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510(k) Data Aggregation
(227 days)
VIRCHOW BIOTECH PVT LTD
Hyaluronic Acid Topical Wound Cream 0.2%w/w is indicated for dressing and management of wounds such as partial to full thickness dermal ulcers (pressure ulcers, venous stasis ulcers, diabetic ulcers), surgical wounds (post-operative incisions and donor sites), first and second degree burns.
Hyaluronic Acid Topical Wound Cream 0.2%w/w is indicated for dressing and management of minor burns, minor superficial cuts, minor lacerations, and minor abrasions; and minor irritation of the skin.
Hyaluronic Acid Topical Wound Cream 0.2%w/w is a white or light straw colored hydrophilic viscous cream containing hyaluronic acid for topical use on wounds.
This document is a 510(k) summary for the Hyaluronic Acid Topical Wound Cream 0.2%w/w, claiming substantial equivalence to a predicate device, Bionect® Cream (K963004). This type of submission is for medical devices that are substantially equivalent to a legally marketed predicate device and does not typically involve comprehensive studies with specific acceptance criteria, sample sizes, and ground truth definitions as would be present in a de novo classification or premarket approval (PMA) application for novel, high-risk devices or software as a medical device (SaMD).
Instead, "acceptance criteria" here refers to demonstrating that the new device shares the same fundamental scientific technology, physical and performance characteristics, and indications for use as the predicate device, and that any differences do not raise new questions of safety or effectiveness. The study supporting this is primarily biocompatibility testing and comparative analysis rather than a clinical trial with specific performance metrics like sensitivity/specificity.
Let's break down the information provided in the context of a 510(k) submission:
1. A table of acceptance criteria and the reported device performance:
Since this is a 510(k) submission based on substantial equivalence, there are no explicit "acceptance criteria" in terms of specific performance metrics like sensitivity, specificity, or F1-score for the device. Instead, the acceptance criteria are implicitly that the new device (Hyaluronic Acid Topical Wound Cream 0.2%w/w) is as safe and effective as the predicate device (Bionect® Cream) and shares the same technological characteristics and intended use.
Acceptance Criteria (Implicit for 510(k) Substantial Equivalence) | Reported Device Performance (Summary) |
---|---|
Technological Characteristics: | The characteristics of Hyaluronic Acid Topical Wound Cream 0.2% w/w are not different from the predicate device (Bionect® Cream). The proposed device uses the same technology (Hyaluronic acid as a moisture-management component) and is a hydrophilic topical cream containing 0.2% w/w sodium hyaluronate. |
Intended Use/Indications: | Prescription Use: Indicated for dressing and management of wounds such as partial to full thickness dermal ulcers (pressure ulcers, venous stasis ulcers, arterial ulcers, diabetic ulcers), surgical wounds (post-operative incisions and donor sites), first and second-degree burns. (Page 5) |
Over-the-Counter Use: Indicated for dressing and management of minor burns, minor superficial cuts, minor lacerations, and minor abrasions; and minor irritation of the skin. (Page 7) (Both indications are stated to be similar to the predicate device.) | |
Safety and Effectiveness: | "The performed studies demonstrated that Hyaluronic Acid Topical Wound Cream 0.2%w/w is as safe and effective as the predicate device (Bionect® Cream) for its intended use on breached and compromised skin as a moist wound dressing." (Page 5 and 7) This conclusion is based on biocompatibility testing and comparative studies. |
Biocompatibility: | Testing conducted according to ISO 10993 'Biological Evaluation of Medical Devices'. (Page 5 and 7) |
Physical/Performance Characteristics: | Described as a white or light straw colored hydrophilic viscous cream intended for moisture management on the wound bed to aid in providing a moist wound environment. It is a repeat use, preservative-protected non-sterile topical product. (Pages 5-7) (These characteristics are implied to be consistent with the predicate.) |
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 clinical images or diagnostic performance. The evaluation performed was primarily biocompatibility testing and comparative studies against the predicate device. The sample size for these studies is not provided, nor is the country of origin of the data explicitly stated (other than the sponsor being in India). The nature of these "comparative studies" is not detailed enough to determine if they were retrospective or prospective, but typical biocompatibility testing would involve in-vitro and/or in-vivo animal models, which are prospective.
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):
This information is not applicable to this 510(k) submission. There was no clinical ground truth established by experts for a test set, as this is a topical wound cream and not a diagnostic device involving expert interpretation of medical images or other clinical data for performance evaluation. The "ground truth" for demonstrating safety and effectiveness relied on standard biocompatibility tests and comparison to a known safe and effective predicate device.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
This information is not applicable. Since there was no test set involving expert review or interpretation of cases, no adjudication method was used or needed.
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 topical wound cream, not an AI or diagnostic tool. Therefore, an MRMC study related to human reader performance with or without AI assistance was not conducted.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done:
This information is not applicable. The device is a topical wound cream, not an algorithm, so a standalone performance evaluation of an algorithm was not performed.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc):
The "ground truth" in this context is the established safety and effectiveness profile of the predicate device (Bionect® Cream), supported by regulatory standards for medical device safety. The studies performed were biocompatibility tests (according to ISO 10993) and comparative studies to show that the new device performed similarly to the predicate. This relies on the assumption that if the new device has identical technological characteristics, similar indications, and passes standard safety tests (biocompatibility), then its safety and effectiveness are "ground-truthed" by the predicate.
8. The sample size for the training set:
This information is not applicable. This is not an AI/ML device, so there is no concept of a "training set" for an algorithm. The development of the cream would involve formulation and laboratory testing, but not in the sense of a data "training set."
9. How the ground truth for the training set was established:
This information is not applicable, as there is no training set for this type of medical device submission.
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(283 days)
VIRCHOW BIOTECH PVT. LTD.
OTC: DONASORB™ is intended for use in management of minor cuts, minor abrasions, minor lacerations and minor burns.
Rx: DONASORB™ is intended for use by prescription for the management of partial and full thickness wounds such as pressure ulcers, vascular ulcers, diabetic wounds, lacerations, abrasions, surgical wounds, graft sites, skin tears, and first and second degree burns. DONASORB™ is not indicated for use on third degree burns.
DONASORB™ is a moist hydrogel sheet containing the antimicrobial ionic silver in the form of silver chloride which is intended to be a primary wound contact dressing to manage wound moisture. The base matrix of the subject device is composed of crosslinked polyacrylate sheet incorporating antimicrobial ionic silver in a silver chloride reservoir. Ionic silver in the form of silver chloride in the sheet inhibits the growth of broad spectrum microbes on or within the dressing. The Device is a sterile single use dressing supplied on PVC (Poly Vinyl Chloride) transparent carrier sheet, packed in a medical grade heat sealed aluminum foil pouch. Five single piece pouches are packed in a Mono-carton along with a package insert. Barrier and Antimicrobial Effectiveness was demonstrated to last for up to 2 days per bench testing. It is recommend to use DONASORB™ for up to 2 days or should be removed gently when completely saturated with wound fluids; whichever occurs first. It is available in sterile sheets of 2x2 cm, 2x4 cm, 4x8 cm, 8x8 cm and 10x10 cm sizes.
This document describes the DONASORB™ Silver Wound Dressing, a medical device, and the testing conducted to demonstrate its performance and safety. It's important to note that this is a 510(k) premarket notification, meaning the device is seeking clearance by demonstrating substantial equivalence to a legally marketed predicate device, rather than requiring extensive clinical trials to prove efficacy from scratch. Therefore, the "acceptance criteria" and "study" described are primarily focused on equivalence and bench testing, not necessarily a comparative effectiveness study against a gold standard for treatment outcomes.
Here's the breakdown of the information requested:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly state quantitative "acceptance criteria" for performance metrics in a pass/fail sense with numerical thresholds typically seen for AI device performance. Instead, the "acceptance criteria" are implied by demonstrating substantial equivalence to the predicate device (AcryDerm Silver Antimicrobial Barrier Wound Dressing) and conformity to established testing standards.
Acceptance Criteria (Implied) | Reported Device Performance |
---|---|
Bacterial Barrier Property (Prevent bacterial penetration) | DONASORB™ was evaluated for its effective barrier property. |
Antimicrobial Efficiency (Inhibit microbial growth on/within dressing) | DONASORB™ was evaluated for its antimicrobial efficiency to inhibit the growth of microorganisms. Tests used 3 Gram positive, 3 Gram negative, and 2 fungi organisms with repeated inoculation over 24 hours. |
Duration of Effectiveness | Barrier and Antimicrobial Effectiveness was demonstrated to last for up to 2 days per bench testing. Recommended use is up to 2 days or until saturated. |
Biocompatibility/Safety (ISO 10993 compliance) | Demonstrated to be substantially similar to its predicate (AcryDerm) in: In Vitro Cytotoxicity Study, Acute Toxicity Test, Intracutaneous Irritation/Reactivity Study, Skin Sensitization testing, and Sub chronic toxicity test. |
Sterility | Provided as a sterile single use device. |
Manufacturing Standards | Will be manufactured according to product specifications under good manufacturing practices. |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size for Test Set: Not explicitly stated in terms of number of dressings or units tested for the bacterial barrier, antimicrobial efficacy, and biocompatibility studies. These were bench tests, not clinical studies on patient samples. For the antimicrobial efficacy, the "sample" refers to the types of microorganisms tested (3 Gram positive, 3 Gram negative, and 2 fungi organisms).
- Data Provenance: The document does not specify country of origin for the test data directly, but the submitter (Virchow Biotech PVT LTD) is located in India. The tests performed are described as "bench testing," meaning they were conducted in a laboratory setting. These were prospective bench tests specifically designed to evaluate the DONASORB™ device.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
This information is not applicable as the "test set" does not involve human interpretation or subjective assessment that would require expert consensus for ground truth. The tests are laboratory-based, objective measurements (e.g., microbial growth inhibition, penetration rates, cytotoxicity).
4. Adjudication Method for the Test Set
This information is not applicable. The tests are objective laboratory tests, and thus no adjudication method like 2+1 or 3+1 is required.
5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study was done
No, a Multi Reader Multi Case (MRMC) comparative effectiveness study was not done. This type of study is typically performed for AI or diagnostic imaging devices where human readers interpret results, and the study would compare human performance with and without AI assistance on a set of cases. The DONASORB™ is a wound dressing, and its performance is evaluated through bench testing and biocompatibility assessments, not through human reader interpretation of output.
6. If a Standalone (i.e. algorithm only without human-in-the loop performance) was done
No, a "standalone" performance evaluation in the context of an algorithm or AI device was not done. The term "standalone" performance typically applies to AI algorithms operating independently of human intervention. DONASORB™ is a physical medical device (wound dressing), not an algorithm or AI. Its performance (e.g., antimicrobial efficacy, barrier property) is inherent to the dressing itself.
7. The Type of Ground Truth Used
The "ground truth" for the device's performance is established through objective laboratory measurements and established scientific testing standards.
- Bacterial Barrier Property: Likely determined by measuring the passage of bacteria through the dressing material under controlled conditions, with the "ground truth" being the measured presence or absence and quantity of bacteria on the "wound" side of the dressing.
- Antimicrobial Efficacy: Determined by measuring the inhibition or reduction of microbial growth on or within the dressing compared to controls, with the "ground truth" being the observed microbial counts.
- Biocompatibility/Safety (ISO 10993): "Ground truth" established by compliance with the well-defined methodologies and acceptance criteria outlined in the ISO 10993 series of standards for biological evaluation of medical devices. This includes observing cellular responses (cytotoxicity), tissue reactions (irritation, sensitization), and systemic effects (acute and subchronic toxicity).
8. The Sample Size for the Training Set
Not applicable. The DONASORB™ is a physical medical device (wound dressing), not an AI/ML algorithm or system that requires a "training set" for model development.
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 to the DONASORB™ device.
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(391 days)
VIRCHOW BIOTECH PVT. LTD.
OTC: For minor wounds, minor ulcerations, minor abrasions, minor surgical wounds and minor skin irritations.
IONSIL GEL™ is a moist amorphous hydrophilic silver chloride gel designed to act as a barrier for wounds, as a moist wound dressing. The viscous hydrogel of the device contains silver in the form of silver chloride which acts as a self preservative that inhibits the growth of broad spectrum of micro organisms in the dressing.
The product is available in a 1.5 oz (45 gm) polyethylene heat sealed tube container. The tubes will be packed in a cardboard box.
This document is a 510(k) premarket notification for a medical device called IONSIL GEL™, an unclassified wound hydrogel. The FDA determined it is substantially equivalent to a predicate device.
Here's an analysis of the acceptance criteria and supporting study information based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly state acceptance criteria in terms of quantitative performance metrics for the device itself (e.g., specific percentages for effectiveness, sensitivity, or specificity). Instead, it focuses on demonstrating substantial equivalence to a predicate device and safety through biocompatibility and antimicrobial testing.
Criterion Type | Acceptance Criterion (Implicit) | Reported Device Performance |
---|---|---|
Intended Use | Equivalent to predicate device's intended use. | IONSIL GEL™ is intended for OTC use in the management of normal skin and minor wounds, ulcerations, minor abrasions, minor surgical wounds and minor skin irritations. This is stated to be substantially equivalent to the predicate device's indications. |
Technological Characteristics | Similar to predicate device; moist wound dressing, silver as self-preservative. | IONSIL GEL™ is a moist amorphous hydrophilic silver chloride gel designed to act as a barrier for wounds. It contains silver in the form of silver chloride as a self-preservative inhibiting microbial growth. This is stated to be substantially equivalent to the predicate device (Acryderm Silver Antimicrobial Wound Gel) in form and function. |
Biocompatibility | Safe for intended use (non-toxic, non-sensitizing, non-irritating). | Biocompatibility testing (systemic toxicity, cytotoxicity, sensitization and irritation) performed with IONSIL GEL™ demonstrates that the dressing is safe for its intended use. Testing was conducted according to ISO Standards. |
Antimicrobial Properties | Effectiveness against microorganisms (as a self-preservative). | In vitro antimicrobial testing was assessed by the standard Zone of Inhibition and USP Antimicrobial Effectiveness Test and USP microbial limit test . The results of these tests are not explicitly detailed as numerical values but are presented as evidence supporting the silver's self-preservative function and overall antimicrobial effectiveness. |
2. Sample Size Used for the Test Set and Data Provenance
The document does not specify a "test set" in the context of clinical performance data for the device. The data mentioned relates to laboratory (in vitro) testing for biocompatibility and antimicrobial properties.
- Biocompatibility Testing: The text states "Biocompatibility testing... was conducted according to ISO Standards." This implies a set of standardized samples (e.g., material extracts, cell cultures, animal models) as prescribed by the specific ISO standards, but no sample size for a "test set" is provided in the document.
- Antimicrobial Testing: "In vitro antimicrobial testing was assessed by the standard Zone of Inhibition and USP Antimicrobial Effectiveness Test and USP microbial limit test ." Again, the sample sizes for these in vitro tests (e.g., number of bacterial cultures, replicates) are not specified.
- Data Provenance: The studies are laboratory-based (in vitro), not involving human subjects or clinical data in the traditional sense. Therefore, country of origin of data (besides the submitting company's location in India) and retrospective/prospective categories are not applicable here.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications
This information is not applicable as the document describes laboratory (in vitro) studies for biocompatibility and antimicrobial efficacy, not a human reader or clinical performance evaluation requiring expert ground truth in the diagnostic sense. The "ground truth" for these tests would be the standardized results and observations of the laboratory assays themselves, interpreted by qualified lab personnel.
4. Adjudication Method for the Test Set
This information is not applicable for the same reasons as point 3. There is no human observer adjudication mentioned for these in vitro tests.
5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study Was Done
No, an MRMC comparative effectiveness study was not done. The document does not describe any human reader studies, either standalone or assisted by AI. The device is a wound hydrogel, not an AI-powered diagnostic tool.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) Was Done
No, a standalone algorithm performance study was not done. The device is a physical product (wound hydrogel), not a software algorithm.
7. The Type of Ground Truth Used
For the laboratory studies:
- Biocompatibility: The "ground truth" is established by the defined endpoints and criteria of the ISO standards used (e.g., cellular viability, irritation scores in validated models).
- Antimicrobial Properties: The "ground truth" reflects the measurable outcomes of the USP and tests and Zone of Inhibition assays, such as bacterial growth inhibition zones or reduction in microbial counts according to standardized methodologies.
8. The Sample Size for the Training Set
This information is not applicable. The device is not an AI/ML algorithm that requires a "training set" for its development.
9. How the Ground Truth for the Training Set Was Established
This information is not applicable for the same reasons as point 8.
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