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510(k) Data Aggregation
(157 days)
3M Tegaderm CHG Chlorhexidine Gluconate Gel Pad
The 3M™ Tegaderm™ CHG Chlorhexidine Gluconate Gel Pad can be used to cover and protect catheter sites. Common applications include covering intravascular catheters and percutaneous devices.
The 3M™ Tegaderm™ CHG Chlorhexidine Gluconate (CHG Gel Pad) is used to cover and protect vascular and non-vascular percutaneous medical devices. The CHG Gel Pad is breathable and transparent, allowing continuous site observation.
The CHG Gel Pad contains 2% w/w Chlorhexidine Gluconate (CHG), an antiseptic agent with broad spectrum antimicrobial and antifungal activity. The CHG Gel Pad absorbs fluid. In vitro testing (log reduction) demonstrates that the CHG Gel Pad has an antimicrobial effect against a variety of gram-positive and gram-negative bacteria, mold, and yeast.
This document is a 510(k) Pre-market Notification for a medical device called the "3M™ Tegaderm™ CHG Chlorhexidine Gluconate Gel Pad". It is a submission to the FDA seeking clearance to market the device, claiming substantial equivalence to a previously cleared predicate device.
Here's an analysis of the provided text in relation to your request:
Based on the provided text, the device is not an AI/ML device, therefore, much of the requested information (sample sizes for training/test sets, ground truth establishment for AI, MRMC studies, details on expert readers/adjudication) is not applicable. The device is a medical dressing with an antiseptic agent.
My analysis will focus on the information relevant to a non-AI medical device submission.
1. Table of Acceptance Criteria and Reported Device Performance
The submission does not explicitly list "acceptance criteria" in a quantitative manner as one might find for an AI algorithm's performance metrics (e.g., sensitivity, specificity thresholds). Instead, for this type of device, "acceptance criteria" are implied by successful completion of standard performance and biocompatibility tests, demonstrating that the device functions as intended and is safe. The "reported device performance" refers to the outcomes of these tests.
Test Description | Reported Device Performance / Outcome |
---|---|
In vitro Direct Time Kill | Demonstrates antimicrobial effect (log reduction) against a variety of gram-positive and gram-negative bacteria, mold, and yeast. |
Absorption | The CHG Gel Pad absorbs fluid. |
Moisture Vapor Transmission Rate | (Result not explicitly stated, but implies the test was performed and met expectations for breathability) |
Biocompatibility | Provided data from predicate device (K123679), concluding the device meets biocompatibility requirements. Categorized as a surface contacting device with breached/compromised skin contact of prolonged duration per ISO 10993-1 and FDA Guidance. |
Adherence (Subject device) | The subject standalone CHG Gel Pad does adhere. |
Securement (Subject device) | Not intended to provide securement. |
Transparency (Subject device) | Transparent, allowing continuous site observation. |
Breathability (Subject device) | Breathable. |
CHG Content (Subject device) | Contains 2% w/w Chlorhexidine Gluconate (CHG). |
2. Sample size used for the test set and the data provenance
- Test Set Sample Size: The document does not specify discrete "sample sizes" for the in vitro tests beyond stating that testing was performed. For in vitro laboratory tests, samples usually refer to a certain number of product units tested, which is not detailed here. Clinical data from human subjects is absent because this is a 510(k) submission based on substantial equivalence and non-clinical testing.
- Data Provenance: The in vitro tests were conducted internally by 3M Company, presumably in a laboratory setting. There is no mention of country of origin of the data in the context of clinical trials (as there are none) or whether the data is retrospective or prospective.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This question is not applicable as the device is not an AI/ML device relying on expert-labeled data for its performance evaluation. The "ground truth" for this device's performance is established by the direct measurement of physical and chemical properties in laboratory settings (e.g., direct measurement of CHG concentration, fluid absorption, bacterial kill rates).
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set
This question is not applicable for the same reasons as #3. Adjudication methods are typically used in clinical trials or for ground truth establishment in AI/ML performance evaluation involving human interpretation, which is not the case here.
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 question is not applicable as the device is not an AI/ML device. MRMC studies are used to evaluate diagnostic accuracy and the impact of AI assistance on human readers, which is entirely outside the scope of this medical dressing.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done
This question is not applicable as the device is not an AI/ML algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
For this device, the "ground truth" is derived from:
- Direct physical and chemical measurements: Examples include the measured concentration of Chlorhexidine Gluconate, measured fluid absorption capacity, and measured moisture vapor transmission rate.
- Microbiological assays: For the in vitro direct time kill studies, the "ground truth" refers to the confirmed reduction in microbial counts based on standardized microbiological testing protocols.
- Biocompatibility standards: Compliance with ISO 10993-1 and FDA Guidance based on established toxicological principles and testing.
8. The sample size for the training set
This question is not applicable as the device is not an AI/ML device and therefore does not have a "training set" in that context. The device's characteristics are inherent to its manufacturing and materials.
9. How the ground truth for the training set was established
This question is not applicable for the same reasons as #8.
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