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510(k) Data Aggregation
(260 days)
Stortford Medical LLC
The myNeWT system is indicted for patients who would benefit from Negative Pressure Wound Therapy as it may promote wound healing by removing low to moderate levels (
The myNeWT Negative Pressure Wound Therapy System is a portable, body worn, Single Use system for patients who have hard to heal wounds. Therapy is accomplished by the electronically controlled pump unit delivering a continuous negative pressure at -80 mmHg ±20mmHg to the wound surface, which draws the exudate into a flexible exudate canister, creating an environment that promotes wound healing via the removal of low to moderate amounts (
Here's an analysis of the provided text regarding the acceptance criteria and study for the myNeWT Negative Pressure Wound Therapy System, structured according to your request:
Note: The provided document is a 510(k) summary, which focuses on demonstrating substantial equivalence to predicate devices rather than a detailed report of a new clinical study with specific performance metrics against pre-defined acceptance criteria for a novel device. Therefore, much of the requested information regarding detailed acceptance criteria, specific performance metrics, sample sizes for test/training sets, expert adjudication methods, MRMC studies, standalone performance, and ground truth establishment in a clinical context is generally not present in this type of regulatory submission. The studies reported are primarily non-clinical (electrical, biocompatibility, mechanical, etc.) and aim to show the device meets design specifications and is safe and effective when compared to existing devices.
1. Table of Acceptance Criteria and Reported Device Performance
As this is a 510(k) summary focused on substantial equivalence rather than a de novo clinical trial, specific numerically defined "acceptance criteria" for a primary endpoint and "reported device performance" in a clinical human context are not explicitly stated in a tabular format. The document generally states that the device "passed all the verification and validation testing," indicating it met its internal design specifications and relevant standards.
Here's an interpretation based on the non-clinical tests conducted, where the "acceptance criteria" are implied by compliance with standards and successful completion of tests:
Acceptance Criteria Category (Implied) | Reported Device Performance |
---|---|
Electrical Safety | Passed AAMI ES 60601-1:2005/R 2012, IEC 60601-1-6: Ed 3.1 2013-10, ANSI/AAMI HA 60601-1-11:2011, and IEC 62366-1:2015. |
Electromagnetic Compatibility | Passed IEC 60601-1-2: Ed 4.0 2014-02 and IEC 60601-1-11: Ed 2.0 2015-01. |
Software Verification & Validation | Conducted and documentation provided as recommended by FDA guidance. |
Biocompatibility | Passed ISO10993-5 (Cytotoxicity), ISO 10993-10 (Sensitization), ISO 10993-10 (Primary skin Irritation). |
Sterility | Passed Sterility Validation using Ethylene Oxide to ANSI/AAMI/ISO 11135:2014. |
Sterile Packaging | Passed BS EN ISO 11607-1:2009 + A1:2014, including ISTA 2A distribution testing and accelerated/real-time aging. |
Mechanical Performance | Passed tests for compressor life, valve performance, battery life, pump noise, display visibility, canister strength, exudate containment, cleaning, and tube/connector mis-connection. |
Therapy Performance | Passed tests for vacuum levels (at pump and wound bed) and exudate removal performance. |
Stability/Shelf Life | Passed stability testing to support shelf life claims. |
Usability | Developed using a usability process conforming to IEC 62366-1:2015 and FDA Guidance. |
Distribution Testing | Passed ISTA Procedure 2A (2011) for final packed kit. |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size for Test Set: Not applicable in the context of human clinical data for this 510(k) submission. The document explicitly states: "Clinical testing was not required to demonstrate the substantial equivalence of the myNeWT System to the predicate devices."
- Data Provenance: The reported "test" data primarily comes from bench testing of the device components and system to engineering specifications and international standards. This is not human data.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
- This information is not provided as the "test set" primarily refers to non-clinical engineering and laboratory tests, not a clinical dataset requiring expert ground truth.
4. Adjudication Method for the Test Set
- Not applicable, as no clinical test set requiring adjudication by experts is mentioned.
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
- This information is not applicable. The device is a Negative Pressure Wound Therapy System, not an AI-powered diagnostic or assistive tool for human readers. No MRMC study was performed.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done
- Not applicable. This is a medical device (a pump system), not an AI algorithm. Its performance is inherent in its mechanical and software operation.
7. The type of ground truth used
- For the non-clinical tests, the "ground truth" is defined by established engineering specifications, international performance standards (e.g., ISO, IEC, AAMI), and documented test protocols. For example, for vacuum levels, the "ground truth" would be the target vacuum range as measured by calibrated equipment.
8. The Sample Size for the Training Set
- Not applicable, as this is not an AI/machine learning device requiring a training set.
9. How the Ground Truth for the Training Set was Established
- Not applicable, as this is not an AI/machine learning device.
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(84 days)
STORTFORD MEDICAL LLC
The Restep DVT System is a prescriptive device that helps stimulate blood flow in the deep veins of the legs and is intended for use in :- . Preventing Deep Vein Thrombosis due to the presence of risk factors for thrombus formation during orthopedic, trauma, neurology, urologic, critical care, general medicine obstetrics and general surgery.
The Restep DVT System consists of the Restep pump and compatible leg and foot compression garments. The system is a lightweight, portable, prescriptive pneumatic compression device that helps to stimulate blood flow in the deep veins of the legs through the use of pneumatically controlled single chamber pressure cuffs, actuated by an electronically controlled pump unit and solenoid valves.
The Restep DVT System is an intermittent pneumatic compression device intended to prevent Deep Vein Thrombosis (DVT). The 510(k) submission (K090308) indicates that no separate acceptance criteria or a dedicated study proving device performance against such criteria were performed for this device in the same way a diagnostic AI device might be evaluated. This device was deemed substantially equivalent to predicate devices based on technological characteristics and similar performance in pressure/cycle profile and blood flow augmentation.
Here's an analysis of the provided information based on your requested criteria:
1. Table of Acceptance Criteria and Reported Device Performance
Criterion Type | Acceptance Criteria | Reported Device Performance |
---|---|---|
Electrical Safety | Adherence to standards: UL60101-1, CSA22.2 No 601-1, IEC60601-1, EN60601-1. | Undergoing electrical safety and electromagnetic testing to the listed standards. (Implied expectation of meeting standards) |
Electromagnetic Compatibility (EMC) | Adherence to standards: IEC60601-2. | Undergoing electrical safety and electromagnetic testing to the listed standards. (Implied expectation of meeting standards) |
Software Performance | Software verification and validation (specific criteria not detailed, but generally implies functional correctness, robustness, and safety). | Software verification and validation completed. |
Output Performance (Pump) | Performance testing of the output parameters and profiles (e.g., consistent pressure delivery of 40mmHg nominal for leg garments and 80mmHg nominal for foot garments, and a cycle of approx. 12 seconds inflated and 48 seconds deflated). | Performance testing of the output parameters and profiles completed. |
Biocompatibility (Garments) | - Cytotoxicity: Material is non-cytotoxic (ISO10993-5). |
- Sensitization: Material does not elicit a sensitization response (ISO10993-10).
- Irritation: Material is a non-irritant (ISO10993-10). | - Cytotoxicity testing (ISO10993-5) results indicate the material is non-cytotoxic.
- Sensitization testing (ISO10993-10) results indicate the material does not elicit a sensitization response.
- Primary skin Irritation testing (ISO10993-10) results indicate the material is a non-irritant.
Overall: "results indicate that the material used will have negligible effects on the patient." |
| Clinical Performance (Blood Flow Augmentation) | Produce a similar pressure/cycle profile and similar level of blood flow velocity augmentation in the femoral vein compared to predicate devices (specific quantitative acceptance criteria are not provided for "similar," but implied to be within an acceptable range for therapeutic equivalence). | Test results of the Restep DVT System and predicate devices have shown that the Restep DVT System produces a similar pressure and time profile whilst squeezing a patient's limb and this results in similar level of blood flow velocity augmentation, as measured in the femoral vein. |
2. Sample Size Used for the Test Set and Data Provenance
The documentation does not explicitly state a specific "test set" sample size or its provenance (country of origin, retrospective/prospective) for a study intended to "prove the device meets acceptance criteria" in the way a diagnostic algorithm would.
Instead, the performance evaluation relies on bench testing (for pump and software) and biocompatibility testing (for garments) against established standards and in-house protocols. For clinical performance, it refers to:
- "test results of the predicate devices"
- "the Restep DVT System have been done for pressure/cycle profile, and blood flow augmentation on test subjects."
The number of "test subjects" for the blood flow augmentation comparison is not provided. The data provenance is also not specified.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
Not applicable in the context of this device. The "ground truth" for electrical safety, EMC, software validation, pump output, and biocompatibility is based on adherence to published international standards and in-house testing protocols, not expert consensus on clinical cases.
For blood flow augmentation, the "ground truth" would be the measured femoral vein velocity, but this is a physiological measurement, not an expert-adjudicated ground truth.
4. Adjudication Method for the Test Set
Not applicable. This is not an AI diagnostic device that requires expert adjudication of cases. The performance is assessed through objective measurements against technical specifications and physiological responses in test subjects.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done
No, an MRMC comparative effectiveness study was not done. This type of study is typically used for diagnostic devices where human readers interpret images or data, and their performance is compared with and without AI assistance. The Restep DVT System is a therapeutic device (intermittent pneumatic compression).
6. If a Standalone Study (i.e., algorithm only without human-in-the-loop performance) was done
Yes, in a sense, a standalone evaluation of the device's functional performance was central to its submission. The "algorithm" here would be the pump's control software and the pneumatic mechanism.
- Software verification and validation was performed.
- Performance testing of the output parameters and profiles of the pump was done to ensure it met its specifications (e.g., pressure, cycle times).
- The comparison for blood flow augmentation was described as "test results... on test subjects" measuring a physiological response directly, implying an "algorithm only" (device only) assessment of its effect.
7. The Type of Ground Truth Used
The "ground truth" for the various tests performed can be characterized as:
- Technical Specifications/Standards: For electrical safety, EMC, software validation, and pump output performance, the ground truth is defined by the requirements of the cited industry standards (e.g., UL, CSA, IEC, EN) and the device's design specifications (e.g., 40mmHg pressure, 12s inflate/48s deflate cycle).
- Biological/Chemical Assays: For biocompatibility (cytotoxicity, sensitization, irritation), the ground truth is derived from laboratory tests adhering to ISO10993 standards.
- Physiological Measurements: For blood flow velocity augmentation, the ground truth is the direct measurement of femoral vein velocity in test subjects.
8. The Sample Size for the Training Set
Not applicable. This device does not use machine learning or AI that would require a "training set." Its operation is based on fixed algorithms and pneumatic principles.
9. How the Ground Truth for the Training Set was Established
Not applicable as there is no training set for this device.
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