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510(k) Data Aggregation

    K Number
    K232758
    Device Name
    Comatryx OTC
    Date Cleared
    2023-12-01

    (84 days)

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

    Strukmyer Medical, LLC.

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

    The device is intended for the management of minor scrapes, minor bruises, minor abrasions, minor lacerations, and minor burns.

    Device Description

    CoMatryx OTC Collagen Wound Dressing is a native bovine Type I Collagen which, when applied to a wound surface in powder or pad form, absorbs wound fluid and maintains a moist wound environment. The CoMatryx OTC powder and pads are provided sterile in the following configurations:

    • . 1 gram powder in 1 pouch
    • 2"x2," 3"x4," and 8"x12" pad in pouch
    AI/ML Overview

    The provided text describes a 510(k) premarket notification for a medical device called "CoMatryx OTC Collagen Wound Dressing." This type of submission aims to demonstrate substantial equivalence to a legally marketed predicate device, rather than proving safety and effectiveness through extensive clinical trials as would be required for a PMA.

    Therefore, the information you've requested regarding acceptance criteria, study details, sample sizes, expert ground truth establishment, MRMC studies, standalone performance, and training set details are not applicable (N/A) in the context of this 510(k) submission.

    Here's why and what information is provided:

    • 510(k) Substantial Equivalence: The primary goal of a 510(k) is to show that a new device is "substantially equivalent" to a predicate device already on the market. This often means demonstrating similar technological characteristics, intended use, and performance, with little to no new safety or effectiveness concerns. It does not typically involve the rigorous performance studies, human-in-the-loop assessments, or detailed ground truth establishment associated with AI/ML device approvals or PMAs.
    • Focus on Bench Testing and Biocompatibility: For devices like wound dressings, the evidence typically relies on bench testing (e.g., sterilization, shelf life, physical properties) and biocompatibility testing, rather than studies involving human readers or complex algorithms.

    Based on the provided document, here's what can be extracted and why the requested information is N/A:

    1. A table of acceptance criteria and the reported device performance

    Parameter / Acceptance CriteriaReported Device PerformanceRationale for N/A
    Acceptance Criteria for Clinical PerformanceN/A - Not ApplicableThe submission is for substantial equivalence to a predicate device, not for proving clinical efficacy against specific performance metrics directly. The performance is assessed by comparison to the predicate.
    Device Performance (Clinical/Algorithmic)N/A - Not ApplicableNo clinical performance data (e.g., accuracy, sensitivity, specificity for a diagnostic device, or wound healing rates) is provided or required for this type of submission beyond demonstrating equivalence to the predicate.

    Instead, the document highlights parameters compared to the predicate device:

    ParametersSubject Device CoMatryx OTC Collagen Wound DressingsPredicate Device Cellufil and Cellusheet Wound Dressings K213092
    ManufacturerStrukmyer Medical LLCHuman Biosciences Inc.
    Intended UseManagement of woundsManagement of wounds
    Indications for UseManagement of minor cuts, minor scrapes, minor bruises, minor abrasions, minor lacerations, and minor burnsManagement of minor cuts, minor scrapes, minor bruises, minor abrasions, minor lacerations, and minor burns.
    Product CodeKGNKGN
    Device ClassUnclassifiedUnclassified
    Rx or OTCOTCOTC
    Physical ShapePowder and PadsPowder and Pads
    UsageSingle patient use onlySingle patient patient use only
    Package Sizes1 gram in 1 pouch, 2"x2", 3"x4", 8"x12" pads1 gram in 1 pouch, 2"x2", 3"x4", 8"x12" pads
    Product DescriptionType I Bovine CollagenType I Bovine Collagen
    Animal TissueDermisDermis
    Sterilization MethodE-Beam. Product supplied sterile.E-Beam. Product supplied sterile.
    Storage ConditionStore in a cool and dry spaceStore in a cool and dry space
    Shelf LifePowder - 36 months, Pads - 48 months60 months

    The conclusion states: "Comatryx OTC Collagen Wound Dressings are identical to the predicate device except for the indications for use; therefore, testing from K171645 applies to this device." This implies that prior testing for the predicate device (K171645) supported its safety and effectiveness, and since the current device is "identical except for indications," that prior testing is considered sufficient.

    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: N/A - No clinical "test set" in the context of an AI/ML or comparative clinical performance study is described. The relevant data for a wound dressing is likely bench testing (sterilization, physical properties, biocompatibility).
    • Data Provenance: N/A - Not applicable for this type of submission.

    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)

    • N/A - Not applicable. This type of ground truth establishment by experts is relevant for diagnostic devices, particularly those involving image interpretation (e.g., radiology AI). This wound dressing device does not involve such an assessment.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    • N/A - Not applicable. No expert adjudication process is described or required for this type of device submission.

    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

    • N/A - Not applicable. This device is a collagen wound dressing, not an AI-assisted diagnostic tool.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    • N/A - Not applicable. This device is not an algorithm.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    • N/A - Not applicable. The "ground truth" for a wound dressing focuses on its material properties, biological compatibility, and ability to maintain a moist wound environment, typically demonstrated through in vitro and in vivo (animal, not human clinical trials unless specifically deemed necessary for a novel claim) testing, rather than clinical outcomes data or expert consensus on interpretations. The submission relies on "comparison of the composition, technological characteristics, intended use and biocompatibility test results" to a predicate.

    8. The sample size for the training set

    • N/A - Not applicable. This device is not an AI/ML algorithm requiring a training set.

    9. How the ground truth for the training set was established

    • N/A - Not applicable. As above, this device is not an AI/ML algorithm.
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    Why did this record match?
    Applicant Name (Manufacturer) :

    STRUKMYER MEDICAL LLC

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

    For Over-the-Counter Use: For moistening absorbent wound dressings and cleaning minor cuts, minor burns, superficial abrasions and minor irritations of the skin.

    For Prescription Use: For moistening absorbent wound dressings and for moistening, debriding and cleaning acute and chronic dermal lesions, such as Stage I-IV pressure ulcers, diabetic ulcers, foot ulcers, post-surgical wounds, first and second degree burns, cuts, abrasions and minor skin irritations and for device irrigation.

    Device Description

    The Sterile Water and Sterile Normal Saline devices are wound and device cleaning solutions that are intended for moistening and debriding of dermal wounds and for device irrigation. The solution is either sterile water or sterile normal saline for irrigation and meets the requirements of USP . The devices are offered in 100 mL, 250 mL and 500 mL bottles and 120 mL cups

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for "USP Sterile Water" and "USP Sterile Normal Saline (0.9% Sodium Chloride)." This document is a regulatory submission for medical devices, primarily focusing on demonstrating substantial equivalence to a predicate device rather than presenting extensive performance studies against specific acceptance criteria.

    As such, the document does not contain the detailed information requested regarding:

    • A table of acceptance criteria and reported device performance.
    • Sample size used for a test set or its provenance.
    • Number of experts and their qualifications for establishing ground truth.
    • Adjudication method for a test set.
    • Multi-Reader Multi-Case (MRMC) comparative effectiveness study or effect size.
    • Standalone (algorithm-only) performance.
    • Type of ground truth used.
    • Sample size for a training set.
    • How ground truth for the training set was established.

    Instead, the document focuses on demonstrating substantial equivalence to a predicate device (K083042, Sterile Water and Sterile Normal Saline from Nurse Assist, Inc.) based on:

    • Intended Use: The device shares the same intended uses as the predicate, which includes moistening absorbent wound dressings, cleaning minor cuts/burns/abrasions/irritations (OTC use), and moistening/debriding/cleaning acute/chronic dermal lesions and device irrigation (Prescription Use).
    • Technological Characteristics: The devices have the same technological characteristics (sterile water or sterile normal saline meeting USP and providing mechanical action for cleaning).
    • Mechanism of Action: The mechanism of action is identical – mechanical action of fluid for removing foreign objects.
    • Composition: Supplied sterile in containers of identical composition.
    • Biocompatibility Testing: The devices were tested according to ISO 10993 standards and found to be non-cytotoxic, non-irritating, and non-sensitizing, with results similar to those reported for the predicate devices.

    Conclusion:

    The submission concludes that "Based on a comparison of composition, technological characteristics, intended use and biocompatibility test results, we conclude that Sterile Normal Saline perform at least as well as the predicate devices. Sterile Water and Sterile Normal Saline are therefore considered to be substantially equivalent to the above-mentioned predicate devices."

    Therefore, for this specific submission, the "acceptance criteria" revolve around demonstrating comparable characteristics and safety to a legally marketed predicate device, rather than quantitative performance metrics against pre-defined clinical thresholds typically seen for more complex diagnostic or therapeutic devices. The "study" that proves the device meets "acceptance criteria" (i.e., substantial equivalence) consists of the comparative analysis described above and the biocompatibility testing.

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