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510(k) Data Aggregation

    K Number
    K200071
    Date Cleared
    2020-11-03

    (295 days)

    Product Code
    Regulation Number
    876.1500
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Blue Beacon Submucosal Injectable Solution

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

    Blue Beacon™ Submucosal Injectable Solution is indicated for submucosal lift of polyps, adenomas, early state cancers or other gastrointestinal mucosal lesions, prior to excision with a snare or endoscopic device.

    Device Description

    Blue Beacon™ Submucosal Injectable Solution is indicated for submucosal lift of polyps, adenomas, early stage cancers or other gastrointestinal mucosal lesions, prior to excision with a snare or endoscopic device. Under the surveillance of endoscope, in conjunction with endoscopic injection needles with a diameter equal to or greater than 23G are recommended), inject the product beneath the lesion until enough submucosal lift. It is supplied in a 5 mL, 10ml syringe. The contents of the syringe are sterile and nonpyrogenic. The proposed devices are moist heat sterilized to achieve the Sterility Assurance Level (SAL) of 10-6 and placed in a sterility maintenance package to ensure a shelf life of 2 years.

    AI/ML Overview

    The provided document describes the Micro-Tech (Nanjing) Co., Ltd. Blue Beacon™ Submucosal Injectable Solution (K200071) and its substantial equivalence to a predicate device. This document is a 510(k) summary, which focuses on demonstrating equivalence rather than providing detailed acceptance criteria and a comprehensive study report with statistically significant outcomes against specific acceptance thresholds for a diagnostic AI device.

    Therefore, the requested information, which is typical for a diagnostic AI device requiring performance against quantitative acceptance criteria, is largely not present in this type of submission. The device described is a medical injectable solution, not an AI or diagnostic device.

    However, I can extract the available information which pertains to device performance and testing, and explain why other requested details are not applicable or provided in this context.

    Here's a breakdown of the available information:


    1. Table of Acceptance Criteria and Reported Device Performance

    As this is a 510(k) submission for a non-AI injectable solution, there are no "acceptance criteria" in the sense of accuracy, sensitivity, or specificity metrics typical for AI or diagnostic devices. Instead, the submission relies on demonstrating substantial equivalence to a predicate device (Eleview™ Submucosal Injection Composition, K150852) and meeting general medical device standards.

    The "acceptance criteria" are implicitly meeting the performance characteristics of the predicate device and relevant international standards.

    CharacteristicPredicate Device (Eleview™ - K150852) PerformanceProposed Device (Blue Beacon™) PerformanceComparison / Acceptance
    Product CodePLLPLLSame / Meets
    Regulation No.876.1500876.1500Same / Meets
    Class22Same / Meets
    Supplied SterileYesYesSame / Meets
    SterilizationFiltration and Aseptic FillingMoist Heat SterilizationDifferent (See note)
    CompositionWater for Injection, Medium chain triglycerides, Poloxamer 188, Olyoxyl-15-Hydroxystearate, Sodium chloride, Methylene blue.Water for Injection, Sodium Hyaluronate, Sodium dihydrogenphosphate anhydrous, Sodium phosphate dibasic, Sodium chloride, Methylene blue.Similar (See note)
    Indications for UseSubmucosal lift of polyps, adenomas, early-stage cancers or other gastrointestinal mucosal lesions, prior to excision with a snare or other suitable endoscopic device.Submucosal lift of polyps, adenomas, early state cancers or other gastrointestinal mucosal lesions, prior to excision with a snare or endoscopic device.Same / Meets
    Single UseYesYesSame / Meets
    PackagingAmpouleSyringeDifferent (See note)
    Shelf LifeTwo yearsTwo yearsSame / Meets
    BiocompatibilityAssumed to meet ISO 10993 standardsTested to ISO 10993-1:2009/(R)2013Meets ISO standards
    Sterilization ValidationAssumed to meet relevant standards priorISO 17665-1:2006 (Moist Heat)Meets ISO standards
    Bench TestsN/A (Comparative Testing)Appearance, Content, pH, Colorant Concentration, Viscosity, Injection ForceDemonstrated "substantially equivalent" to predicate
    Pre-filled syringe tests (Specific to packaging)N/A (Comparative Testing)Graduation Accuracy, Luer-lock Connection Seal Integrity, Separation Force, Tip Cap Removal Force, Seal IntegrityDemonstrated "qualified"
    Accelerated Aging/Shelf-lifeN/A (Comparative Testing)ASTM F1980-16 for accelerated aging; 2-year aging test to support resultsSupported 2-year shelf life

    Note on Differences: The differences in sterilization method, composition, and packaging are addressed by performance testing (bench tests, syringe tests, biocompatibility, sterilization validation) to demonstrate that these differences do not raise new questions of safety or effectiveness. The conclusion is that despite these differences, the devices are "substantially equivalent."


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

    • Sample Size for Test Set: Not explicitly stated numerically for "bench performance tests" (Appearance, Content, pH, etc.) or for the pre-filled syringe tests. The document mentions "a series of bench performance tests" and "a series tests were conducted" which implies multiple samples were tested under each category.
    • Data Provenance: The studies were conducted by Micro-Tech (Nanjing) Co., Ltd. in China, as indicated by the company's address and the origin of the submission. The studies are retrospective in the sense that they are conducted on manufactured devices and evaluated against established standards and the predicate device's characteristics.

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

    This information is not applicable and not provided as the device is an injectable solution, not a diagnostic device requiring expert interpretation of results or images. The "ground truth" for the performance tests would be objective measurements against specified physical/chemical properties or validated standards.


    4. Adjudication Method for the Test Set

    This information is not applicable as the device is not a diagnostic device requiring adjudication of human reader 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

    This information is not applicable as the device is not an AI diagnostic tool and therefore no MRMC studies involving human readers and AI assistance would be performed.


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

    This information is not applicable as the device is not an AI algorithm.


    7. The Type of Ground Truth Used

    The "ground truth" for the performance characteristics of this device is based on:

    • Objective measurements of physical and chemical properties (e.g., pH, viscosity, content, colorant concentration).
    • Compliance with international standards for medical device safety and performance (e.g., ISO 10993 for biocompatibility, ISO 17665 for sterilization, ASTM F1980 for accelerated aging).
    • Comparison to the established characteristics of the legally marketed predicate device (K150852) to demonstrate substantial equivalence.
    • Animal testing for safety and effectiveness, conducted under GLP Regulations (21 CFR §58), is also cited as "ground truth" for in-vivo performance.

    8. The Sample Size for the Training Set

    This information is not applicable as the device does not involve a "training set" in the context of machine learning or AI.


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

    This information is not applicable as the device does not involve a "training set."

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