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510(k) Data Aggregation
(198 days)
The 3M™ Attest™ Steam Chemical Integrators are designed to all critical parameters over a specified range of steam sterilization cycles. The integrating intended to be placed in each pack, pouch, container, tray or other containment device to function as an independent monitor of critical parameters for the following sterilization cycles:
| Cycle Type | Temperature | Exposure Time |
|---|---|---|
| Gravity | 250°F/121°C | 30 minutes |
| Gravity | 270°F/132°C | 3, 4, 10, 15, 25 minutes |
| Gravity | 275°F/135°C | 3, 10 minutes |
| Dynamic Air Removal | 250°F/121°C | 30 minutes |
| Dynamic Air Removal | 270°F/132°C | 4, 10 minutes |
| Dynamic Air Removal | 273°F/134°C | 3, 4 minutes |
| Dynamic Air Removal | 275°F/135°C | 3 minutes |
Minimum Stated Values for 3M™ Attest™ Steam Chemical Integrators as determined in a resistometer: 250°F / 121°C: 16.5 minutes 270°F/ 132°C: 2.0 minutes 273°F/ 134°C: 1.4 minutes 275°F/ 135°C: 1.2 minutes
3M™ Attest™ Steam Chemical Integrators are chemical indicators consisting of a paper wick and a steam and temperature sensitive chemical pellet contained in a paper/film/foil laminate. The chemical pellet melts and migrates as a dark color along the paper wick. The migration is visible through a window marked ACCEPT or window marked REJECT; the extent of migration depends on steam, time, and temperature.
The provided text describes the acceptance criteria and study proving the device meets those criteria, specifically for the 3M™ Attest™ Steam Chemical Integrators (K191236).
Here's the breakdown of the information requested:
1. A table of acceptance criteria and the reported device performance
| Test Name | Purpose | Acceptance Criteria | Reported Device Performance/Results |
|---|---|---|---|
| Stated Value (SV) Testing | To identify the critical parameters required to achieve a stated inactivation, by referring to a stated test organism with stated D and z values. The integrator must turn to "ACCEPT" endpoint at the stated value time and must also remain "REJECT" when exposed to conditions of -1°C/-15% set point of the SV time. All testing is completed in a saturated steam resistometer. Integrator temperature coefficient and correlation coefficient are calculated to confirm alignment to biological indicator performance. | SV at 121°C ≥ 16.5 minutesSV at 132°C ≥ 2.0 minutesSV at 134°C ≥ 1.4 minutesSV at 135°C ≥ 1.2 minutesIntegrator temperature coefficient 10 - 27°CCorrelation coefficient ≥ 0.9 | PASS |
| Health Care Facility Simulated Use Testing | Confirm integrators provide acceptable performance in cleared customer use sterilization cycles. | Device reaches "ACCEPT" endpoint reaction when exposed to customer use cycles.Device does not reach endpoint ("REJECT") when exposed to failing conditions in customer use cycles. | PASS |
| Dry Heat Testing | Verify device requires the presence of saturated steam to turn to reach endpoint. | Endpoint must not be met following dry heat exposure at 140°C for 30 min. | PASS |
| Side-by-Side Testing with Biological Indicator | Confirm integrators are parallel in performance to biological indicators (BI). | Chemical integrator parallels performance of BI and does not reach endpoint before BI is inactivated. | PASS |
| Endpoint Color Stability | Confirm endpoint color stability for samples exposed to passing and failing conditions in a steam resistometer. | Endpoint decision must remain unchanged after 6 months. | PASS |
2. Sample size used for the test set and the data provenance
The document does not specify the exact sample sizes (number of integrators) used for each test. However, it indicates that the testing was conducted in accordance with "FDA Guidance for Industry and FDA Staff: Premarket Notification [510(k)] Submissions for Chemical Indicators, issued December 19, 2003 as well as ANSI/AAM/ISO 11140-1:2014." These standards would define the appropriate sample sizes for such tests.
The data provenance is not explicitly stated in terms of country of origin or whether it was retrospective or prospective. However, given that this is a 510(k) submission to the US FDA, it can be inferred that the studies were conducted by or on behalf of 3M Company, located in St. Paul, Minnesota, USA. The nature of the tests ("Nonclinical testing") suggests prospective laboratory-based studies rather than retrospective clinical data.
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 and therefore not provided in the document. The device is a chemical indicator for sterilization processes. Its "ground truth" (i.e., whether sterilization conditions were met or not, or if it indicates "ACCEPT" or "REJECT") is determined by objective physical and chemical reactions under controlled laboratory conditions using resistometers and simulated use cycles, not by expert human interpretation like in medical imaging. The performance is assessed against established physical parameters and the performance of biological indicators, not human expert consensus.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. As explained in point 3, the output of the chemical indicator is an objective visual change (migration of a dark color to an ACCEPT or REJECT window). There is no human interpretation or adjudication process described for determining the device's output.
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 passive chemical indicator, not an AI-assisted diagnostic tool that would involve human readers. Therefore, an MRMC study and AI assistance are irrelevant to its evaluation.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This refers to the core performance of the device itself. The "Nonclinical Testing" summarized in the document is essentially the standalone performance evaluation of the chemical indicator. The device (chemical indicator) intrinsically operates "standalone" as a physical/chemical system without human intervention or an algorithm in the traditional sense of medical devices. Its performance is directly observed and measured against physical parameters of sterilization cycles.
7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)
The "ground truth" for the performance of the 3M™ Attest™ Steam Chemical Integrators is established through:
- Physical Parameters: Measured steam temperature and exposure time in controlled resistometers.
- Biological Indicator Inactivation: The performance is correlated and compared to biological indicators (BIs), which contain resistant bacterial spores, serving as a gold standard for sterilization effectiveness. The acceptance criteria state "Chemical integrator parallels performance of BI and does not reach endpoint before BI is inactivated."
- Defined Pass/Fail Conditions: Precise conditions (e.g., minimum stated values, exposure to failing conditions) are set for evaluation.
8. The sample size for the training set
Not applicable. This device is a chemical indicator, not a machine learning or AI algorithm. Therefore, there is no "training set" in the context of data-driven model development. The device's performance is based on its inherent chemical and physical properties and manufacturing consistency, not on learned data.
9. How the ground truth for the training set was established
Not applicable, as there is no training set for this device type.
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