using 532, 694, 755, and 1064 nm standard Q-Switched (QS) lasers and 532, 755, 785, and 1064 nm standard picosecond lasers in Fitzpatrick Skin Type I-III patients.

    Device Description

    The DESCRIBE® PFD Patch consists of two components: a dual-layer medicalgrade silicone transparent film, and an optical clearing agent (OCA). The dual-layer silicone film is composed of a thin low-friction silicone membrane and a tacky silicone polymer layer. The low-friction silicone membrane forms the upper layer of the film. The tacky silicone polymer layer (i.e., the lower layer) contacts the patient's skin during the device's use. The OCA in the Device is sterile, high-purity perfluorodecalin (PFD), an inert, non-toxic liquid (FluoroMed, LLC).

    AI/ML Overview

    Here's an analysis of the provided text regarding the DESCRIBE PFD Patch, focusing on the acceptance criteria and supporting studies.

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria provided primarily relate to the optical stability and chemical integrity of the patch and its optical clearing agent (PFD) under laser exposure, as well as the stability of the packaging over time. No numerical performance metrics (e.g., accuracy, sensitivity, specificity) were provided for the device's function in aiding tattoo removal, as it is an accessory and not an independently evaluable diagnostic or therapeutic device in that regard.

    Acceptance CriteriaReported Device Performance
    Optical Stability (Patch & PFD) after laser exposure (wavelengths: Q-switched 532, 694, 755, 1064 nm; picosecond 532, 755, 785, 1064 nm)No optical changes observed within the precision of the instrument (UV/VIS/NIR spectroscopy). The patch remained optically transparent at all wavelengths tested.
    Chemical Stability (PFD) after laser exposure (wavelengths: Q-switched 532, 694, 755, 1064 nm; picosecond 532, 755, 785, 1064 nm)No chemical changes to the PFD occurred within the precision of the instrument (Gas chromatography and mass spectrometry - GC/MS).
    Packaging Burst Testing (3-year stability)All Nonporous Packaging Validation test method acceptance criteria were met.
    Bubble Emission Leak Testing (3-year stability)All Nonporous Packaging Validation test method acceptance criteria were met.
    Visual Verification of Seal (3-year stability)Product remained properly sealed.
    Heat Seal Width (3-year stability)Width was no less than approximately 5 mm.
    PFD Volume (3-year stability)1.8 mL + 30% - 10% had remained in the pouch (verified by product weight measurement before and after evaporative removal of PFD).

    2. Sample Size Used for the Test Set and Data Provenance

    • Bench Performance Testing (Optical & Chemical Stability): The text does not explicitly state a sample size in terms of the number of patches or PFD samples tested for optical and chemical stability. It refers to "the patch and PFD" and "respective associated PFD," suggesting individual or small batches for each test condition.
    • Stability Testing:
      • Packaging: Twenty samples of the Patch from identical lots manufactured in 2014 were initially placed in storage. After 3 years, fourteen of these were tested for package burst and bubble emission leak testing.
      • Patch & PFD content: A "representative sample Patch" from the above batch was used to test visual verification, heat seal width, and PFD volume.
    • Data Provenance: All data appears to be from bench testing conducted by the manufacturer, Merz North America, Inc. The location of the test facilities is not specified, but the company is based in Raleigh, North Carolina, USA. The studies are not explicitly labeled as retrospective or prospective, but bench tests on manufactured products would generally be considered prospective in their execution.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications

    • This device is an accessory to a laser surgical instrument. The studies described are bench performance and stability tests, not clinical studies involving human patients or complex interpretations. Therefore, there is no mention of experts establishing a "ground truth" for a test set in the conventional sense of clinical or diagnostic performance. The "ground truth" for these tests is based on objective physical and chemical measurements (e.g., spectrophotometry, mass spectrometry, physical dimensions).

    4. Adjudication Method for the Test Set

    • Not applicable. As described above, these are bench tests with objective measurements, not subjective evaluations requiring adjudication.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    • No MRMC comparative effectiveness study was done. The device is a physical accessory, not an AI or imaging diagnostic tool that would typically involve human readers interpreting cases.

    6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study

    • Not applicable. The DESCRIBE PFD Patch is a physical medical device, not an algorithm or software. Its performance is evaluated through its physical and chemical properties.

    7. Type of Ground Truth Used

    • The ground truth for the bench tests was based on objective physical and chemical measurements and adherence to established reference standards for these measurements (e.g., UV/VIS/NIR spectroscopy, GC/MS, ISO 11607 for packaging).

    8. Sample Size for the Training Set

    • Not applicable. This device is not an AI/ML algorithm requiring a training set. The descriptions are of physical product performance and stability testing.

    9. How the Ground Truth for the Training Set Was Established

    • Not applicable, as there is no training set for this type of device.
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