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510(k) Data Aggregation

    K Number
    K171003
    Manufacturer
    Date Cleared
    2017-07-21

    (108 days)

    Product Code
    Regulation Number
    880.2800
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    3M Attest Rapid Readout Biological Indicator, 3M Attest Auto-reader

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

    Use the 3M™ Attest™ Rapid Readout Biological Indicator 1295 in conjunction with the 3M™ Attest™ Auto-reader 490H as a standard method of routine monitoring of vaporized hydrogen peroxide sterilization processes in the Amsco® V-PRO® maX Low Temperature Sterilization System (Lumen, Non Lumen, and Flexible cycles), and in STERRAD® 100S, STERRAD® NX® (Standard and Advanced cycles) and STERRAD® 100NX® (Standard, Flex, Express, and Duo cycles) systems.

    Device Description

    The 3M™ Attest™ Rapid Readout Biological Indicator 1295 is a self-contained biological indicator specifically designed for rapid and reliable routine monitoring of vaporized hydrogen peroxide sterilization processes when used in conjunction with the 3M™ Attest™ Auto-reader 490H. The 1295 BI is a single-use device composed of a polycarbonate sleeve containing a spore carrier and media ampoule, enclosed with a color-coded cap. A chemical process indicator printed with stripes which change from blue toward pink upon exposure to vaporized hydrogen peroxide is located on the top of the cap. The detection of fluorescence upon incubation of the 1295 BI in the 490H Auto-reader indicates a sterilization failure.

    AI/ML Overview

    The provided text describes the regulatory filing (510(k) submission K171003) for the 3M™ Attest™ Rapid Readout Biological Indicator 1295 and 3M™ Attest™ Auto-reader 490H. This document details the non-clinical performance evaluation of a device designed to monitor sterilization processes, not an AI/ML medical device for diagnosis or prognosis involving human expert review of medical images.

    Therefore, many of the requested points, such as "number of experts used to establish ground truth," "adjudication method," "MRMC comparative effectiveness study," and "training set details," are not applicable to this specific device and the provided documentation. The study described is a laboratory performance test of a biological indicator and an auto-reader, not a study evaluating human reader performance with or without AI assistance on medical images.

    However, I can extract the relevant information from the document to answer the applicable parts of your request:

    Device and Study Overview

    The device under review is the 3M™ Attest™ Rapid Readout Biological Indicator 1295, used in conjunction with the 3M™ Attest™ Auto-reader 490H. This submission addresses a software change to the Auto-reader to reduce the final fluorescent readout time from 4 hours to 24 minutes. The biological indicator itself (1295 BI) has the same design, materials, and fundamental scientific technology as the previously cleared device.

    The "study" in this context refers to non-clinical performance testing conducted to demonstrate that the device, with the reduced readout time, still functions effectively as a biological indicator for monitoring vaporized hydrogen peroxide sterilization processes.

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria are implied by the "Passed" results for each test. The actual quantitative acceptance thresholds are not explicitly listed in this summary, but the results confirm they were met.

    TestAcceptance Criteria (Implied)Reported Device Performance
    Positive ControlBiological indicator shows growth/fluorescence.Passed
    Survival Time ≤ 5 secondsBiological indicator shows growth/fluorescence.Passed (Survival Time = 5 seconds)
    Kill Time ≥ 7 minutesBiological indicator shows no growth/fluorescence.Passed (Kill Time = 7 minutes)
    Reduced Incubation Time: Alignment with 7-day conventional incubation time> 97% alignmentPassed (Meets FDA's requirements for Reduced Incubation Time with > 97% alignment)
    Final fluorescent readout time24 minutes24 minutes

    2. Sample Size Used for the Test Set and Data Provenance

    • Sample Size for Test Set: The document does not specify the exact number of biological indicators tested for each performance criterion (e.g., how many BIs were used to determine survival time or kill time, or for the reduced incubation time study). It only states "No clinical data was included in this premarket application submission," indicating the tests were non-clinical.
    • Data Provenance: The tests would have been conducted in a laboratory setting by 3M Company. The document does not specify the country of origin of the data, but 3M's contact address is St. Paul, Minnesota, USA. The studies are prospective in the sense that they were conducted specifically for this regulatory submission to demonstrate the performance with the new readout time.

    3. Number of Experts Used to Establish Ground Truth and Qualifications

    • Not Applicable. This is a non-clinical, in-vitro performance study of a biological indicator and auto-reader. Ground truth is established by the known conditions of the sterilization cycles (e.g., exposure time to sterilant) and the inherent biological response of the Geobacillus stearothermophilus spores. The "truth" is the presence or absence of viable spores after treatment, which is determined by the biological indicator's function, not by human expert interpretation of an outcome.

    4. Adjudication Method for the Test Set

    • Not Applicable. There is no human interpretation or subjective assessment that would require an adjudication method. The device's readout (fluorescence) is an objective, automated measurement.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was Done

    • No. This is a non-clinical performance study of a device, not a study evaluating human reader performance (with or without AI assistance).

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was Done

    • Yes, in essence. The testing described is a standalone performance evaluation of the integrated system (biological indicator + auto-reader algorithm) without human intervention in the interpretation of the results. The 490H Auto-reader automatically interprets the biological indicator and provides a fluorescent readout. The "algorithm" here is the system's ability to detect fluorescence within a specific incubation time.

    7. The Type of Ground Truth Used

    • Biological/Chemical Performance & Controlled Environmental Conditions: The ground truth for the "Passed" results is based on established scientific principles for biological indicators:
      • Viable spores (positive control): Known viability and growth in ideal conditions.
      • Survival Time: Exposure to a specific, short duration of sterilant where spores are expected to survive.
      • Kill Time: Exposure to a specific, longer duration of sterilant where all spores are expected to be killed.
      • Reduced Incubation Time Alignment: Comparison to the conventional, well-established 7-day incubation method, serving as a gold standard for biological indicator performance. The fluorescence indicates the presence (or absence) of enzyme activity from viable spores.

    8. The Sample Size for the Training Set

    • Not Applicable. This device does not use machine learning or AI models that require "training sets" in the conventional sense. The "training" of the device is its design and manufacturing to function according to biophysical principles, not an iterative data-driven process.

    9. How the Ground Truth for the Training Set Was Established

    • Not Applicable. (See point 8). The device's function is based on the biological activity of bacterial spores and their response to sterilization, which is a well-understood and established scientific principle in microbiology and sterilization.
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    K Number
    K140392
    Manufacturer
    Date Cleared
    2014-08-13

    (180 days)

    Product Code
    Regulation Number
    880.2800
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    3M ATTEST RAPID READOUT BIOLOGICAL INDICATOR / 3M ATTEST AUTO-READER

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

    Use the 3M Attest™ Rapid Readout Biological Indicator 1295 in conjunction with the 3M Attest™ Auto-reader 490H as a standard method of routine monitoring of vaporized hydrogen peroxide sterilization processes in STERRAD® NX and 100NX systems.

    Device Description

    The 3M Attest™ 1295 Rapid Readout Biological Indicator for Vaporized Hydrogen Peroxide Sterilization (pink cap, referred to hereinafter as the 1295 BI) is a self-contained biological indicator specifically designed for rapid and reliable routine monitoring of STERRAD® vaporized hydrogen peroxide sterilization processes when used in conjunction with the 3M Attest™ Auto-reader 490H (hereinafter referred to as the 490H Auto-reader). The 1295 BI is a single-use device.

    The Attest™ 1295 BI is composed of a polycarbonate sleeve containing a spore carrier and media ampoule, enclosed with a color-coded cap. A chemical process indicator printed with stripes which change from blue to pink upon exposure to vaporized hydrogen peroxide is located on the top of the cap.

    The 1295 BI utilizes the same fundamental technology that exists in current 3M Attest™ Rapid Readout and Super Rapid Readout BIs. All Attest™ Rapid Readout and Super Rapid Readout BIs for steam utilize the a-glucosidase enzyme system, which is generated naturally within growing Geobacillus stearothermophilus organisms. The a-glucosidase enzyme in its active state is detected by measuring the fluorescence produced by the enzymatic hydrolysis of a non-fluorescent substrate. The resultant fluorescent by-product is detected in the 3M Attest™ 490H Auto-reader. The detection of fluorescence upon incubation of the 1295 BI in the 490H Auto-reader indicates a sterilization failure.

    The 1295 BI is similar in design to the 3M Attest™ 1492V Super Rapid Readout Biological Indicator for Steam cleared as K121484 for dynamic-air-removal (prevacuum) steam sterilization cycles. Minor modifications were made to 1492V that resulted in the 1295 BI for STERRAD® vaporized hydrogen peroxide sterilization cycles.

    The Attest™ Auto-reader 490H is similar in design to the Attest™ Auto-reader 490 that has been cleared for use with the Attest™ 1491 Super Rapid Readout Biological Indicator under K103277 and Attest™ 1492V Super Rapid Readout Biological Indicator under K121484.

    The Attest™ Auto-reader 490H is designed to incubate at 60°C and automatically read the Attest™ 1295 BI for a fluorescent result within 4 hours. The fluorescent readout at 4 hours met the FDA's requirement of > 97% alignment with the result after the conventional incubation time of 7 days. The Auto-reader 490H is also designed to allow further incubation of the 1295 BI for an optional visual pH color change result of the growth media at 7 days.

    AI/ML Overview

    The provided document describes the 3M Attest™ Rapid Readout Biological Indicator 1295 (BI) and 3M Attest™ Auto-reader 490H. The primary study presented is a substantial equivalence comparison to predicate devices, rather than a direct study demonstrating absolute performance against highly specific, quantitative acceptance criteria for all aspects of a typical diagnostic device. However, some performance characteristics are outlined, particularly in comparison to the predicate.

    Here's an analysis based on the document:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document doesn't explicitly state "acceptance criteria" for the new device as a set of a priori thresholds. Instead, it demonstrates substantial equivalence by comparing its characteristics and performance to legally marketed predicate devices, and against the FDA's Guidance for Industry and FDA Staff, Biological Indicator (BI) Premarket Notification [510(k)] Submissions.

    The table below summarizes the key performance characteristics mentioned for the Attest™ 1295 BI compared to its "Intended Use Predicate," the STERRAD® CycleSure® 24 BI (K123017).

    CharacteristicAcceptance Criteria (Predicate Performance / Guidance)Reported Device Performance (Attest™ 1295 BI)
    Intended UseMonitoring vaporized hydrogen peroxide sterilization processes (e.g., STERRAD® NX, 100NX).Same as predicate.
    Organism (Species, Strain)Geobacillus stearothermophilus traceable to ATCC™ 7953.Same as predicate.
    Viable Spore Population≥ 10^6^Same as predicate.
    D-value (Resistance)D_2.5 mg/L_ ≥ 1 second (for predicate at 2.5 mg/L H2O2)D_10 mg/L_ ≥ 1 second (at 10 mg/L H2O2).
    Survival Time≥ 5 seconds≥ 5 seconds
    Kill Time= 60 seconds (for predicate at 2.5 mg/L H2O2)= 7 minutes (at 10 mg/L H2O2) - Note: Much longer due to higher challenge.
    Reduced Incubation Time (Fluorescent Result)>97% correlation to 7-day visual pH color change (for predicate: 24 hours visual pH).Fluorescent result in 4 hours (>97% correlation to 7-day visual pH color change not explicitly stated for 1295, but inferred by meeting FDA guidance).
    Chemical Process IndicatorChanges from red to golden yellow or bronze.Changes from blue to pink.
    Incubation Temperature55-60°C60 +/- 2 °C
    Shelf-life6 months6 months (with plans for extension).

    Note for Auto-reader 490H: The document states the fluorescent readout at 4 hours met the FDA's requirement of > 97% alignment with the result after the conventional incubation time of 7 days. This is a key "acceptance criterion" for the rapid readout functionality, implying the accuracy of the 4-hour fluorescent result vs. the traditional 7-day visual result.

    2. Sample Size Used for the Test Set and Data Provenance

    • Test Set Sample Size: The document states, "Multiple lots of Attest™ 1295 BIs were evaluated for performance." However, it does not provide a specific number or breakdown of the sample size (e.g., number of BIs, number of sterilization cycles, replicates) used for the resistance testing or reduced incubation time validation.
    • Data Provenance: Not explicitly stated. Given it's a 510(k) submission, the studies would likely be conducted in a controlled laboratory setting (e.g., 3M's R&D facilities) in the country of origin of the manufacturer (USA, St. Paul, MN). The data would be prospective as it involves controlled testing of the new device's performance against defined parameters.

    3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of Experts

    • This type of device (biological indicator) relies on a biological process (spore inactivation) and a chemical reaction for ground truth, rather than expert review of images or clinical assessments.
    • Ground Truth Establishment: The ground truth for the BI performance studies is based on established microbiological methods for assessing spore viability (e.g., lack of growth after incubation for positive control, confirmed kill for negative control) and comparison to the predicate device's known performance characteristics. No human "experts" in the sense of clinicians or radiologists are involved in establishing the ground truth for this device's function.

    4. Adjudication Method

    • Not applicable in the conventional sense. The "ground truth" for a biological indicator is determined by the growth or non-growth of spores, and the optical detection of fluorescence by the auto-reader. This is a direct, objective measurement, not subject to human interpretation or adjudication in the study itself.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    • No, an MRMC comparative effectiveness study was not done. This type of study is relevant for diagnostic devices where human reader performance is being evaluated, often with or without AI assistance. The 3M Attest system is a standalone biological sterilization indicator and auto-reader, not a diagnostic device involving human interpretation of complex medical cases.

    6. Standalone Performance Study

    • Yes, a standalone performance evaluation of the algorithm (or device's intrinsic function) was performed.
      • The "Reduced Incubation Time" validation demonstrates standalone performance, showing the 4-hour fluorescent readout reliably predicts the 7-day visual pH color change. This is the core "algorithm" of the rapid readout auto-reader.
      • The resistance characteristics (D-value, Survival/Kill Time) are also standalone performance metrics for the BI itself.
      • The comparison to the predicate device is also a form of standalone evaluation against a known standard.

    7. Type of Ground Truth Used

    • The ground truth used for performance evaluation is microbiological growth/non-growth of spores (indicating sterilization efficacy), and chemical pH change in growth media (for the traditional 7-day visual result).
    • For the rapid readout function, the fluorescent signal's correlation to the 7-day visual pH change is the key ground truth.

    8. Sample Size for the Training Set

    • The document does not explicitly mention a training set in the context of an AI/ML algorithm development. This device uses a physiological detection mechanism (enzyme activity leading to fluorescence) rather than a machine learning model that would typically require a training set. The "development of a test cycle" and "evaluating multiple lots" suggests R&D and validation efforts, but not a distinct training set for an AI model.

    9. How the Ground Truth for the Training Set was Established

    • Not applicable, as a conventional AI/ML training set is not described or implied for this device. The development process would involve standard microbiology and engineering principles to ensure the BI and auto-reader accurately detect spore viability and fluorescence, respectively.
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