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510(k) Data Aggregation

    K Number
    K230730
    Device Name
    Apyx
    Manufacturer
    Date Cleared
    2023-07-25

    (131 days)

    Product Code
    Regulation Number
    884.4530
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Apyx is intended for attaching sutures to ligaments of the pelvic floor.

    Device Description

    The Apyx device is indicated for anchoring sutures to ligaments of the pelvic floor. The device consists of an implantable nitinol anchor with 4 prongs configured with either non-absorbable or resorbable suture. The anchor-suture assembly is contained within a cartridge, wherein the anchor / suture assembly is deployed to the target site from the cartridge with an applicator. An optional use retriever may be used to remove the anchor in the event of sub-optimal placement of an Anchor during the index procedure. The Apyx also includes an optional securement element which may be used as a suture retention device to distribute suture tension over a larger tissue area and aid in wound healing.

    The Apyx device is a single use device which is supplied sterile.

    AI/ML Overview

    The provided text does not contain detailed acceptance criteria or a study proving the device meets those criteria in the typical format of a clinical or performance study with specific metrics like sensitivity, specificity, or AUC, as these would be associated with diagnostic or AI-powered devices.

    However, based on the information provided, here's a breakdown of what can be extracted regarding performance and testing:

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

    The document mentions various tests conducted, generally implying that the device met the requirements of these tests to demonstrate safety and effectiveness. Since specific numerical acceptance criteria (e.g., "pull-out strength > X N") and the exact reported performance values are not explicitly stated, I will infer the acceptance as "Met requirements" based on the conclusion of substantial equivalence.

    Acceptance Criterion (Implied)Reported Device Performance
    BiocompatibilityMet requirements (ISO 10993 compliant)
    Chemical Characterization and Toxicological Risk AssessmentMet requirements (ISO 10993-18 compliant)
    Corrosion ResistanceMet requirements
    Packaging ValidationMet requirements
    Shelf-Life ValidationMet requirements
    Securement Element Pull-OutMet requirements
    Cadaver Model Testing (Delivery)All anchors accurately delivered into target ligament; no complications or unanticipated risks observed. Successfully performed.
    Cadaver Model Testing (Retrieval)Successfully performed. Successfully removed.
    Cadaver Model Testing (Securement)All anchors secured using the securement element and properly fixed at the desired position with ease.

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

    • Sample size for test set: The "Cadaver Testing" section does not specify the number of cadavers or the number of anchors tested. It uses general phrasing like "users," "all anchor delivery and retrieval procedures," and "All anchors."
    • Data provenance: Not explicitly stated, but cadaver testing implies a controlled laboratory environment. The country of origin of the data is not mentioned. It is prospective testing carried out for regulatory submission.

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

    • This information is not provided. The cadaver testing describes the actions of "users" (implying medical professionals) who delivered and retrieved anchors, but doesn't mention independent expert assessment or ground truth establishment in a formalized way for outcomes like accuracy or safety observed during the testing. The "ground truth" here is the observed outcome of the procedure itself (e.g., successful placement, no damage).

    4. Adjudication method for the test set

    • Not applicable/Not described. The cadaver testing describes qualitative observations of successful delivery, retrieval, and proper fixation. There's no mention of an adjudication process for resolving disagreements between multiple observers, as might be seen in diagnostic studies.

    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

    • No. This device is a surgical instrument (fixation device), not an imaging or AI-assisted diagnostic tool. Therefore, an MRMC study and AI-related effectiveness are not relevant or discussed.

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

    • No. This device is a manual instrument for surgical use, not an algorithm.

    7. The type of ground truth used

    • For the cadaver testing, the ground truth was the direct observation of the physical outcome and success of the procedure (e.g., "anchors were accurately delivered," "no damage observed," "properly fixed"). This is akin to direct experimental observation and physical verification rather than consensus, pathology, or outcomes data in a clinical trial.

    8. The sample size for the training set

    • Not applicable. This device is a physical medical instrument, not a machine learning algorithm, so there is no "training set."

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

    • Not applicable, as there is no training set for a physical medical instrument.
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    K Number
    K221830
    Device Name
    Apyx One Console
    Date Cleared
    2022-10-11

    (110 days)

    Product Code
    Regulation Number
    878.4400
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Apyx One Console is indicated for delivery of radiofrequency energy and/or helium plasma to cut, coagulate and ablate soft tissue during open and laparoscopic surgical procedures. The helium plasma portion of the generator can be used only with dedicated Renuvion/J-Plasma handpieces.

    Device Description

    The Apyx One Console is an electrosurgical generator that delivers radiofrequency (RF) energy to cut and coagulate soft tissue. It can also deliver Helium plasma energy for cutting, coagulation, and ablation of soft tissue. Like the predicate, the Apyx One Console provides standard electrosurgical energy and Helium Plasma energy, with no changes to the intended use, electrosurgical modes, output power waveforms, or maximum power settings. The Apyx One Console is a modified version of the primary predicate device that was cleared under K192867 (Apyx Helium Plasma Generator), with a no change to the intended use.

    The Apyx One Console has a Graphical User Interface (GUI). Remote Services will be available using an attached cellular module to assist in troubleshooting the generator in the field, a helium Gas Pressure Transmitter, and two monopolar ports.

    The Remote Service module will also provide non-HIPPA data to a cloud data system which will log the various settings of the generator throughout its use.

    AI/ML Overview

    The Apyx One Console is an electrosurgical generator intended for the delivery of radiofrequency energy and/or helium plasma to cut, coagulate, and ablate soft tissue during open and laparoscopic surgical procedures. The helium plasma portion of the generator can only be used with dedicated Renuvion/J-Plasma handpieces.

    Here's a breakdown of the acceptance criteria and the study proving the device meets them:

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

    Acceptance Criteria (Standards Met)Reported Device Performance (Results)
    Electrical Safety Standards:
    ANSI/AAMI/IEC ES60601-1:2005/(R2012)+A1:2012 (General requirements for basic safety and essential performance)The electrical functionality of the generator was verified to meet performance specification requirements.
    AAMI/ANSI/IEC 60601-1-2:2014 (4th Edition) (Electromagnetic disturbances - Requirements and tests)Complies with the standard.
    AAMI/ANSI/IEC-60601-2-2:2017 (6th Edition) (Particular requirements for the basic safety and essential performance of high-frequency surgical equipment and accessories)Complies with the standard.
    Usability Standard:
    IEC 62366-1:2015+AMD1:2020 (Application of usability engineering to medical devices)
    Software/Firmware Performance:
    Field Programmable Gate Array (FPGA) Procedure and Logic Design ValidationThe results demonstrated that the system and FPGA perform as intended and according to the product specifications.
    Mechanical Performance:
    Mechanical Product and Performance Specification RequirementsThe results verified that the mechanical design meets the product and performance requirements.

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

    The document does not specify a separate "test set" in the context of clinical data for performance evaluation. Instead, the performance testing described focuses on engineering verification and validation. Therefore, information regarding sample size and data provenance for a test set (e.g., patient data) is not applicable here as it is not a clinical study in that sense.

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

    Not applicable. This evaluation focuses on engineering performance rather than clinical endpoints requiring expert ground truth establishment.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    Not applicable. This was not a study requiring adjudication of interpretations.

    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. The device is an electrosurgical generator, not an AI-powered diagnostic tool, so an MRMC study comparing human readers with and without AI assistance is not relevant.

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

    Not applicable. The device is a physical medical instrument, not an algorithm, so the concept of "standalone algorithm performance" is not relevant. The performance evaluation focuses on the engineering safety and effectiveness of the hardware and software in its intended operational context.

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

    The "ground truth" for this device's acceptance criteria primarily involved:

    • Compliance with established international electrical safety, electromagnetic compatibility, and usability standards.
    • Verification against product and performance specifications for electrical functionality, software/firmware operation, and mechanical design.

    8. The sample size for the training set

    Not applicable. This device, being an electrosurgical generator, does not utilize a "training set" in the context of machine learning.

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

    Not applicable, as there is no training set for this type of medical device evaluation.

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    K Number
    K213783
    Device Name
    Apyx
    Manufacturer
    Date Cleared
    2022-04-05

    (123 days)

    Product Code
    Regulation Number
    884.4530
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Apyx is intended for attaching sutures to ligaments of the pelvic floor.

    Device Description

    The Apyx device is indicated for anchoring sutures to ligaments of the pelvic floor. The device consists of an implantable nitinol anchor with 4 prongs configured with either non-absorbable or resorbable suture. The anchor-suture assembly is contained within a cartridge, wherein the anchor/suture assembly is deployed to the target site from the cartridge with an applicator. An optional retriever can be used to remove the anchor in the event of sub-optimal placement of an Anchor during the index procedure. The Apyx device is a single use device which is supplied sterile.

    AI/ML Overview

    The provided text describes a 510(k) submission for the Apyx device, which is intended for attaching sutures to ligaments of the pelvic floor. The submission claims substantial equivalence to the predicate device, POP Medical Solutions, NeuGuide (K160569). However, the document does not contain a table of acceptance criteria and reported device performance or information about a specific study proving the device meets acceptance criteria related to efficacy metrics for an AI/ML algorithm.

    The information provided is primarily related to the mechanical and biocompatibility testing of the Apyx device as a medical instrument, not an AI/ML system. Therefore, I cannot fulfill the request for information on acceptance criteria and a study proving an AI/ML device meets them, as those details are not present in the provided text.

    Based on the available text, I can only extract general performance data categories and a cadaver study description for the mechanical device as follows:


    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not provide a table of acceptance criteria with specific numerical targets for performance metrics (e.g., sensitivity, specificity, accuracy) for an AI/ML device. It lists general performance data categories for the Apyx medical device (a mechanical fixation device), along with a summary of cadaver testing.

    Performance Data Category (for Apyx Mechanical Device)Reported Device Performance
    Biocompatibility testing (ISO 10993)Consistent with intended duration of contact for Cytotoxicity, Sensitization, Pyrogenicity, Irritation, Intracutaneous reactivity.
    Chemical characterization & toxicological risk assessment (ISO 10993-18)Addresses biocompatibility endpoints of Genotoxicity, Acute systemic toxicity, Chronic systemic toxicity, Carcinogenicity, Developmental/reproductive toxicity.
    Sterilization validation (ISO 11135)Performed.
    Packaging validationPerformed.
    Shelf-life validationPerformed.
    Dimensional verificationPerformed.
    Anchor fracture resistancePerformed.
    Anchor fixation pull outPerformed.
    Suture detachmentPerformed.
    Suture tensile strengthPerformed.
    MRI compatibilityPerformed.
    Corrosion resistance (ASTM F2129)Performed.
    Bond strengthPerformed.
    Cadaver TestingUsers successfully delivered and retrieved anchors through a transvaginal approach. No complications or unanticipated risks. All anchors accurately delivered to target ligament, no damage to surrounding structures. Concluded device meets design requirements and is suitable for intended use.

    The subsequent questions (2-9) are specifically tailored to the evaluation of an AI/ML-based medical device. Since the provided document describes a mechanical medical instrument (Apyx) and not an AI/ML product, these questions are not applicable to the information given. The text does not mention any AI/ML components, software algorithms, or their performance evaluation. Therefore, I cannot answer questions 2 through 9 based on the provided input.

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    K Number
    K192867
    Date Cleared
    2019-10-31

    (24 days)

    Product Code
    Regulation Number
    878.4400
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Apyx Helium Plasma Generators (owned by Apyx Medical) are indicated for delivery of radiofrequency energy and/ or helium plasma to cut, coagulate and ablate soft tissue during open and laparoscopic surgical procedures. The helium plasma portion of the generator can be used only with dedicated Renuvion/ J-Plasma handpieces.

    Device Description

    The Apyx Helium Plasma Generator is an electrosurqical device that delivers radiofrequency (RF) energy to cut and coaqulate soft tissue. It can also deliver Helium plasma energy for cutting, coagulation, and ablation of soft tissue. Like the predicate, the Apyx Helium Plasma Generator provides standard electrosurgical energy and Helium Plasma energy, and there are no changes to the intended use, performance specifications, electrosurgical modes, output power waveforms or maximum power settings. Essentially, the Apyx Helium Plasma Generator is a combination of a standard electrosurgical generator and a Helium Plasma generator.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and the study that proves the device meets them, based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Objective)Reported Device Performance (Result)
    Electrical SafetyComplies with: - ANSI/AAMI/IEC ES60601-1:2005/(R)2012 and A1:2012 (Medical Electrical Equipment - Part 1: General requirements for basic safety and essential performance) - AAMI/ANSI/IEC 60601-1-2:2014 (4th Edition) (Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances - Requirements and tests) - AAMI/ANSI/IEC-60601-2-2:2017 (Medical electrical equipment - Part 2-2: Particular requirements of basic safety and essential performance of high-frequency surgical equipment)
    Electromagnetic Compatibility (EMC)Complies with: - AAMI/ANSI/IEC 60601-1-2:2014 (4th Edition) (Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances - Requirements and tests) - IEC60601-1-2 (electromagnetic compatibility)
    Electrical PerformanceThe electrical functionality of the generator was verified to meet performance specification requirements.
    Software FunctionalityThe system and Field Programmable Gate Array (FPGA) perform as intended and according to the product specifications.
    Mechanical DesignThe mechanical design meets the product and performance requirements.

    Summary of the Study:

    The provided document describes a 510(k) premarket notification for the Apyx Helium Plasma Generator. This notification seeks to demonstrate substantial equivalence to a previously cleared predicate device (K170188, Bovie Ultimate® Gen 2 Electrosurgical Generator). The study involved bench and software verification and validation testing to confirm the modified device's safety and effectiveness.

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

    The document does not specify a numerical sample size for the test set. The tests describe "Electrical Verification," "Software Verification & Validation," and "Mechanical Verification," which are typically performed on a limited number of manufactured units or system components, rather than a large clinical "test set" in the sense of patient data.

    The data provenance is retrospective, as the study primarily compares the modified device to a previously cleared predicate and leverages existing regulatory standards. The testing itself would have been conducted in a controlled laboratory or engineering environment, rather than using patient data from a specific country of origin.

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

    This information is not provided in the document. The type of testing described (electrical, software, mechanical verification) typically relies on engineering and regulatory standards rather than expert clinical consensus to establish "ground truth" for the device's functional and safety characteristics.

    4. Adjudication Method for the Test Set

    This information is not applicable/not provided for the type of testing described. Adjudication methods like 2+1 or 3+1 are typically used in clinical studies where expert consensus is needed to establish ground truth for diagnostic decisions. Here, the "truth" is determined by adherence to established engineering and safety standards.

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

    No, an MRMC comparative effectiveness study was not done. The study described is not a clinical trial evaluating human reader performance with or without AI assistance. It's a regulatory submission demonstrating the substantial equivalence of an electrosurgical device through engineering and software verification.

    6. Standalone Performance (Algorithm Only Without Human-in-the-Loop Performance)

    This concept is not directly applicable to this device. The Apyx Helium Plasma Generator is a physical medical device that delivers energy for surgical procedures. It does not operate as an "algorithm only" or an AI system that provides diagnostic output without human intervention in the loop. Its performance is evaluated based on its technical specifications and safety conformity, regardless of human interaction methods.

    7. Type of Ground Truth Used

    The "ground truth" used in this submission is implicitly based on established international and national standards for medical electrical equipment (e.g., IEC 60601 series). Compliance with these standards, along with the device's documented performance against its own product specifications, forms the basis of its "truth" for safety and effectiveness in the context of substantial equivalence. There is no mention of pathology, expert consensus (in a clinical sense), or outcomes data being used to establish ground truth for the device itself in this specific regulatory context.

    8. Sample Size for the Training Set

    This information is not applicable/not provided. The device in question is an electrosurgical generator, which is a hardware device with embedded software. It is not an artificial intelligence (AI) or machine learning (ML) algorithm that requires a "training set" of data in the conventional sense. The software verification and validation are against predefined specifications, not learned from a dataset.

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

    This information is not applicable/not provided for the same reasons mentioned in point 8.

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    K Number
    K191542
    Date Cleared
    2019-10-11

    (122 days)

    Product Code
    Regulation Number
    878.4400
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Apyx Plasma/RF Handpiece is intended to be used with compatible electrosurgical generators for the delivery of radiofrequency energy and/or helium plasma for cutting, coagulation of soft tissue during open surgical procedures. The Apyx Plasma/RF Handpiece is compatible with the Electrosurgical Generators, BVX-200H and BVX-200P, owned by Apyx Medical.

    Device Description

    The Apyx Plasma/RF Handpiece is a sterile, single use electrosurgical (monopolar) device intended to be used in conjunction with compatible generators for the percutaneous delivery of radiofrequency energy and/or helium plasma for cutting, coagulation and ablation of soft tissue. The compatible Generators operate at an adjustable power of up to 40W (expressed as 0-100% where 100% is 40W) and provide an adjustable helium gas flow of 1-5 LPM. Radiofrequency energy is delivered to the handpiece by the generator and used to energize the electrode. When helium gas is passed over the energized electrode, a helium plasma is generated for soft tissue cutting, coagulation or ablation.

    The Apyx Plasma/RF Handpiece has a non-extendable electrode to generate helium plasma. The handpiece is available in two different lengths: 15cm and 27cm. The 15cm length is available in a single port (APYX-15-SP) as well as a twin port configuration (APYX-15-TP). The 27cm length is only available with a twin port configuration (APYX-27-TP).

    AI/ML Overview

    The provided text describes the performance data for the Apyx Plasma/RF Handpiece (K191542) to demonstrate its substantial equivalence to predicate devices, focusing on non-clinical testing.

    Here's the breakdown of the acceptance criteria and the studies that prove the device meets them:

    1. Table of Acceptance Criteria and Reported Device Performance

    This section synthesizes the various tests and their outcomes as presented in the document.

    Test CategoryAcceptance Criteria/ObjectiveReported Device Performance/Result
    Bench Testing
    Mechanical Verification & FunctionalityVerify mechanical functionality of the Apyx Plasma/RF Handpiece.Mechanical functionality requirements met.
    Energy & Power OutputVerify via calorimetric testing that the tissue effects are equivalent between the subject device (Apyx Plasma/RF Handpiece), primary predicate device (Renuvion/J-Plasma® Precise Open Handpiece - K183610 & K170188), and predicate device (Renuvion/J-Plasma® Precise Handpiece - K183610 & K151325). Aim to show all deliver the same amount of energy to tissue at equivalent generator settings.There are no significant differences in energy and power outputs between the subject device, Primary Predicate devices owned by Apyx Medical; all 3 devices will deliver the same amount of energy to tissue at equivalent generator settings.
    Electrical Safety & EMC
    Standards ComplianceComplies with ANSI/AAMI/IEC 60601-1:2015/(R)2012 and A1:2012, AAMI/ANSI/IEC 60601-2-2:2017 for safety, and AAMI/ANSI/IEC 60601-1-2:2014 (4th Edition) for EMC.The Apyx Plasma/RF System was determined to be in conformance with these standards.
    Biocompatibility Testing
    ISO 10993 ComplianceEvaluation in accordance with FDA Guidance "Use of International Standard ISO 10993-1" and AAMI/ANSI/ISO 10993-1:2009/(R2013). Focus on cytotoxicity, sensitization, systemic toxicity, irritation, hemolysis, and material-mediated pyrogen/pyrogenicity for an external communicating device with an indirect blood path contact for <24 hours.Biocompatibility has been established per ISO 10993 guidelines for this category. Biocompatibility verification testing was satisfactorily conducted for the subject device.
    Pre-Clinical & Ex-Vivo Studies
    Tissue Temperature Profile EquivalencyCompare tissue temperature profiles of the subject device and predicate devices (Renuvion/J-Plasma® Precise Open Handpiece and Renuvion/J-Plasma® Precise Handpiece) via device activation on porcine skin. Objective: demonstrate equivalent heating of tissue.The subject device (Apyx Plasma/RF Handpiece) and predicate devices (Renuvion/J-Plasma® Precise Open Handpiece & Renuvion/J-Plasma® Precise Handpiece) all heat tissue in an equivalent manner and are substantially equivalent in terms of tissue effect for the coagulation of soft tissue.
    Maximum Internal & External Temperature StudyQuantify internal and external tissue temperatures (via thermal video camera) resulting from Renuvion/J-Plasma® technology for soft tissue coagulation in a live porcine model. Determine effect of multiple variables and worst-case scenario (six consecutive passes in the same area). Acceptance (implied): epidermal surface temperature remains below 41°C and safe limits (below 47°C).The porcine skin epidermal surface temperature remained below 41°C and within safe limits (below 47°C) even with 6 passes in the same area. The results demonstrate that safe skin temperatures are maintained with Renuvion/J-Plasma® Technology, and skin temperature monitoring is not indicated due to its unique mechanism of action.
    Thermal Tissue Effect Comparison (Ex-vivo)Verify that the Apyx Plasma/RF Handpiece produces an equivalent ex-vivo tissue effect (depth and lateral spread of thermal effect) when compared to the predicate device across a range of power and flow settings, including worst-case clinical scenarios.The depth and lateral spread (i.e., average of length and width) of thermal effect measured for the Apyx Plasma/RF handpiece were equivalent to the predicate device's thermal effect as measured over a range of power and flow settings which include worst-case clinical scenarios. The quantitative results demonstrated that the tissue effects of all subject device models (APYX-27-TP, APYX-15-TP and APYX-15-SP) are equivalent to the predicate device's effect.

    2. Sample Size for Test Set and Data Provenance

    • Sample Size: Not explicitly stated for each individual test. The document mentions "testing involved device activation on porcine skin" for the tissue temperature profile equivalency and "a live porcine model" for the maximum temperature study. For ex-vivo studies, it states "several tissue types (i.e., muscle, liver, kidney)."
    • Data Provenance:
      • Country of Origin: Not specified but typically assumed to be conducted in the US or collaborating international laboratories if not stated otherwise for FDA submissions.
      • Retrospective or Prospective: Prospective, as these were specific tests designed and executed to evaluate the new device and its equivalence to predicates.

    3. Number of Experts and Qualifications for Ground Truth

    • Not Applicable: For this device, the "ground truth" is based on objective, quantifiable physical and biological measurements (e.g., temperature, power output, tissue necrosis depth, mechanical integrity, standard safety compliance), not subjective expert interpretation of images or clinical outcomes that would require expert consensus. Therefore, no "experts" in the sense of clinicians establishing ground truth for a diagnostic test were used. The ground truth is defined by established engineering and biological standards and quantitative measurements.

    4. Adjudication Method

    • None (Not Applicable): As the ground truth is based on objective measurements and compliance with established standards, there is no need for an adjudication method typically used in studies involving subjective interpretation (e.g., by radiologists).

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

    • No: No MRMC comparative effectiveness study was performed or described. This type of study is more relevant for diagnostic AI tools where human readers interpret medical images. This submission focuses on the safety and performance equivalence of a surgical electrosurgical handpiece through bench and animal testing.

    6. Standalone Performance (Algorithm Only)

    • Yes, In essence: The studies described are inherently "standalone" in the sense that they evaluate the device's technical and biological performance directly, rather than its performance in assisting human operators or interpreting data for them. The device itself (the Apyx Plasma/RF Handpiece) is the "system" being tested for its intrinsic capabilities (e.g., cutting, coagulation, ablation effectiveness, and safety). There is no "human-in-the-loop" performance being measured in these specific tests, as they focus on the physical and biological effects generated by the device.

    7. Type of Ground Truth Used

    • Objective Measurements and Standard Compliance: The ground truth for these studies is based on:
      • Benchmarking against Predicate Devices: Demonstrating equivalent electrical output and tissue effects.
      • Physical Measurements: Calorimetric energy/power output, mechanical functionality, thermal video camera measurements for tissue temperature, depth and lateral spread of thermal effect in tissue.
      • Compliance with Standards: Electrical safety (IEC 60601 series) and Biocompatibility (ISO 10993 series).
      • Biological Outcomes (Animal/Ex-vivo): Observation of tissue heating, coagulation, and ablation effects in porcine models and various tissue types.

    8. Sample Size for Training Set

    • Not Applicable / Not Provided: This device is a medical instrument, not an AI/ML algorithm that requires a "training set" in the conventional sense. The device's design is based on established engineering principles and iterative development, not data-driven machine learning.

    9. How Ground Truth for Training Set Was Established

    • Not Applicable: As there is no "training set" for an AI/ML algorithm, the concept of establishing ground truth for it does not apply here. The device's performance is verified against design specifications and established safety and efficacy benchmarks through the testing described.
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