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510(k) Data Aggregation

    K Number
    K181074
    Manufacturer
    Date Cleared
    2018-08-17

    (115 days)

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

    Simple Science LLC

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

    For Over-the-Counter Use: For management of minor skin abrasions, minor lacerations, minor irritations, and intact skin of the face, eyelid and eyelashes.

    Device Description

    Simple Science Antimicrobial Facial & Eyelid Cleanser is a clear hypotonic solution topically applied to skin, eyelid and wound areas. The subject device is a wound management and cleansing solution that is intended for cleansing, irrigating, and debriding dermal wounds in addition to moistening and lubricating absorbent wound dressings (e.g. gauze). The mechanical action of fluid moving across the wound provides for the mechanism of action and aids in the removal of foreign objects such as dirt and debris. Simple Science Antimicrobial Facial & Eyelid Cleanser contains the following ingredients: Ionized water (99.927%), Sodium chloride (0.06%), Hypochlorous acid (0.011%) and hypochlorite Ion (0.002%). Simple Science Antimicrobial Facial & Eyelid Cleanser will be supplied in 2 oz Glass bottle with spray inserts / caps.

    AI/ML Overview

    The provided text does not contain information about acceptance criteria for device performance in the context of image analysis, AI models, or diagnostic accuracy. Instead, it is a 510(k) summary for a medical device called "Simple Science Antimicrobial Facial & Eyelid Cleanser."

    The acceptance criteria and study information requested in the prompt (e.g., sample size for test set, ground truth experts, MRMC studies, standalone performance, training set details) are relevant to the evaluation of AI/ML-based medical devices or diagnostic tools. The document describes a physical product and its regulatory submission, focusing on:

    • Device Description: A clear hypotonic solution for topical application.
    • Intended Use: For management of minor skin abrasions, minor lacerations, minor irritations, and intact skin of the face, eyelid, and eyelashes.
    • Technological Characteristics: Contains ionized water, sodium chloride, hypochlorous acid, and hypochlorite ion. It's a wound management and cleansing solution.
    • Performance Testing (for this physical product):
      • Biocompatibility studies (ISO 10993): Cytotoxicity, sensitization, ocular studies.
      • Preservative effectiveness: Supported by USP testing against specific bacteria (Proteus mirabilis, Serratia marcescens, MRSA, VRE, Acinetobacter baumannii).
      • Stability study: Demonstrates stability and effectiveness for a 12-month shelf life.

    Since the document is about a topical cleanser and not an AI/ML diagnostic device, it does not include the specific details requested in your prompt regarding acceptance criteria, study design, and ground truth for such technologies. Therefore, I cannot construct the table or answer the specific questions about AI/ML performance from this document.

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    Why did this record match?
    Applicant Name (Manufacturer) :

    Simple Science, LLC

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

    For Over-the-Counter Use: For management of minor skin abrasions, minor lacerations, minor irritations, minor cuts, minor burns and intact skin.

    Prescription Use: For management of wounds such as Stage I-IV pressure ulcers, partial and full thickness wounds, diabetic foot and leg ulcers, post-surgical wounds, first-and seconddegree burns, grafted and donor sites, and minor irritations of the skin in addition to moistening and lubricating absorbent wound dressings.

    Device Description

    Simple Science Antimicrobial Wound & Skin Cleanser is a clear hypotonic solution topically applied to skin and wound areas. The subject device is a wound management and cleansing solution that is intended for cleansing, irrigating, and debriding dermal wounds in addition to moistening and lubricating absorbent wound dressings (e.g. gauze). The mechanical action of fluid moving across the wound provides for the mechanism of action and aids in the removal of foreign objects such as dirt and debris. Simple Science Antimicrobial Wound & Skin Cleanser contains the following ingredients: Ionized water (99.927%), Sodium chloride (0.06%), Hypochlorous acid (0.011%) and hypochlorite Ion (0.002%). Simple Science Antimicrobial Wound & Skin will be supplied in Polyethylene terephthalate (PET) bottles of various volumes (2 oz, 8 oz, 16 oz, 23 oz) with spray inserts / caps.

    AI/ML Overview

    This document is a 510(k) Pre-market Notification for a medical device called "Simple Science Antimicrobial Wound & Skin Cleanser." It is a submission to the FDA seeking clearance to market the device by demonstrating its substantial equivalence to legally marketed predicate devices.

    Here's an analysis of the acceptance criteria and study information based on the provided text:

    This document describes a medical device, not an AI/ML powered device, therefore, many of the requested fields (e.g. number of experts for ground truth, adjudication methods, MRMC studies, standalone performance) are not applicable.


    1. Table of acceptance criteria and the reported device performance

    Acceptance Criteria CategorySpecific CriteriaReported Device Performance
    BiocompatibilityDemonstrate that the device is as safe and effective as predicate devices as per ISO 10993.Met for cytotoxicity, sensitization, and irritation. Device is "as safe and as effective as its predicate devices."
    Preservative EffectivenessDemonstrate preservative effectiveness as per USP .Met. Demonstrated effectiveness against: Proteus mirabilis, Serratia marcescens, antibiotic resistant Methicillin-Resistant Staphylococcus aureus (MRSA), Vancomycin-resistant Enterococcus faecalis (VRE), and Acinetobacter baumannii in solution.
    Shelf-life StabilityDemonstrate stability and effectiveness for the claimed shelf life.Product is "stable and effective for the entire shelf life of 12 Months."
    ManufacturingManufactured under current Good Manufacturing Practices (cGMPs) guidelines and established manufacturing, quality, and product specifications."Process validations have been completed... Manufacturing controls have been established and implemented... Established cGMPs will assure the device manufactured... Meets all the established specifications prior to release."

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    The document does not specify a "test set" in the context of a dataset for an AI/ML model. The performance testing described (biocompatibility, preservative effectiveness, stability) involves laboratory-based studies rather than a clinical dataset of patients. Therefore, information about data provenance and retrospective/prospective nature is not applicable here.

    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 traditional medical device (wound cleanser), not an AI/ML device that requires human expert annotation for ground truth. The "ground truth" for its performance is established through standard laboratory and chemical testing methodologies.

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

    Not applicable. As this is not an AI/ML device relying on expert review of a test set, adjudication methods are irrelevant.

    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 wound cleanser, not an imaging or diagnostic AI/ML device that would involve human readers or MRMC studies.

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

    Not applicable. There is no algorithm, AI, or software component mentioned that would operate in a standalone mode.

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

    The "ground truth" for this device's performance is based on well-established laboratory and scientific standards:

    • Biocompatibility: ISO 10993 toxicology standards.
    • Preservative Effectiveness: United States Pharmacopeia (USP) standards, which involve specific microbial challenges.
    • Stability: Direct measurement of product characteristics over time under controlled conditions.
    • Antimicrobial activity: Testing against specific ATCC (American Type Culture Collection) bacterial strains.

    8. The sample size for the training set

    Not applicable. This is not an AI/ML device that uses a "training set."

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

    Not applicable. As there is no training set for an AI/ML model, the concept of establishing ground truth for it is irrelevant.

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    K Number
    K142592
    Date Cleared
    2015-09-02

    (352 days)

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

    SIMPLE SCIENCE, LLC

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

    Over-the-Counter Use: For management of minor skin abrasions, minor irritations, minor cuts, minor cuts, minor burns and intact skin. Prescription Use: For management of wounds such as Stage I-IV pressure ulcers, partial and full thickness wounds, diabetic foot and leg ulcers, post-surgical wounds, first-and second-degree burns, grafted and donor sites, and minor irritations of the skin in addition to moistening and lubricating absorbent wound dressings.

    Device Description

    CleanSmart™ Wound Cleanser is a clear hypotonic solution topically applied to skin and wound areas. The subject device is a wound management and cleansing solution that is intended for cleansing, irrigating, and debriding dermal wounds in addition to moistening and lubricating absorbent wound dressings (e.g. gauze). The mechanical action of fluid moving across the wound provides for the mechanism of action and aids in the removal of foreign objects such as dirt and debris. CleanSmart™ Wound Cleanser contains the following ingredients: Ionized water (99.927%), Sodium chloride (0.06%), Hypochlorous acid (0.011%) and hypochlorite Ion (0.002%). CleanSmart™ Wound Cleanser will be supplied in Polyethylene terephthalate (PET) bottles of various volumes (2 oz, 8 oz, 16 oz, 23 oz) with spray inserts / caps.

    AI/ML Overview

    This document is a 510(k) Summary for the CleanSmart™ Wound Cleanser, indicating that it is a medical device application seeking to demonstrate substantial equivalence to previously cleared devices. It is not an AI/ML device, and therefore the majority of the requested information (sample sizes, expert ground truth, MRMC studies, standalone performance, training sets, etc.) is not applicable.

    However, I can extract the relevant information regarding the performance testing and acceptance criteria as described in the document.

    1. Table of Acceptance Criteria and Reported Device Performance:

    Acceptance Criteria CategorySpecific Test/RequirementAcceptance CriteriaReported Device Performance
    BiocompatibilityCytotoxicityMeets ISO 10993Device demonstrated to meet ISO 10993 requirements
    SensitizationMeets ISO 10993Device demonstrated to meet ISO 10993 requirements
    IrritationMeets ISO 10993Device demonstrated to meet ISO 10993 requirements
    Preservative EffectivenessUSP testing Against Specific OrganismsEffective against listed microorganismsDemonstrated effectiveness against: * Proteus mirabilis (ATCC - 25933) * Serratia marcescens (ATCC-8100) * Methicillin-Resistant Staphylococcus aureus (MRSA) (ATCC-43300) * Vancomycin-resistant Enterococcus faecalis (VRE) (ATCC-700221) * Acinetobacter baumannii (ATCC 19606)
    Shelf-Life StabilityProduct StabilityStable and effective for 12 monthsProduct demonstrated to be stable and effective for 12 months

    Study Proving Device Meets Acceptance Criteria:

    The study that proves the device meets the acceptance criteria is detailed in the "Performance Testing" section (Page 5, Section 14) of the 510(k) Summary.

    2. Sample size used for the test set and the data provenance:

    • Sample Size for Test Set: This type of information is not provided in the summary. For studies like biocompatibility (ISO 10993) and preservative effectiveness (USP ), the sample sizes are determined by the specific standards and test methodologies themselves, rather than being explicitly stated as a general "test set" size in this summary.
    • Data Provenance: Not explicitly stated, but these are laboratory tests following established international standards (ISO) and pharmacopeial monographs (USP). The manufacturer is Simple Science, LLC, based in Edina, Minnesota, USA, suggesting the studies were likely conducted in the US or by accredited labs following these standards. The data would be prospective, as these are de novo tests conducted for the purpose of the 510(k) submission.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    This information is not applicable to the type of device and testing described. The "ground truth" for chemical and biological laboratory tests of a wound cleanser is based on the objective readings and protocols of the specified standards (ISO 10993, USP ), not on human expert consensus, pathology, or outcomes data in the way an AI/ML diagnostic device would require.

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

    Not applicable. Adjudication methods are typically relevant for subjective expert reviews, particularly in medical image analysis or clinical trials involving human assessment, which is not the case for these laboratory-based performance tests.

    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 device is a wound cleanser, not an AI/ML diagnostic or assistive device that would involve human readers.

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

    Not applicable. This device is a physical product (wound cleanser), not an algorithm. Therefore, "standalone performance" in the context of an algorithm is irrelevant.

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

    The "ground truth" for the performance tests described (biocompatibility, preservative effectiveness, stability) is based on:

    • Objective measurements and standardized protocols: For ISO 10993 (biocompatibility), the ground truth is determined by the cellular responses and tissue reactions measured against established safety thresholds.
    • Microbiological assay results: For USP (preservative effectiveness), the ground truth is the measured reduction in microbial populations over time, compared to acceptance criteria defined in the USP monograph.
    • Chemical and physical stability parameters: For shelf-life stability, the ground truth is the chemical composition and physical properties remaining within specified ranges over time.

    These are not based on expert consensus, pathology, or outcomes data in a clinical sense.

    8. The sample size for the training set:

    Not applicable. This is not an AI/ML device, so there is no "training set."

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

    Not applicable. As there is no training set for an AI/ML algorithm, this question is not relevant.

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