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510(k) Data Aggregation
(244 days)
Sumitomo Bakelite Co., Ltd
Flexible Overtube is a device used in conjunction with a flexible endoscope for tissue or foreign body retrieval, and/or for endoscopic procedures requiring multiple endoscope intubations.
Flexible Overtube™ provides an access for repeated insertion and withdrawal of an endoscope for tissue or foreign body retrieval, and/or for endoscopic procedures requiring multiple endoscope intubations. Prior to inserting an endoscope into a patient, the user passes the endoscope through Flexible Overtube™. Flexible Overtube™ is placed after the endoscope is inserted into the patient. The endoscope can be inserted and withdrawn through properly placed Flexible Overtube™.
Here's an analysis of the provided text regarding the acceptance criteria and study proving device performance:
Crucially, the provided text describes a 510(k) submission for a medical device (Flexible Overtube™) seeking substantial equivalence to a predicate device. This type of submission generally does not involve clinical studies with human subjects to prove a device meets specific performance criteria in the way a de novo or PMA submission would. Instead, it focuses on demonstrating that the new device is as safe and effective as a legally marketed predicate device, primarily through technological comparison, material biocompatibility testing, and functional bench testing.
Therefore, many of the typical questions for AI/diagnostic device performance studies (like sample sizes for test sets, expert ground truth, MRMC studies, etc.) are not applicable to this document. The focus here is on the "acceptance criteria" for establishing substantial equivalence, which are different from those for proving a diagnostic algorithm's accuracy.
The "study" here refers to the testing and comparisons done to support the claim of substantial equivalence.
Understanding the Context: 510(k) Premarket Notification
This submission (K182520) is a 510(k) Traditional Premarket Submission. The FDA review process for 510(k)s focuses on demonstrating substantial equivalence to a predicate device. This means the new device is:
- Intended for the same use as a predicate device.
- Has the same technological characteristics as the predicate device, OR
- Has different technological characteristics, but the information submitted by the applicant demonstrates that the device is as safe and effective as a legally marketed predicate device, and does not raise different questions of safety and effectiveness.
This is different from proving absolute performance against a set of clinical criteria for a diagnostic/AI device.
Analysis of the Provided Information:
1. A table of acceptance criteria and the reported device performance
The "acceptance criteria" in this context are not quantitative performance metrics for a diagnostic algorithm, but rather the criteria for demonstrating substantial equivalence to the predicate device. The "reported device performance" is mainly shown through qualitative comparisons and results of bench tests.
Acceptance Criterion (for Substantial Equivalence) | Reported Device "Performance" (Evidence from the Submission) |
---|---|
Similar Indications for Use | Met: Flexible Overtube™ is used "for tissue or foreign body retrieval, and/or for endoscopic procedures requiring multiple endoscope intubations." This is stated to be "identical to that of the Predicate device (Disposable Overtube K040836)." |
Similar Principles of Operation | Met: Both devices facilitate repeated insertion/withdrawal of an endoscope. The predicate device also uses a similar principle to reduce mucosal pinching (albeit with a two-tube system vs. single tube for the subject device). |
Technological Characteristics - Overtube Design | Met (with justification): Subject device uses a single tube with a soft, beveled distal end and lengthwise slit to reduce mucosal pinching. Predicate uses a two-tube system (inner/outer) with a tapered distal end for similar purpose. Justification: "both the proposed and the predicate devices provides an access for repeated insertion and withdrawal of an endoscope with reduced potential for mucosal pinching." |
Technological Characteristics - Seal Unit | Met (with justification): Subject device has a detachable seal unit. Insufflation seal testing showed internal pressure >4.0 kPa, which "is much more than the average of stomach pressure during insufflation." (No direct comparison to predicate seal performance provided, but the functionality appears to be similar and adequate). |
Technological Characteristics - Mouthpiece | Met (with justification): Subject device includes a detachable mouthpiece. Justification: "It is recommended that a minimum 60FR bite block be used with the predicate device. Therefore, the use of the Flexible Overtube™ with the Mouthpiece is not different from the use of the predicate device." |
Technological Characteristics - Length | Met (with justification): Subject device is 205 mm. Justification: This length is "within the range" (20-25 cm) recommended by ASGE for protection. The predicate has 250 mm and 500 mm models, with the 250 mm model also in range. |
Technological Characteristics - Diameter | Met (with comparison): |
Inner diameter: Subject - 16.0 mm. Predicate - 16.7 mm (Outer), 8.6 mm or 10.2 mm (Inner). | |
Outer diameter: Subject - 19.0 mm. Predicate - 19.5 mm (Outer tube). | |
Endoscope OD range: Subject - 9.0-12.0 mm. Predicate - 8.6-10.0 mm (for 8.6mm ID inner tube), 10.0-11.7 mm (for 10.2mm ID inner tube). The differences are noted but not presented as raising new questions of safety/effectiveness, implying clinical equivalence in use. | |
Technological Characteristics - Sterility | Improved (advantage for subject device): Subject device is EO sterilized (Sterility Assurance Level 10-6 achieved, residual EO/ECH/endotoxin within limits). Predicate device is non-sterile. This is considered a positive difference, not a new QSE. |
Biocompatibility | Met: Contact with mucosal membrane (Surface device, Mucosal, Contact A-limited). Tests performed: Cytotoxicity, Sensitization, Acute systemic toxicity, Irritation reactivity. "No biocompatibility concern was raised." |
Mechanical Performance | Met: Tensile strength test conducted, showed "enough for actual use." Simulated use test showed "bendability and stiffness... were kept during endoscopic treatment." |
2. Sample sized used for the test set and the data provenance
- Sample Size for Test Set: Not applicable in the traditional sense of a clinical test set for diagnostic performance. The "test set" here would refer to the physical devices used for bench testing (tensile strength, simulated use, insufflation seal, biocompatibility). The number of samples tested is not specified in the provided summary, but device submissions typically outline these in detailed test reports.
- Data Provenance: Not applicable. This is not clinical data from patients. The data comes from in vitro (bench) testing of the device itself and its materials.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Not applicable. There is no "ground truth" to establish for a diagnostic decision in this context. The testing is physical and chemical verification of device characteristics and safety.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable. No human adjudication of results is mentioned or would typically be required for this type of physical/material testing.
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
- No. An MRMC study is not relevant for this device. This is a physical medical device (an overtube for endoscopy), not an AI-assisted diagnostic tool.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- No. This is not an algorithm or AI device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- Not applicable. For this device, "ground truth" refers to established engineering standards, material safety standards (e.g., ISO, AAMI), and the functional requirements for an overtube. For example, the ground truth for biocompatibility is whether the materials elicit an adverse biological response when tested against ISO 10993 standards.
8. The sample size for the training set
- Not applicable. This device does not involve a training set as it is not an AI/machine learning product.
9. How the ground truth for the training set was established
- Not applicable. (See point 8).
In summary, the provided document details a 510(k) submission for a physical medical device (Flexible Overtube™). The "acceptance criteria" and "proof" relate to demonstrating substantial equivalence to a predicate device through a comparison of technological characteristics, confirmed by various bench tests (e.g., biocompatibility testing, tensile strength, seal testing). It does not involve clinical studies with human subjects or the evaluation of an AI algorithm's diagnostic performance.
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(43 days)
Sumitomo Bakelite Co., Ltd
The SB Knife® is a single-use sterile Electrosurgical Knife (Model Numbers: MD-47703 W, MD-47706 and MD-47703L). This device is designed to be used with Olympus and ERBE Electrosurgical monopolar HF generators, connectors and patient grounding plates to cut tissue including Zenker's diverticulum within the digestive tract using high-frequency current.
The SB Knife® is a single-use sterile Electrosurgical Knife (Model Numbers: MD-47703 W, MD-47706 and MD-47703L).
I am sorry, but the provided text does not contain information about acceptance criteria, device performance, study details, or ground truth establishment for a medical device. The document is a 510(k) clearance letter from the FDA for the SB Knife®, which states that the device is substantially equivalent to legally marketed predicate devices. It outlines regulatory requirements and indications for use, but it does not include performance study data, sample sizes, expert qualifications, or details about how ground truth was established, which are necessary to answer your request.
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(223 days)
Sumitomo Bakelite Co., Ltd
SB Soft Hood is intended for use with SB Knife for endoscopic submucosal dissection within the gastrointestinal tract and for use in keeping the suitable depth of endoscopic field of view.
SB Soft Hood™ is a transparent distal attachment applied to the tip of an endoscope. It is used in endoscopic submucosal dissection (hereinatter ESD) procedures. The subject device is used for maintaining visualization during the dissection phase of the procedure. The subject device is disposable and in a variety of diameters that correspond to different endoscope sizes. Each model of the subject device contains a drainage side hole that allows egress of water and blood.
This document is a 510(k) Summary for the SB Soft Hood™ device. It details the device's description, indications for use, comparison to a predicate device, and non-clinical testing performed to demonstrate substantial equivalence.
Here's a breakdown of the requested information based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly present a table of acceptance criteria with corresponding performance metrics in the format typically seen for algorithm performance (e.g., sensitivity, specificity, AUC). Instead, the "acceptance criteria" are implied by the non-clinical tests performed and the conclusion of "no new concern" or meeting "in-house standard which was determined based on expected worst-case."
Here's an interpretation of the implied acceptance criteria and reported performance:
Acceptance Criterion (Implied) | Reported Device Performance |
---|---|
Biocompatibility: No adverse biological reactions upon contact with tissue. | No biocompatibility concern was raised from tests (Cytotoxicity, Sensitization, Acute systemic toxicity, Irritation reactivity, Material-mediated pyrogenicity) per ISO 10993 standards and USPC 151. |
Durability: Device remains attached to the endoscope during clinical use (unaged and aged). | All samples met in-house standard which was determined based on expected worst-case (Visual inspection, durability testing, detachment testing). |
Sterility: Sterilization Assurance Level of 10^-6, no residual ETO/ECH, no endotoxin. | Sterilization Validation demonstrated SAL of 10^-6 per ISO 11135-1:2007. Residual EO and ECH were not detected per ISO10993-7:2008. Endotoxin was not detected per USP. Packaging integrity met ASTM F1929 and ASTM F88/F88M. |
Design Integrity/Functionality: Proper functioning (e.g., maintaining visualization, not interfering with SB Knife). | Risks related to inadequate length, poor view, endoscope disturbance, and SB Knife interference were mitigated by proper design. (No quantitative performance metrics are provided for this, just design-based mitigation). |
Material Safety: Materials are safe for intended use. | (Addressed by biocompatibility testing.) |
Substantial Equivalence to Predicate Device: No new safety or effectiveness concerns compared to the predicate. | Based on risk analysis, biocompatibility testing, sterilization validation, and shelf-life testing, no new concern demonstrated. Concluded to be substantially equivalent. |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
This device is a physical medical device, not an AI/software device that processes data or images. Therefore, the concepts of "test set sample size" and "data provenance" (country of origin, retrospective/prospective) stemming from AI/machine learning studies are not applicable to this submission. The tests performed are non-clinical, laboratory-based tests on the device itself.
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)
Again, the device is a physical medical accessory for endoscopy, not an algorithm requiring expert-established ground truth from images or data. Therefore, this information is not applicable. The "ground truth" for the non-clinical tests is based on established engineering and biological standards (e.g., ISO, USP, ASTM).
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Since this is not an AI/imaging study with subjective interpretation, an adjudication method for a "test set" is not applicable. The test results are objective measurements against established standards.
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
No, a multi-reader multi-case (MRMC) comparative effectiveness study was not done. This type of study is relevant for evaluating the impact of AI systems on human interpretation, which is not applicable to a physical endoscopic accessory. The document explicitly states: "Clinical testing was not performed for SB Soft Hood™."
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
No, a standalone performance study (algorithm only) was not done because this is a physical medical device, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
The concept of "ground truth" as typically used in AI/diagnostic studies (e.g., pathology, clinical outcomes) is not applicable here. For the non-clinical tests performed, the "truth" or reference is defined by:
- Established international and national standards (e.g., ISO 10993-5, ISO 10993-10, ISO 10993-11, USPC 151, ISO 11135-1:2007, ASTM F1929, ASTM F88/F88M, ISO10993-7:2008, USP).
- "In-house standard which was determined based on expected worst-case" for performance testing.
8. The sample size for the training set
This is not applicable as the device is not an AI/machine learning product and does not involve training data.
9. How the ground truth for the training set was established
This is not applicable as the device is not an AI/machine learning product and does not involve training data or ground truth establishment for a training set.
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(266 days)
SUMITOMO BAKELITE CO., LTD.
The SB Knife™ is a single-use sterile Electrosurgical Knife (Model Numbers: MD-47704, MD-47706 and MD-47703L). This device is designed to be used with Olympus and ERBE Electrosurgical monopolar HF generators, connectors and patient grounding plates to cut tissue within the digestive tract using high-frequency current.
The SB Knife™ is a single-patient use EtO-sterilized hand-held device that connects to an external high frequency (HF) generator and is designed to be used with Olympus and ERBE Electrosurgical monopolar HF generators, connectors and patient grounding plates to cut tissue within the digestive tract using high-frequency current. Varying generator power, cycle and duration results in a control of these surgical capabilities. The SB Knives are designed to connect with Olympus and ERBE connectors and use the disposable or reusable Olympus or ERBE grounding plates and connecting cables intended for the generators.
The device is not life supporting or life sustaining. It is designed as a short-term limited contact device (less than 24 hours), has no software, and has been certified to comply with IEC 60601-1 and IEC 60601-2-2 and IEC 60601-2-18 by UL Japan
This document is a 510(k) premarket notification for the SB Knife, an electrosurgical knife. It does not describe an AI medical device or a study involving acceptance criteria for an AI device's performance. Therefore, I cannot extract the requested information regarding acceptance criteria and studies that prove the device meets these criteria in the context of AI.
The document discusses the following:
- Device Name: SB Knife Jr Type, SB Knife Short Type, SB Knife Standard Type, SB Knife Jr Type - Long
- Regulation Number: 21 CFR 876.4300
- Regulation Name: Endoscopic Electrosurgical Unit and Accessories
- Regulatory Class: Class II
- Product Code: KNS
- Predicates: Olympus Medical Systems, Corp. IT Knife 2/ Hook Knife/ Flex Knife/ Triangle Tip Knife Electrosurgical Knife (K092309)
- Indications for Use: To be used with Olympus and ERBE Electrosurgical monopolar HF generators, connectors, and patient grounding plates to cut tissue within the digestive tract using high-frequency current.
- Non-Clinical Testing: Comparative bench and animal tissue testing was performed for tissue ablation, resection, incision, cauterization, hemostasis, coagulation, vaporization, and dissection of tissues using Olympus and ERBE monopolar HF generators.
- Clinical Testing: "Clinical testing was not performed for this medical device."
Since the SB Knife is a physical electrosurgical tool and not an AI device, the provided information does not contain the specific details requested for an AI acceptance criteria study (e.g., sample size for test/training sets, experts for ground truth, adjudication methods, MRMC studies, standalone performance, type of ground truth for AI).
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