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510(k) Data Aggregation
(155 days)
Atteris Antimicrobial Barrier Film Dressing is intended for application to minor wounds and damaged skin as a liquid, film forming barrier, which creates a waterproof, film dressing, protecting the wound or damaged skin.
Atteris™ Antimicrobial Barrier Film Dressing is a polymeric solution which forms a uniform film when applied to minor wounds and damaged skin. The product is dispersed in a unique non-cytotoxic, non-stinging solution via a standard 28 mL pump spray bottle. The product is biocompatible, non-stinging, fast drying, and has low friction. Antimicrobial Barrier Film Dressing protects minor wounds and damaged skin by providing a secure, breathable, waterproof barrier to external contaminates. The film dressing is colorless, transparent, and possesses good oxygen and moisture vapor permeability. The antimicrobial PHMB at a concentration of 0.001% w/w is added to the product as a preservative to inhibit the growth of microorganisms within the product.
The provided document is a 510(k) premarket notification for the "Atteris Antimicrobial Barrier Film Dressing" and focuses on demonstrating substantial equivalence to a predicate device, rather than presenting a study to prove a device meets specific acceptance criteria in the context of AI/machine learning performance.
Therefore, most of the requested information regarding AI/ML study design (sample size for test/training sets, data provenance, expert ground truth, adjudication methods, MRMC studies, standalone performance) is not applicable to this document.
However, I can extract the acceptance criteria and reported device performance from the provided "Performance Testing" section.
Acceptance Criteria and Reported Device Performance
| Acceptance Criteria | Reported Device Performance |
|---|---|
| Preservative Effectiveness (USP 51) | Broad spectrum activity demonstrated against 5 organisms (Gram positive, Gram negative, and fungal types). Total kill was achieved for 24 hours at >6 log of each organism: P. aeruginosa, E. coli, C. albicans, S. aureus, A. brasiliensis. Performance was sustained initially and at several points during aging. This indicates the product is preserved using PHMB. |
| Biocompatibility (ISO 10993 parts 1, 5, 10) | The device is non-cytotoxic, non-sensitizing, and non-irritating. This was demonstrated through cytotoxicity, sensitization, and irritation studies. |
| Shelf Life Stability | Real-time aging studies indicate the product is expected to be stable and effective for a shelf life of 6 months. |
Answers to other questions based on the provided document:
- Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective): Not applicable. The document describes in-vitro lab testing, not a clinical study with a "test set" of patients/data.
- Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable.
- Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable.
- 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 not an AI/ML device.
- If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable. This is not an AI/ML device.
- The type of ground truth used (expert consensus, pathology, outcomes data, etc): The "ground truth" or reference standards for the performance tests were established using recognized international standards and methods, specifically:
- USP 51 for antimicrobial effectiveness.
- ISO 10993 parts 1, 5, and 10 for biocompatibility.
- The sample size for the training set: Not applicable. This is not an AI/ML device.
- How the ground truth for the training set was established: Not applicable.
In summary, this document is a regulatory submission for a medical device (a film dressing) and its performance is evaluated through standard laboratory and biocompatibility testing, not through AI/ML performance studies.
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(183 days)
(Rx Only) Atteris Antimicrobial Skin & Wound Cleanser is intended for mechanical cleansing and removal of debris, dirt and foreign materials, including microorganisms from wounds such as stage I-IV pressure ulcers, diabetic foot ulcers, post-surgical wounds, first and second degree burns, grafted and donor sites.
(OTC use) Atteris Antimicrobial Skin & Wound Cleanser is intended for physical cleaning and removal of dirt and debris, from skin scrapes, cuts, lacerations, minor irritations, exit sites and unbroken skin.
Atteris Antimicrobial Skin & Wound Cleanser helps in the mechanical removal of debris and foreign material from the skin, wound or application site. Atteris Antimicrobial Skin & Wound Cleanser is a pure, colorless, isotonic cleanser that is safe. The cleanser has a six month expiration due to the preservative that provides bactericidal and fungicidal properties through the action of the antimicrobial (PHMB).
A preservative, PHMB, at a concentration of 0.1% w/w is added to the product to inhibit the growth of microorganisms such as, Staphylococcus aureus, Staphylococcus epidermidis, Pseudomonas aeruginosa, Escherichia coli, antibiotic resistant Methicillin Resistant Staphylococcus aureus (MRSA), and fungus Candida albicans within the product.
The provided text describes a 510(k) premarket notification for the Atteris™ Antimicrobial Skin & Wound Cleanser. This type of submission aims to demonstrate substantial equivalence to a legally marketed predicate device, rather than proving direct clinical effectiveness against specific acceptance criteria in the same way a new drug or novel medical device might.
Therefore, the document does not contain a study that establishes clinical acceptance criteria for the device's performance in a clinical setting (e.g., wound healing rates, infection reduction rates). Instead, the studies mentioned are to demonstrate the new device is as safe and effective as the predicate based on pre-defined regulatory and biocompatibility standards.
However, I can extract information related to the performance testing that addresses aspects of safety and effectiveness as required for substantial equivalence.
Here's an attempt to organize the information based on your request, focusing on what is available in the document:
1. Table of Acceptance Criteria and Reported Device Performance
As this is a 510(k) submission, the "acceptance criteria" are primarily related to demonstrating equivalence in safety, performance, and specific product characteristics compared to a predicate device, rather than meeting specific clinical efficacy endpoints with numerical benchmarks.
| Criterion Type | Acceptance Criteria (Implied by 510(k) & Standards) | Reported Device Performance |
|---|---|---|
| Biocompatibility | Adherence to ISO 10993 standards for cytotoxicity, sensitization, and irritation. | Cytotoxicity: Final GLP Report - 15-03643-G1: L929 Agar Diffusion Test (Direct Contact) - ISO (Reference 4). Performance reported as non-cytotoxic. |
| Sensitization: Final GLP Report - 15-03643-G4: Direct Buehler Sensitization Test - ISO (Reference 6). Performance reported as non-sensitizing. | ||
| Irritation: Final GLP Report - 15-03643-G2: Direct Primary Skin Irritation Test - ISO (Reference 5). Performance reported as non-irritating. | ||
| Preservation | Meets USP <51> criteria for antimicrobial effectiveness, specifically inhibiting growth of target microorganisms within the product. | Preservative Effectiveness Testing (USP <51>): Results demonstrated effectiveness against Escherichia coli (ATCC No. 8739), Staphylococcus aureus (ATCC No. 6538), Pseudomonas aeruginosa (ATCC No. 27853), Staphylococcus epidermidis (ATCC No. 12228), and Candida albicans (ATCC No. 10231). |
| Shelf Life/Stability | Device expected to maintain stability and effectiveness for a defined period. | Real-time aging study: Results indicate the product is expected to be stable and effective for a shelf life of 6 months. |
| Composition/Properties | Similar physical and chemical characteristics to predicate/reference devices (e.g., aqueous, density, non-sterile, not buffered). | Composition: Aqueous, ~1.0 g/ml density, non-sterile, not buffered. (Matches predicate/reference). Contains PHMB for preservation. |
| Intended Use | Same intended use as the predicate device (mechanical cleansing and removal of debris, dirt, foreign materials, including microorganisms). | Stated Intended Use (Rx and OTC) is consistent with the predicate device for wound and skin cleansing. |
2. Sample Size Used for the Test Set and the Data Provenance
- Sample Size: The document does not specify exact sample sizes for the test sets used in the biocompatibility, preservative effectiveness, or shelf-life studies. These would typically be detailed in the full study reports referenced (e.g., Toxikon reports, USP <51> reports), but not in the 510(k) summary. For biocompatibility tests (ISO 10993), sample sizes are generally small (e.g., a few animals or cell cultures per test).
- Data Provenance: The biocompatibility studies were conducted by "Toxikon" (a contract research organization presumably based in the US or an ISO-certified lab). The USP <51> testing is a standard methodology. Real-time aging studies are conducted on the manufacturer's product. The provenance of the data is generally from laboratory testing, which is prospective in nature for these specific tests. Country of origin for data is not explicitly stated but assumed to be from a reputable testing facility.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts
This type of information (experts establishing ground truth for a test set) is not applicable to this 510(k) safety and performance testing. The "ground truth" for these tests are the established standards:
- For biocompatibility: ISO 10993 standards.
- For preservative effectiveness: USP <51> monograph.
Experts (e.g., toxicologists, microbiologists) would perform and interpret the tests according to these standards, but there isn't a "ground truth" derived from expert consensus on images or clinical outcomes in the context of this submission.
4. Adjudication Method for the Test Set
Not applicable. Adjudication methods (like 2+1 or 3+1) are typically used in clinical studies, especially those involving human interpretation of data (e.g., radiology reads, pathology diagnoses), to establish a consensus "ground truth." The tests performed here are laboratory-based and follow standardized protocols; outcomes are objective measurements or categorical determinations (e.g., cytotoxic/non-cytotoxic, effective/not effective).
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 510(k) clearance for an antimicrobial skin and wound cleanser, not an AI-powered diagnostic or assistive tool. No human readers or AI assistance are involved in the performance evaluation described.
6. If a Standalone (i.e. algorithm only without human-in-the loop performance) was done
Not applicable. This is not an algorithm or AI device.
7. The Type of Ground Truth Used
The "ground truth" for the performance claims in this submission are based on:
- Standardized Laboratory Controls: For biocompatibility, the ground truth is whether the device materials elicit a toxic, irritating, or sensitizing response when compared to controls as defined by ISO 10993.
- Pharmacopoeial Standards: For preservative effectiveness, the ground truth is the reduction in microbial count defined by the USP <51> antimicrobial effectiveness test.
- Physical/Chemical Measurements: For shelf life and other characteristics, the ground truth is the stability of physical/chemical properties over time.
8. The Sample Size for the Training Set
Not applicable. This is not an AI/ML device that requires a training set.
9. How the Ground Truth for the Training Set was Established
Not applicable. This is not an AI/ML device that requires a training set.
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(137 days)
Atteris No Sting Skin Protectant is intended for application to intact or damaged skin as a liquid, film-forming product, which creates a long-lasting waterproof barrier, protecting the skin from bodily wastes, fluids, add friction. It is intended as a primary barrier against irritation from body fluids.
Atteris No Sting Skin Protectant is a polymeric solution which forms a uniform film when applied to the skin. The product is biocompatible, non-stinging, and fast drying. Atteris No Sting Skin Protectant shields intact or damaged skin from irritation caused by bodily fluids, wound drainage, adhesives, and friction. The film is colorless, transparent, and possesses good oxygen and moisture vapor permeability. Atteris No Sting Skin Protectant will be supplied in a High Density Polyethylene (HDPE) bottle with pump spray cap.
The provided document describes the Atteris No Sting Skin Protectant and its performance characteristics, primarily to demonstrate substantial equivalence to a predicate device. It does not contain information about a study proving the device meets acceptance criteria in the context of typical AI/software device evaluation (e.g., diagnostic accuracy on a test set). Instead, it details performance testing to substantiate specific product claims related to its physical and biological properties.
Therefore, many of the requested sections related to AI device evaluation (such as sample size for test set, data provenance, expert ground truth, MRMC study, standalone performance, training set details) are not applicable to the information contained in this document.
However, I can extract the acceptance criteria (claims) and the reported device performance from the provided text for the aspects that were evaluated.
1. Table of Acceptance Criteria and Reported Device Performance
| Performance Characteristic (Claim) | Acceptance Criteria (Implied) | Reported Device Performance |
|---|---|---|
| No Sting | Non-stinging | "NSP is non-stinging." |
| Barrier Film | Functions as a barrier film | "NSP is a barrier film." |
| Sterile | Meets sterility requirements | "NSP passed the requirements for sterility with no observed turbidity in the 10 test samples." |
| Breathable | Breathable | "NSP is breathable." |
| Biocompatible | Non-cytotoxic, non-sensitizing, non-irritating | "NSSB is non-cytotoxic, non-sensitizing, and non-irritating." |
| Dries in ~60 seconds | Dries in approximately 60 seconds | "NSP dries in approximately 60 seconds." |
| Good in Skin Folds (non-self-adherent) | Non-self-adherent | "NSP is consider non-self-adherent." |
| Single Patient Use (Use life-28 days after opening) | Retains performance characteristics for 28 days after opening | "product retains its performance characteristics, and it does. The Use Life is 28 days after opening..." |
Summary of inapplicable AI/Software Device Evaluation Criteria:
The following items are not applicable as this document describes a physical medical device (skin protectant) and its chemical/biological properties, not an AI/software device for diagnostic or predictive purposes.
- Sample size used for the test set and the data provenance
- Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Adjudication method for the test set
- If a multi reader multi case (MRMC) comparative effectiveness study was done
- If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- The type of ground truth used
- The sample size for the training set
- How the ground truth for the training set was established
Details of the Studies Conducted (as per the document):
- No Sting:
- Study: Human testing using the Skin Trauma After Razor Shaving (STARS) bioassay.
- Purpose: To determine if the protectant caused subjective stinging when applied to skin challenged by dry shaving.
- Barrier Film:
- Study: Human testing conducted at cyberDERM Clinical Studies.
- Method: Carbon retention test method.
- Sterile:
- Study: USP 71, Sterility Tests.
- Sample Size: 10 test samples.
- Conditions: After 2 months of accelerated aging.
- Breathable:
- Study: Oxygen and moisture vapor transmission rate testing.
- Biocompatible:
- Study: Testing consistent with ISO 10993.
- Specific Tests:
- Cytotoxicity: L929 Agar Diffusion Test (Direct Contact); ISO Final GLP Report: 15-04007-G1. Test article: Atteris Skin Protectant on mouse fibroblast L929 cells.
- Direct Primary Skin Irritation: ISO Final GLP Report: 15-04007-G2. Test article: Atteris Skin Protectant on abraded skin sites of New Zealand White rabbits (single topical minimum 4-hour application).
- Direct Buehler Sensitization: ISO Final GLP Project: 15-04007-G3. Test article: Atteris Skin Protectant on albino guinea pigs (topical application).
- Dries in ~60 seconds:
- Study: Human testing conducted at cyberDERM Clinical Studies.
- Purpose: To determine dry time.
- Good in Skin Folds (non-self-adherent):
- Study: Human testing conducted at cyberDERM Clinical Studies.
- Comparison: To the commercial control, 3M Cavilon No Sting Barrier Film.
- Single Patient Use (Use life-28 days after opening):
- Study: Use life testing.
- Method: Product opened, sprayed, left open for 28 days, then re-tested to confirm performance characteristics.
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