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510(k) Data Aggregation
(30 days)
Biodesign Otologic Repair Graft
The Cook® Biodesign® Otologic Repair Graft is intended for use as an implant material to aid in surgical repairs and as an adjunct to aid in the natural healing process in various otologic procedures, including but not limited to myringoplasty and tympanoplasty. The device is supplied sterile and is intended for one-time use.
The Cook® Biodesign® Otologic Repair Graft is a porous, absorbable, multi-layer biomaterial composed of laminated extracellular collagen matrix derived from porcine small intestinal submucosa (SIS). SIS is obtained from the intestine using a process that retains the natural composition of matrix molecules such as collagen (Types I, III, VI), glycosaminoglycans (hyaluronic acid, chondroitin sulfate A and B, heparin, and heparin sulfate), proteoglycans, and fibronectin. The device achieves its intended use by providing a scaffold for cellular invasion and capillary growth, and maintaining a supportive environment for wound management.
This document describes a 510(k) premarket notification for the Biodesign Otologic Repair Graft (K161000). The key information revolves around a packaging change and the demonstration of substantial equivalence to a predicate device (K150594).
Here's the breakdown of the acceptance criteria and the study that proves the device meets them:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria Category | Specific Acceptance Criteria (Implied) | Reported Device Performance |
---|---|---|
Preamble Testing | Demonstration of sterility maintenance over the product's shelf life. | "Sterilization adoption" was performed, implying the sterilization method remains effective with the new packaging configuration. The document states, "Any potential new risks associated with the change in device packaging have been identified by appropriate risk analysis techniques. These potential new risks have been addressed with verification and validation activities in a manner satisfactory to the pre-determined acceptance criteria to ensure that no change to device safety has occurred." |
Packaging Integrity | The new packaging (snap-top container) must maintain its integrity and protect the device throughout its intended shelf life and under various transport/storage conditions. | "Package performance testing for accelerated aged devices in the snap-top container packaging" was performed, suggesting the new packaging meets performance requirements for integrity and protection. |
Biocompatibility | The new packaging component (snap-top tray) must not introduce cytotoxins or other harmful substances that could leach into the device or patient. | "Cytotoxicity testing of the snap-top tray" was performed, indicating the material of the new packaging is biocompatible and does not pose a cytotoxic risk. |
Material Composition | The device's material composition should remain identical to the predicate device. | The document explicitly states the "material composition... of both subject and predicate devices are identical." The device is composed of "laminated extracellular collagen matrix derived from porcine small intestinal submucosa (SIS)." |
Intended Use | The intended use of the device should remain unchanged from the predicate device. | The document states, "This intended use is identical to that previously cleared under K150594 for the predicate device." |
Sterilization Method | The sterilization method should remain consistent and effective. | The document confirms the sterilization method is "Ethylene Oxide," which is the same as the predicate. |
Single Use | The device remains intended for single use. | The document confirms the device is intended for "single use," same as the predicate. |
2. Sample Size Used for the Test Set and Data Provenance
The document does not explicitly state specific sample sizes for the "sterilization adoption," "package performance testing," or "cytotoxicity testing." It only mentions that these tests were "performed to demonstrate substantial equivalence."
- Data Provenance: The studies were conducted by Cook Biotech Incorporated, as part of their 510(k) submission. The data is retrospective in the sense that these tests were performed on the device and its new packaging configuration to demonstrate equivalence, rather than being part of a prospective clinical trial. The country of origin of the data is implied to be the USA, where Cook Biotech Incorporated is located.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
This document does not pertain to studies requiring expert adjudication for ground truth (e.g., medical image interpretation). The testing described here is related to device engineering, materials science, and packaging performance. The "ground truth" for these tests would be established through defined scientific methodologies and standards (e.g., ISO standards for biocompatibility or ASTM standards for package testing), rather than expert consensus on a clinical outcome or image.
4. Adjudication Method for the Test Set
Not applicable as this is not a study involving human reader interpretation or clinical outcomes that would require adjudication.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done
No, an MRMC comparative effectiveness study was not done. This submission is for a material and packaging change, not an AI or diagnostic device that would involve human readers.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done
No, a standalone algorithm performance study was not done. This device is a surgical graft, not an algorithm.
7. The Type of Ground Truth Used
The ground truth used for the non-clinical tests would be based on:
- Scientific Standards: For sterilization adoption, it would be demonstration of sterility in accordance with established standards (e.g., ISO 11135 for ethylene oxide sterilization).
- Engineering Standards: For package performance, it would be meeting pre-defined physical and barrier property requirements based on industry standards (e.g., ASTM F1980 for accelerated aging, various ASTM standards for package integrity like peel strength, burst tests, etc.).
- Biological Standards: For cytotoxicity, it would be meeting the requirements of recognized biocompatibility standards (e.g., ISO 10993-5 for in vitro cytotoxicity).
8. The Sample Size for the Training Set
Not applicable. This device is a physical medical device, not an AI or machine learning model that requires a training set.
9. How the Ground Truth for the Training Set was Established
Not applicable for the same reason as above.
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(191 days)
Biodesign Otologic Repair Graft
The Biodesign Otologic Repair Graft is intended for use as an implant to aid in surgical repairs and as an adjunct to aid in the natural healing process in various otologic procedures, including but not limited to myringoplasty and tympanoplasty. The device is supplied sterile and is intended for one-time use.
The Biodesign Otologic Repair Graft is an absorbable multi-layer biomaterial composed of four layers of laminated extracellular collagen matrix derived from porcine small intestinal submucosa (SIS). The SIS material is lyophilized and then punched into the desired shape. The device is available in 4 mm, 6 mm and 9 mm diameter discs, as well as 2.5 x 2.5 cm and 5 x 5 cm square sheets. Upon implantation, the Biodesign Otologic Repair Graft is infiltrated by the host cells and acts as a scaffold for these cells during the body's natural repair process.
Additionally, the circular configurations of the device are packaged in a dried state and supplied sterile in a tray inside a sealed Tyvek® pouch. The square configurations of the device are also packaged sterile in a dried state inside a sealed Tyvek® pouch.
The provided text describes the Biodesign Otologic Repair Graft and its substantial equivalence to predicate devices, but it does not contain the specific information required to complete the detailed table about acceptance criteria and study design for a device. The document is a 510(k) summary, which focuses on demonstrating substantial equivalence to existing devices rather than defining and proving acceptance criteria with specific performance metrics and a detailed study design as might be seen for a novel device or PMA.
Here's a breakdown of what can be extracted and what information is missing:
1. Table of Acceptance Criteria and Reported Device Performance
Performance Metric | Acceptance Criteria | Reported Device Performance |
---|---|---|
Biocompatibility | Meets ISO 10993-1 standards | Biodesign Otologic Repair Graft met biocompatibility requirements for genotoxicity, direct contact in vitro hemolysis, cytotoxicity, muscle implantation, acute intracutaneous reactivity, ISO sensitization, acute systemic toxicity, pyrogenicity, LAL endotoxins, and subchronic systemic toxicity. |
Mechanical Strength (Burst Strength) | Adequate mechanical strength for application (Specific threshold not provided) | Biodesign Otologic Repair Graft "has adequate mechanical strength for its application" (specific values and comparison not detailed). |
Efficacy (Myringoplasty & Tympanoplasty) | Effectiveness comparable to predicate device/autologous tissue repair for myringoplasty. | In a 404-patient study for myringoplasty, stable tympanic membrane closures were seen in 212/217 (97.2%) of SIS repairs (Biodesign material) compared to 204/215 (94.8%) of temporalis fascia (PTF) procedures. This difference was not statistically significant regarding procedural times. |
Safety (Adverse Reactions) | No significant adverse reactions | No adverse reactions observed with SIS or PTF repairs in the 404-patient study. |
"No significant adverse events were reported" in additional unpublished clinical data sets (18, 19, 32, and 8 patients). | ||
Device Degradation/Host Response | Similar to predicate device MeroGel Otologic Pack | Mouse implant study showed Biodesign Otologic Repair Graft performed similarly to MeroGel Otologic Pack in terms of device degradation and non-inflammatory host responses. |
Missing Information/Cannot be extracted:
The document focuses on substantial equivalence based on material properties, biocompatibility, and clinical outcomes, rather than specific, quantified acceptance criteria for novel performance claims. For example, while mechanical strength was tested, the acceptance criterion (e.g., "burst strength must exceed X MPa") is not provided, only the qualitative statement that it was "adequate." Similarly, for efficacy, there's no explicitly stated acceptance criteria (e.g., "myringoplasty success rate must be >90%") before the study results are presented.
2. Sample Size for the Test Set and Data Provenance
- Biocompatibility Tests: The exact number of samples used for each test (genotoxicity, cytotoxicity, etc.) is not specified. The tests were performed on "sterilized SIS devices," which are identical in composition to the Biodesign Otologic Repair Graft.
- Mechanical Testing (Burst Strength): The sample size is not specified.
- Animal Testing:
- Efficacy study: Chinchilla model (number of animals not specified).
- Implant study: Mouse model (number of animals not specified).
- Clinical Testing (Prospective Data):
- Primary Study: 404 patients (217 SIS repairs, 215 temporalis fascia (PTF) repairs).
- Data Provenance: The study was conducted by D'Eredita, but the country of origin is not explicitly stated. The material was labeled as "Surgisis." The comparison was made against "temporalis fascia (PTF) repairs performed by the same surgeon," implying a clinical setting. The follow-up was 2-11 years (average 7.7 years).
- Additional Unpublished Data:
- a) 18 patients (Hsu, DuPage Medical Group, 2015)
- b) 19 patients (Toh C. et al., Birmingham Heartland Hospital, UK, 2003) - UK origin.
- c) 32 patients (Ofo E. et al., North West London Hospital, UK, 2009) - UK origin.
- d) 8 patients (Lalwani A. San Francisco, CA, COSM 2003) - USA origin.
- Retrospective/Prospective: The 404-patient study is explicitly called "Prospective data." The additional data are referred to as "unpublished data" but their specific prospective/retrospective nature is not detailed.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
- This information is not provided. Clinical outcomes (e.g., stable tympanic membrane closures, adverse events) would have been assessed by treating physicians, but the document does not detail a specific expert panel/adjudication process for establishing ground truth for the clinical studies mentioned.
4. Adjudication Method for the Test Set
- This information is not provided. For clinical outcomes, the treating surgeon or independent clinicians would typically assess post-operative results, but no specific adjudication method (like 2+1 consensus) is outlined.
5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study was done
- No, an MRMC comparative effectiveness study was not done. The clinical studies reported involved a comparison of the device material (SIS) with autologous tissue repair (temporalis fascia) or comparison to a predicate in an animal model, and observations of patient outcomes. These are not MRMC studies as typically understood for AI device assessments involving multiple readers evaluating cases with and without AI assistance to measure reader improvement.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done
- This is not applicable. The Biodesign Otologic Repair Graft is a physical medical device (implantable biomaterial), not an AI algorithm or software device. Therefore, a "standalone algorithm performance" study is not relevant to this product.
7. The Type of Ground Truth Used
- Biocompatibility: In vitro and in vivo test results against ISO 10993-1 standards.
- Mechanical Testing: Measured burst strength.
- Animal Testing: Histological assessment of cellular response and device degradation (observations by researchers), and efficacy observations in chinchilla tympanic membrane repair.
- Clinical Testing: Clinical outcomes data (e.g., stable tympanic membrane closures, occurrence/absence of adverse reactions/events) observed post-operatively by treating physicians or study investigators. This would be considered outcomes data or clinical expert observation.
8. The Sample Size for the Training Set
- This is not applicable. The Biodesign Otologic Repair Graft is a physical medical device (biomaterial), not an AI algorithm. Therefore, there is no "training set" in the context of machine learning. The device itself is manufactured using a specific process and its properties are inherently defined by its material and design, not by being "trained" on data.
9. How the Ground Truth for the Training Set Was Established
- This is not applicable for the reasons stated in point 8.
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