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510(k) Data Aggregation

    K Number
    K190129
    Device Name
    AC5 Topical Gel
    Date Cleared
    2020-03-11

    (408 days)

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

    AC5 Topical Gel

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

    Under the supervision of a health care professional, AC5 Topical dressing used for the management of partial and full- thickness wounds, such as pressure sores, leg ulcers, and surgical wounds.

    Device Description

    AC5 Topical Gel is configured as a package containing one vial of synthetic self-assembling peptide, one vial of diluent (Sterile Water for Injection, USP), one syringe, one needle, two blunt fill needle applicators and two Alcohol Prep pads. AC5 is biocompatible. The diluent (Sterile Water for Injection, USP) is sterile and non-pyrogenic. AC5 is to be prepared by reconstitution of the lyophilized peptide in Sterile Water for Injection, USP. The reconstituted peptide solution is acidic (pH 2.3 ± 0.7).

    AI/ML Overview

    The provided document is a 510(k) Pre-Market Notification from the FDA regarding the AC5 Topical Gel. It confirms the substantial equivalence of the device to a predicate device and provides information on its intended use, composition, and some performance testing related to biocompatibility.

    However, the document does not contain information about the acceptance criteria or a specific study that proves the device meets those acceptance criteria in the context of device performance metrics like sensitivity, specificity, accuracy, or any comparative effectiveness studies as typically found in an AI/ML device submission. The performance section (11.6) discusses biocompatibility testing, which is a different type of performance evaluation.

    Therefore, I cannot provide a detailed answer to your request regarding acceptance criteria and performance study data as these details are not present in the provided text.

    Based on the provided text, I can extract information related to biocompatibility testing, but not the specific type of performance study you are asking for (e.g., an MRMC study or standalone algorithm performance).

    Here's what can be inferred from the document regarding "performance" though it pertains to biocompatibility, not clinical efficacy or AI performance:

    • Acceptance Criteria (for Biocompatibility): The implicit acceptance criterion for biocompatibility was that AC5 Topical Gel passed all tests conducted in accordance with the specified guidelines.
    • Study Proving Acceptance Criteria (for Biocompatibility): The document states:
      • Types of tests conducted: Cytotoxicity, sensitization, irritation (animal irritation with abraded skin and animal intracutaneous reactivity), acute systemic toxicity, pyrogenicity (endotoxin and material mediated), implantation, and subchronic/subacute toxicity.
      • Standards followed: Guidance for Industry and Food and Drug Administration Staff, issued on June 16, 2016, entitled "Use of International Standard ISO-10993, Biological evaluation of medical devices Part 1 Evaluation and testing within a risk management process."
      • Regulatory compliance: Conducted in full accordance with the FDA's Good Laboratory Practice regulations (21 CFR Part 58).

    Missing Information:

    The document does not provide any of the following details critical to your request:

    1. A table of acceptance criteria and reported device performance (for clinical or AI performance).
    2. Sample size used for a test set (clinical or AI).
    3. Data provenance (country of origin, retrospective/prospective for clinical or AI data).
    4. Number of experts used to establish ground truth or their qualifications (for clinical or AI data).
    5. Adjudication method (for clinical or AI data).
    6. If a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was done, or its effect size.
    7. If a standalone (algorithm only) performance study was done.
    8. The type of ground truth used (expert consensus, pathology, outcomes data, etc.) for clinical or AI performance.
    9. The sample size for the training set (for AI).
    10. How the ground truth for the training set was established (for AI).

    This document is a 510(k) clearance letter and summary for a topical gel, which is a traditional medical device, not an AI/ML-driven device. Therefore, the performance evaluation focuses on material safety (biocompatibility) and equivalence to a predicate device based on material composition and mechanism of action, rather than clinical efficacy metrics or AI algorithm performance.

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    K Number
    K182681
    Device Name
    AC5 Topical Gel
    Date Cleared
    2018-12-14

    (79 days)

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

    AC5 Topical Gel

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

    Under the supervision of a health care professional, AC5 Topical dressing used for the management of partial and full-thickness wounds, such as pressure sores, diabetic ulcers, and surgical wounds.

    Device Description

    AC5 Topical Gel is configured as a kit containing one vial of synthetic self-assembling peptide, one vial of diluent (Sterile Water for Injection, USP), one syringe, one needle, two blunt fill needle applicators and two Alcohol Prep pads. AC5 is biocompatible. The diluent (Sterile Water for Injection, USP) is sterile and non-pyrogenic. AC5 is to be prepared by reconstitution of the lyophilized peptide in Sterile Water for Injection, USP. The reconstituted peptide solution is acidic (pH 2.3 ± 0.7).

    AI/ML Overview

    This is a 510(k) summary for AC5 Topical Gel, which is a wound dressing. The document describes the device, its intended use, and claims substantial equivalence to predicate devices (PuraDermTM Gel and DuoDERM® Hydroactive Gel).

    The 510(k) summary does not contain the specific acceptance criteria or a detailed study report that proves the device meets specific acceptance criteria in a quantitative manner as would typically be presented for a device reliant on algorithmic performance. Instead, the performance evaluation for this topical gel focuses on biocompatibility and non-clinical performance (in vivo and bench-top studies).

    Here's an analysis of the provided text based on your request, keeping in mind that the nature of this submission (a topical gel, not an AI/algorithm-driven device) means some of your requested points are not directly applicable or are interpreted differently.

    1. A table of acceptance criteria and the reported device performance

    Since this is not an AI/algorithmic device, there are no specific numerical acceptance criteria like sensitivity, specificity, or AUC. The "acceptance criteria" for this type of device revolve around safety and demonstrating comparable performance to predicate devices.

    Acceptance Criteria (Implied)Reported Device Performance
    Biocompatibility (Safety)AC5 passed all recommended biocompatibility tests from ISO-10993, including cytotoxicity, sensitization, acute systemic toxicity, pyrogenicity (endotoxin and material mediated), implantation, and subchronic/subacute toxicity.
    Non-Irritating & Non-Sensitizing in HumansIn the Human Repeat Insult Patch Testing (HRIPT), AC5 was found to be non-irritating and non-sensitizing.
    Wound Hydration Performance (Effectiveness - Comparative)The performance of AC5 Topical Gel for hydration of wounds was found equivalent to that of DuoDERM Hydroactive Gel in a bench-top study. This is a key comparative effectiveness claim for this type of device.
    Similar Indications for UseAC5 Topical Gel's indications for use (management of partial and full-thickness wounds: pressure sores, leg ulcers, diabetic ulcers, surgical wounds) are substantially equivalent to the predicate devices.
    Similar Safety ProfileRisks addressed through materials, processing controls, quality assurance, and compliance with GMP.

    2. Sample size used for the test set and the data provenance

    • Biocompatibility tests: These tests are typically conducted on standardized laboratory models (in vitro and animal models). The document doesn't specify the exact "sample size" in terms of number of animals or repeat tests but mentions it was done "in full accordance with the Food and Drug Administration's Good Laboratory Practice regulations."
    • Human Repeat Insult Patch Testing (HRIPT): This is a human clinical study. The sample size is not specified in this document, nor is the country of origin. HRIPTs are typically prospective studies.
    • Porcine Excisional Wound Model: This is an animal study. The sample size (number of pigs, number of wounds) is not specified. This is a prospective animal study.
    • Bench-top study (Wound Hydration): This is an in vitro study. The sample size (e.g., number of test samples, replicates) is not specified.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    This is not applicable for this type of device. There is no "ground truth" established by experts in the context of image interpretation or diagnostic accuracy for this topical gel. The evaluations are based on direct biological and physical measurements and observations in laboratory, animal, and human patch tests.

    4. Adjudication method for the test set

    Not applicable for this type of device. Adjudication methods like 2+1 or 3+1 are used for expert consensus in cases like radiological image reading or clinical event classification, which don't apply to the performance studies of a topical gel.

    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 is not an AI device, and no human "readers" or AI assistance studies were conducted. The comparative effectiveness stated is about the wound hydration performance of the gel itself versus a predicate gel, not about clinician performance with or without the device.

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

    Not applicable. This is a topical medical device, not an algorithm.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    The "ground truth" in the context of this device's performance studies relies on:

    • Standardized endpoints for biocompatibility: Measured biological reactions (e.g., cell viability for cytotoxicity, skin reaction for sensitization, pyrogen levels).
    • Observed outcomes in animal models: Healing progression in the porcine excisional wound model.
    • Direct physical/chemical measurements in bench-top studies: Measurement of hydration properties.
    • Clinical observations in human patch tests: Skin reactions (irritation, sensitization) assessed by trained professionals.

    8. The sample size for the training set

    Not applicable. This is not a machine learning/AI device, so there is no training set in that sense.

    9. How the ground truth for the training set was established

    Not applicable, as there is no training set for an algorithm.

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