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510(k) Data Aggregation
(165 days)
Bead Block (100 - 300µm, 1ml), Bead Block (300 - 500µm, 1ml), Bead Block (500 - 700µm, 1ml), Bead Block
(700 - 900µm, 1ml), Bead Block (900 - 1200µm, 1ml), Bead Block (100 - 300µm, 2ml), Bead Block (300 -
500µm, 2ml), Bead Block (500 - 700µm, 2ml), Bead Block (700 - 900µm, 2ml), Bead Block (900 - 1200µm,
Bead Block microspheres are intended to be used for the embolization of hypervascular tumours, including uterine fibroids (UFE) and arteriovenous malformations (AVMs). Bead Block microspheres are also intended for embolization of prostatic arteries (PAE) for symptomatic benign prostatic hyperplasia (BPH).
Bead Block, a permanent intravascular implant, is made up of preformed soft, compressible, biocompatible, hydrophilic, non-resorbable and precisely calibrated microspheres that occlude vessels for the purpose of blocking the blood flow to a target tissue. Bead Block compressible microspheres consist of a macromer derived from polyvinyl alcohol (PVA). The fully polymerized microsphere is approximately 90-95% water and is compressible to approximately 30% by diameter. Bead Block microspheres are dyed blue to aid in the visualization of the microspheres in the delivery syringe. The microspheres can be suspended in contrast agents and delivered through microcatheters to the target location. Bead Block is available in bead sizes from 100 – 1200µm and supplied sterile in 20ml syringes which contain 1 or 2 ml of beads suspended in 6 or 5 ml of phosphate buffered saline, respectively. The different bead sizes of the product are differentiated by differently colored labels and syringe end caps. Bead Block is provided as a single use, non-pyrogenic, sterile (steam sterilized) device.
This document is a 510(k) Premarket Notification from the FDA regarding the "Bead Block" device. It attests to the device's substantial equivalence to previously marketed predicate devices for the specified indications for use.
Based on the provided text, the Acceptance Criteria and Device Performance for this medical device (Bead Block) are not defined in terms of typical AI/ML-based image analysis performance metrics (e.g., sensitivity, specificity, AUC). Instead, the document focuses on demonstrating substantial equivalence to existing predicate devices based on safety and effectiveness for its intended use, which is embolization.
The "study" described is a retrospective data review of the clinical outcomes of patients treated with Bead Block for prostatic artery embolization (PAE) for symptomatic benign prostatic hyperplasia (BPH). This is a clinical effectiveness study, not a study of an AI/ML device's diagnostic or analytical performance.
Therefore, many of the requested points related to AI/ML device study parameters (e.g., test set, ground truth experts, MRMC studies, standalone performance) are not applicable to this document.
Here's an attempt to answer the prompt based on the provided text, reinterpreting the "acceptance criteria" and "study" in the context of a medical device submission for substantial equivalence:
1. A table of acceptance criteria and the reported device performance
The "acceptance criteria" for this 510(k) submission are not explicitly stated as quantitative thresholds for clinical performance but rather are implicitly tied to demonstrating safety and effectiveness comparable to predicate devices. The "reported device performance" refers to the clinical outcomes observed in the retrospective study.
Acceptance Criteria (Implicit from 510(k) Process) | Reported Device Performance (from Retrospective Study) |
---|---|
Safety: Device is safe for intended use, with acceptable adverse event profile compared to predicate. | Observed AEs: 149/232 patients (64.2%) reported at least one AE. Most AEs were non-serious and transient. Most common were renal/urinary disorders (15.2%), dysuria (41.4%), pollakiuria (45.3%). Conclusion: "well tolerated treatment." |
Effectiveness: Device effectively achieves intended clinical outcome, comparable to predicate. | Clinical Improvements at 12 Months: |
- 85% of patients: decrease in total IPSS by at least 3 points.
- 62% of patients: dropped at least 1 symptom category (severe to moderate to mild).
- Statistically significant and clinically relevant improvements in total IPSS, QoL, PSA, and prostate volume (p
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(341 days)
Bead Block
Bead Block™ microspheres are intended to be used for the embolization of hypervascular tumors, including uterine fibroids and arteriovenous malformations (AVMs).
Bead Block™ is made up of preformed soft, deformable microspheres that occlude arteries for the purpose of blocking the blood flow to a target tissue, such as a fibroid or a cancerous tumor. Bead Block™ compressible microspheres consist of a macromer derived from polyvinyl alcohol (PVA). The fully polymerized microsphere is approximately 90-95% water and is compressible to approximately 30% by diameter. Bead Block™ microspheres are dyed blue to aid in the visualization of the microspheres in the delivery syringe. The microspheres can be delivered through typical microcatheters in the 1.5-5Fr range.
The provided document is a 510(k) summary for the Bead Block™ device, which is a vascular embolization device. The information requested pertains to the acceptance criteria and the study that proves the device meets the acceptance criteria. The document largely focuses on demonstrating substantial equivalence to a predicate device rather than performance against specific numeric acceptance criteria for the new device.
Here's an analysis based on the available information:
1. Table of acceptance criteria and the reported device performance
The document does not present a table of explicit numeric acceptance criteria. Instead, it relies on demonstrating that Bead Block™ is "as safe and effective as the predicate device" and that its performance is "similar to the predicate device". The "performance" is described qualitatively through the results of non-clinical and animal testing.
Acceptance Criteria Category | Reported Device Performance |
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Material Properties: | |
Residual starting material | Specifications met (details not provided) |
Residual solvent material | Specifications met (details not provided) |
Physical Appearance: | |
Visual inspection | Visual defects, color, solution clarity evaluated (results not explicitly stated, but implied to be acceptable for substantial equivalence) |
Delivery & Functionality: | |
Catheter delivery | Evaluated for catheter clogging, aggregation, ease of injection, and particle shape after injection (results not explicitly stated, but implied to be acceptable for substantial equivalence, and "similar to the predicate device") |
Particle size range | Confirmation performed (results not explicitly stated, but implied to be within specified range as per product configurations table, e.g., 100-300μm, 300-500μm, etc.) |
Particle fiber shedding | Evaluated (results not explicitly stated, but implied to be acceptable for substantial equivalence) |
Biocompatibility: | |
pH | Evaluated (results not explicitly stated, but implied to be acceptable for substantial equivalence) |
Endotoxin |
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(108 days)
LC BEAD MICROSPHERES, BEAD BLOCK COMPRESSIBLE MICROSPHERES
LC Bead Microspheres & Bead Block Compressible Microspheres is intended for embolization of hypervascular tumors and arteriovenous malformations.
LC Bead/Bead Block are preformed, soft, deformable microspheres that occlude arteries for the purpose of blocking the blood flow to a target tissue, such as a hypervascular tumor or arteriovenous malformations (AVM's). LC Bead/Bead Block consists of a macromer derived from polyvinyl alcohol (PVA). The fully polymerized microsphere is approximately 90% water and is compressible to approximately 20-30% by diameter. Bead Block is dyed blue (LC Bead are available as blue and in natural color) to aid in the visualization of the microspheres in the delivery syringe. The microspheres can be delivered through typical microcatheters in the 1.8-5Fr range.
LC Bead is supplied sterile and packaged in sealed glass vials. Bead Block is supplied sterile and packaged in polycarbonate syringes. The product configurations are described in the table. LC Bead/Bead Block are supplied in several unit sizes covering the range from 100-1200um diameter. At the time of use, LC Bead/Bead Block is mixed with a nonionic contrast agent, e.g. Omnipaque™, to make a 30-50% by weight solution.
The provided text describes the LC Bead/Bead Block Embolic Agent, a vascular embolization device, and includes information relevant to its acceptance criteria and the studies conducted to demonstrate its performance.
Acceptance Criteria and Device Performance
The acceptance criteria for the LC Bead/Bead Block devices are primarily defined by successful outcomes in various biocompatibility tests, in-vitro physical property tests, and pre-clinical animal model performance, all demonstrating substantial equivalence to predicate devices and adherence to relevant standards.
Here's a table summarizing the acceptance criteria and the reported device performance based on the provided document:
Acceptance Criteria Category | Specific Test/Property | Acceptance Criteria | Reported Device Performance |
---|---|---|---|
Biocompatibility (ISO 10993) | Genotoxicity: In Vitro Chromosomal Aberration Study | Pass | Pass |
Mouse Bone Marrow Micronucleus Study | Pass | Pass | |
In Vitro Hemolysis Study | Pass | Pass | |
ISO Muscle Implantation Study (Rabbit) | Pass | Pass | |
Cytotoxicity Study (ISO Elution Method) | Pass | Pass | |
ISO Sensitization Study (Guinea Pig) | Pass | Pass | |
ISO Acute Intracutaneous Reactivity Study (Rabbit) | Pass | Pass | |
Chronic Toxicity Study (Rat, Subcutaneous, 13 weeks) | Pass | Pass | |
Subchronic Intravenous Toxicity Study (Rat, 14 days) | Pass | Pass | |
Genotoxicity: Bacterial Reverse Mutation Study | Pass | Pass | |
ISO Acute Systemic Toxicity Study (Mouse) | Pass | Pass | |
ISO Surgical Muscle Implantation (Rabbit, 26 weeks) | Pass | Pass | |
Pre-clinical (Swine Model) | Recanalization of vessels (comparison to predicate) | Substantially equivalent or better than predicate | LC Bead demonstrated an advantage in having a more durable embolization effect compared to Embospheres. |
Local and systemic foreign body tissue reactions | Very mild and similar to predicate | Very mild and essentially the same as Embospheres. | |
Ease of delivery | Easy delivery, minimal catheter clogging | LC Bead delivered easily; only one case of catheter clogging (vs. six for predicate). | |
Occurrence of blood vessel rupture | No incidents | No incidents. | |
Non-target embolization/device migration | Minimal incidence, comparable to predicate | One case of unexplained non-target embolization with Embospheres, none with LC Bead. One potential case of device migration with LC Bead, none with Embospheres (overall comparable). | |
In-Vitro Physical Properties | Size distribution (new 70-150µm LC Bead) | Met specification | All product met specification; graph shows tight distribution for Lots A, B, C. |
Fibres Specification (new 70-150µm LC Bead) | Pass | Pass | |
Compressibility | Equivalent to other marketed embolic agents | Equivalent compressibility to other marketed embolic agents. | |
Catheter Deliverability | Compatible with typical microcatheters | Successfully delivered through various microcatheters ranging from 0.016" to 0.024" ID. | |
Other Device Attributes | Residual starting materials | Pass | Pass |
Residual solvents | Pass | Pass | |
Product visual inspection for presence of fibres | Pass | Pass | |
Bead Aggregation/Clogging (during catheter delivery) | No unintended aggregation or catheter blockage | Assessed during catheter delivery testing, implied Pass. | |
Ease of Delivery (during catheter delivery) | "Not difficult" | Assessed as part of catheter delivery testing, must be "not difficult" to pass; implied Pass. | |
Shape after embolic after injection | Evaluated using optical microscopy; implied acceptable | Evaluated using optical microscopy; implied Pass. | |
Bead Deliverability (whole vial through catheter) | Successful delivery of whole vial | Ability to deliver the whole vial of beads mixed with contrast agent through a catheter as described in the IFU; implied Pass. | |
Levels of broken or bead fragments after catheter delivery | Minimal/acceptable | Evaluated after catheter delivery using optical microscopy; implied Pass. | |
Time to Suspension Studies | Stable homogeneous suspension within specified time | Time taken for beads to form a stable homogeneous suspension when mixed with contrast and saline/water; implied Pass. | |
Bead aspiration from vial | Easy removal using standard syringes and needles | Ease of removing beads from primary packaging using standard syringes and needles as described in IFU; implied Pass. | |
Bead sizing (after packaging and sterilization) | Met specification | Size of beads after packaging and sterilization; implied Pass. | |
pH Testing (of final packing solution) | Met specification | pH of the final packing solution after sterilization; implied Pass. |
Study Details
The primary study mentioned to demonstrate device performance is a pre-clinical evaluation in a swine model and various in-vitro and biocompatibility tests.
2. Sample Size and Data Provenance
- Test Set (Pre-clinical Swine Model):
- Sample Size: LC Bead Embolic Agent (n=36) and Embosphere® microspheres (n=36). Total of 72 cases.
- Data Provenance: Prospective animal study (swine model), likely conducted in a controlled laboratory setting. The country of origin is not specified but assumed to be within the regulatory framework of the submitting company (UK) or a contracted research organization.
3. Number of Experts and Qualifications for Ground Truth (Test Set)
The document does not specify the number or qualifications of experts used to establish a "ground truth" in the clinical sense for the animal study. The evaluation appears to be based on direct observations and pathological analyses rather than expert consensus on diagnostic images. Outcomes assessed include recanalization, tissue reactions, ease of delivery, rupture, and migration. These would typically be evaluated by a team of veterinary surgeons, pathologists, and potentially radiologists, but their specific qualifications are not detailed.
4. Adjudication Method (Test Set)
The document does not describe a formal adjudication method (like 2+1 or 3+1 consensus) for the pre-clinical swine study outcomes. The assessment appears to be based on direct measurement and observation by the study investigators.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No MRMC comparative effectiveness study involving human readers or AI assistance is described. This device is a physical embolization device, not an AI software or diagnostic tool that would typically involve such a study with human readers interpreting images.
6. Standalone Performance Study
The "pre-clinical testing in a large animal model" and the "in-vitro testing" sections describe studies of the device's standalone performance. These are intended to demonstrate the device's intrinsic characteristics and biological safety without human interaction beyond its intended use (delivery by a clinician).
7. Type of Ground Truth Used for Test Set
- Pre-clinical Swine Model: The ground truth was established through direct observation during procedures (e.g., ease of delivery, vessel rupture), gross pathological examination (e.g., non-target embolization, device migration), and histological analysis of explanted tissues (e.g., recanalization, local and systemic foreign body tissue reactions).
- Biocompatibility Tests: Laboratory assays and animal studies according to ISO standards, providing biological and toxicological endpoints.
- In-vitro testing: Direct physical measurements and observations of device properties (e.g., size distribution, compressibility, catheter deliverability, residual materials).
8. Sample Size for the Training Set
The document does not mention a training set. This is because the device is a physical medical device, not a machine learning or AI algorithm that requires a training set. The performance data presented are from verification and validation studies.
9. How the Ground Truth for the Training Set Was Established
Not applicable, as no training set for an AI/ML algorithm is described.
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(68 days)
LC BEAD MICROSPHERES, BEAD BLOCK COMPRESSIBLE MICROSPHERES
LC Bead Microspheres & Bead Block™ Compressible Microspheres is intended for embolization of hypervascular tumors and arteriovenous malformations.
LC Bead and Bead Block™ Compressible Microspheres are preformed soft, deformable microspheres that occlude arteries for the purpose of blocking the blood flow to a target tissue, such as a hypervascular tumor or arteriovenous malformations (AVM's). LC Bead and Bead Block ™ Compressible Microspheres consist of a macromer derived from polyvinyl alcohol (PVA). The fully polymerized microsphere is approximately 90% water and is compressible to approximately 20-30% by diameter. Bead Block™ Compressible Microspheres is dyed blue (LC Bead are available in natural color) to aid in the visualization of the microspheres in the delivery syringe. The microspheres can be delivered through typical microcatheters in the 1.8-5Fr range.
LC Bead Microspheres is supplied sterile and packaged in sealed glass vials. Bead Block™ Compressible Microspheres is supplied sterile and packaged in a polycarbonate syringe. Two quantities will be available in a vial: (1) 1.0 mL LC Bead /Bead Block™ Compressible Microspheres in sterile physiologic buffered saline (PBS) to a volume of 8 mL, and (2) 2.0mL LC Bead/Bead Block™ Compressible Microspheres in sterile PBS to a volume of 8 mL.
LC Bead and Bead Block Compressible Microspheres are supplied in several unit sizes covering the range from 100um to 1200um diameter.
At the time of use, LC Bead/Bead Block™ Compressible Microspheres is mixed with a nonionic contrast agent, e.g. Omnipaque, to make a 30-50% by weight solution. The bolus of contrast agent elutes from the vascular bed to leave a radiolucent, embolized vessel.
The provided text describes the 510(k) submission for "Bead Block and LC Bead" microspheres. However, the document does not contain information about acceptance criteria or a study proving the device meets specific performance metrics in the way typically seen for AI/ML-driven devices (e.g., sensitivity, specificity, or reader study results). This submission is for a medical device (embolic microspheres), not a diagnostic algorithm or AI system.
Therefore, most of the requested information regarding acceptance criteria and study details (like sample size for test sets, data provenance, expert ground truth, MRMC studies, standalone performance, training set details) is not applicable to this particular document.
Here's an attempt to address the request based only on the provided text, while highlighting the limitations:
1. A table of acceptance criteria and the reported device performance
The document lists "Performance Standards" which are primarily regulatory and quality standards for medical devices, rather than specific numerical performance metrics related to diagnostic accuracy or efficacy in the way an AI/ML device would be evaluated.
Acceptance Criteria (Performance Standard) | Reported Device Performance | Notes |
---|---|---|
FDA Guidance for Neurological Embolization Products (2004) | Met | The device's indications for use align with this guidance. |
ISO/EN 10993-1 (1997) Biological Evaluation of Medical Devices, Part 1: Evaluation and Testing | Met | Implies the device has undergone biological evaluation. |
ISO/EN 10993-3 (1993) Biological Evaluation of Medical Devices, Part 3: Tests for genotoxicity, carcinogenicity and reproductive toxicity | Met | Implies the device has been tested for these toxicities. |
ISO/EN 10993-4 (1993) Biological Evaluation of Medical Devices, Part 4: Selection of tests for interaction with blood | Met | Implies the device has been tested for blood interaction. |
ISO/EN 10993-6 (1995) Biological Evaluation of Medical Devices, Part 6: Test for local effects after implantation | Met | Implies the device has been tested for local effects. |
ISO/EN 10993-10 (1995) Biological Evaluation of Medical Devices. Part 10: Tests for Irritation and Sensitization | Met | Implies the device has been tested for irritation and sensitization. |
ISO/EN 10993-11 (1993) Biological Evaluation of Medical Devices, Part 11: Tests for Systemic Toxicity | Met | Implies the device has been tested for systemic toxicity. |
ISO/EN 11607 (1997) Packaging for terminally sterilized products | Met | Implies the device packaging meets sterilization standards. |
AAMI 11134 (1993) Sterilization of Health Care Products Requirements for validation and routine control - Industrial moist heat sterilization | Met | Implies the sterilization process meets this standard. |
ANSI/AAMI/ISO 14937 (2000) Sterilization of Health Care Products - Characterization of a Sterilizing Agent and the Development, Validation and Routine Control of a Sterilization Process for Medical Devices | Met | Implies the sterilization process meets this standard. |
EN 554: Sterilization of Medical Devices validation and Routine Control of Sterilization by Moist Heat | Met | Implies the sterilization process meets this standard. |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
This information is not provided in the document. The document describes a medical device (microspheres) and its regulatory submission, not a study involving a test set of data for an AI/ML algorithm. The "Performance Standards" listed are for the device itself (biocompatibility, sterilization, etc.), not for evaluating an algorithm's performance on a dataset.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
This information is not provided and is not applicable to the type of device described. Ground truth for an AI/ML test set would involve expert annotations or pathology, which is not relevant for the regulatory approval of embolic microspheres based on biocompatibility and manufacturing standards.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This information is not provided and is not applicable.
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 information is not provided and is not applicable. MRMC studies are typically for evaluating the impact of AI/ML systems on human reader performance, which is not the subject of this 510(k) submission.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This information is not provided and is not applicable. The device is a physical medical product (microspheres), not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
For the device itself, the "ground truth" would relate to its physical and biological properties meeting established standards (e.g., sterility confirmed by lab tests, biocompatibility confirmed by in-vitro/in-vivo studies, particle size confirmed by measurement). The document references various ISO/EN standards which would implicitly define the "ground truth" for compliance. There is no mention of expert consensus, pathology, or outcomes data in the context of proving the device meets acceptance criteria as would be relevant for an AI/ML system.
8. The sample size for the training set
This information is not provided and is not applicable. This is not an AI/ML device.
9. How the ground truth for the training set was established
This information is not provided and is not applicable.
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(87 days)
GELSPHERES MICROSPHERES AND BEAD BLOCK COMPRESSIBLE MICROSPHERES
GelSpheres™/Bead Block™ Compressible Microspheres are indicated for Embolization of hypervascular tumors and arteriovenous malformations (AVM's).
GelSpheres™ and Bead Block™ Compressible Microspheres are preformed soft, deformable microspheres that occlude arteries for the purpose of blocking the blood flow to a target tissue, such as a hypervascular tumor or arteriovenous malformations (AVM's). GelSpheres™ and Bead Block ™ Compressible Microspheres consist of a macromer derived from polyvinyl alcohol (PVA). The fully polymerized microsphere is approximately 90% water and is compressible to approximately 20-30% by diameter. Bead Block™ Compressible Microspheres is dyed blue (GelSpheres™ are available in natural color) to aid in the visualization of the microspheres in the delivery syringe. The microspheres can be delivered through typical microcatheters in the 1.8-5Fr range.
GelSpheres ™ Microspheres is supplied sterile and packaged in sealed glass vials. Bead Block™ Compressible Microspheres is supplied sterile and packaged in a polycarbonate syringe. Two quantities will be available in a vial: (1) 1.0 mL GelSpheres™ /Bead Block™ Compressible Microspheres in sterile physiologic buffered saline (PBS) to a volume of 8 mL, and (2) 2.0mL GelSpheres™/Bead Block™ Compressible Microspheres in sterile PBS to a volume of 8 mL.
GelSpheres™ and Bead Block Compressible Microspheres are supplied in several unit sizes covering the range from 100μm to 1200um diameter. At the time of use, GelSpheres"™/Bead Block™ Compressible Microspheres is mixed with a nonionic contrast agent, e.g. Omnipaque, to make a 30-50% by weight solution. The bolus of contrast agent elutes from the vascular bed to leave a radiolucent, embolized vessel.
The provided FDA 510(k) Pre-Market Notification for GelSpheres™ Microspheres and Bead Block™ Compressible Microspheres does not describe a study that uses acceptance criteria related to device performance metrics, nor does it report on such performance metrics for the device itself.
Instead, this submission focuses on demonstrating substantial equivalence to previously cleared predicate devices (K023089 and K033761). The core of the submission is that the current device (K042231) is identical in design, intended use, warnings, contraindications, product, manufacturing, and primary packaging to the predicates. The only reported change is the final packager from BioCure, Inc. to Biocompatibles UK Ltd.
Therefore, the information requested in your prompt regarding acceptance criteria, device performance, sample sizes, ground truth establishment, expert involvement, and MRMC studies is not present in this document.
The document lists Performance Standards that the device meets, but these are generic regulatory and biological evaluation standards, not specific performance metrics (e.g., accuracy, sensitivity, specificity) for evaluating its efficacy in embolization. These standards ensure the device meets safety and manufacturing requirements, but not a clinical performance standard regarding, for example, the success rate of embolization or reduction in tumor size.
Specifically:
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A table of acceptance criteria and the reported device performance: Not applicable. No performance metrics (e.g., embolization success rate, AVM reduction) or associated acceptance criteria are stated or evaluated in this document. The "acceptance criteria" here are implied to be meeting the listed performance standards (e.g., ISO, AAMI for biocompatibility, sterility, packaging), and the "device performance" is deemed equivalent to the predicate devices.
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Sample sizes used for the test set and the data provenance: Not applicable. No clinical or performance test set data is presented.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. No ground truth for performance evaluation is established or discussed.
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Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable.
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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 medical implant (microspheres for embolization), not an AI-powered diagnostic or assistive tool.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable. This is not an algorithm.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc): Not applicable.
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The sample size for the training set: Not applicable.
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How the ground truth for the training set was established: Not applicable.
In summary, this 510(k) submission primarily relies on demonstrating substantial equivalence based on design and intended use rather than presenting new clinical or performance data against pre-defined acceptance criteria for efficacy. The "study that proves the device meets the acceptance criteria" refers to the entire 510(k) submission process, which asserts equivalence and compliance with general safety and performance standards rather than specific performance metrics directly related to its therapeutic effect.
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