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510(k) Data Aggregation
(77 days)
ENDOSCOPIC PLICATION SYSTEM, EPS, EPLICATOR, PLICATOR INSTRUMENT
The NDO Endoscopic Plication System (EPS) is indicated for the treatment of the symptoms of chronic gastroesophageal reflux disease (GERD) in patients who require and respond to pharmacological therapy.
The NDO Surgical Endoscopic Plication System (EPS) deploys a suture-based implant in the stomach near the Gastroesophageal Junction thereby creating a full thickness plication of the gastric cardia for the treatment of Gastroesophageal Reflux Disease (GERD). The EPS consists of three procedural components: the Plicator instrument, the Plicator retractor and the Plicator implant cartridge. The implant cartridge and retractor are loaded onto the instrument and the instrument is then passed transorally into the stomach to create the plication.
Both the retractor and implant cartridge are provided as sterile, single use, disposable components of the EPS. The Plicator instrument is a non-sterile multiple use device that is subject to cleaning and high level chemical disinfection between uses. To facilitate cleaning and high level disinfection of the Plicator instrument with an Automated Endoscope Reprocessor (AER), the EPS will include a non-procedural "cleaning adapter" accessory.
The provided document describes a 510(k) submission for the NDO Surgical Endoscopic Plication System (EPS). This submission focuses on modifications to the cleaning and high-level disinfection instructions and an added accessory rather than a new device or significant design change requiring extensive clinical performance studies. Therefore, the information typically available for software-as-a-medical-device (SaMD) studies (e.g., sample sizes for training/test sets, expert qualifications, MRMC studies) is not applicable here.
Here's an analysis based on the provided text, focusing on the device modifications and the performance data provided for those modifications:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria | Reported Device Performance |
---|---|
Efficacy of disinfection processes for reusable medical devices (demonstrated by simulated use testing using Mycobacterium terrae in accordance with ASTM E 1837-96) | Cleaning and high-level disinfection of the Plicator instrument was achievable using CIDEX in a Custom Ultrasonics System 83 Plus™ Endoscope Washer/Disinfector. |
2. Sample Size Used for the Test Set and Data Provenance
The document does not specify a "test set" in the context of clinical or algorithmic performance data. The testing performed was simulated use testing for cleaning and disinfection. Therefore, typical sample sizes (e.g., number of patients, images) and data provenance (country, retrospective/prospective) are not applicable.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
Not applicable. The ground truth for the cleaning and disinfection study was the successful elimination of Mycobacterium terrae to accepted standards, as determined by laboratory testing protocols outlined in ASTM E 1837-96. This does not involve human experts in the way clinical diagnostic studies would.
4. Adjudication Method for the Test Set
Not applicable. This was a laboratory-based performance test following a standardized protocol (ASTM E 1837-96), not a study requiring adjudication of human expert opinions.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No. An MRMC study is relevant for evaluating the impact of AI on human reader performance, typically in diagnostic imaging. This submission concerns a physical medical device and its cleaning/disinfection procedures, not an AI or diagnostic application.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
Not applicable. This submission is not for an algorithm or software. The performance data relates to the physical Plicator instrument's ability to be properly disinfected.
7. The Type of Ground Truth Used
For the cleaning and disinfection study, the ground truth was derived from laboratory testing standards and microbial inactivation as stipulated by ASTM E 1837-96. This standard outlines procedures to determine the efficacy of disinfection processes. The "ground truth" was whether the specified disinfection process effectively eliminated the test microorganism (Mycobacterium terrae) from the device, which is an objective, measurable outcome in a laboratory setting.
8. The Sample Size for the Training Set
Not applicable. This submission is not for an AI/ML device, 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 this device modification submission.
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(104 days)
ENDOSCOPIC PLICATION SYSTEM; EPS; PLICATOR
The NDO Endoscopic Plication System (EPS) is indicated for the treatment of the symptoms of chronic gastroesophageal reflux disease (GERD) in patients who require and respond to pharmacological therapy.
The NDO Surgical Endoscopic Plication System (EPS) is a device that deploys a suture-based implant in the stomach near the Gastroesophageal Junction thereby creating a full thickness plication of the gastric cardia for the treatment of Gastroesophageal Reflux Disease (GERD). The EPS consists of three procedural components: the Plicator instrument, the Plicator retractor and the Plicator implant cartridge. The implant cartridge and retractor are loaded onto the instrument and the instrument is then passed transorally into the stomach to create the plication. The Plicator instrument's shaft, which comes into contact with the patient, is made of polyurethane. The retractor is made of surgical grade stainless steel, with a polycarbonate sheath. The implant is comprised of two titanium retention bridges, 2.0 polypropylene suture and two ePTFE pledgets. The implant is housed in a disposable cartridge. Once the Plicator instrument has been introduced into the stomach, the retractor is engaged into the gastric cardia and the tissue is retracted into the arms of the instrument. The arms of the instrument are closed and the implant is deployed, creating a full thickness, serosa-to-serosa plication.
Here's an analysis of the provided text regarding the NDO Surgical Endoscopic Plication System (EPS) and its acceptance criteria and supporting studies:
Acceptance Criteria and Device Performance
The submission focuses on modifications to a previously cleared device (predicate EPS) and demonstrates substantial equivalence. Therefore, the "acceptance criteria" are primarily established by the performance of the predicate device and the new device's ability to meet those same levels of safety and effectiveness, especially for the modified components and new features (like multiple implant deployment).
Acceptance Criteria Category | Reported Device Performance (Modified EPS) |
---|---|
Moisture Ingress Inhibition | The modified leak test port design, cap, and seal reliably inhibit the ingress of moisture into the Plicator instrument during cleaning and high-level disinfection. |
Instrument/Cartridge Compatibility & Implant Deployment | The modified Plicator instrument and implant cartridge are compatible and reliably deploy Plicator implants. |
Biocompatibility | Biocompatibility testing confirmed acceptable and equivalent biocompatibility profiles of patient contact materials used in the modified Plicator instrument and implant cartridge as compared to materials present in the predicate instrument and implant cartridge. |
Feasibility of Multiple Implants | Simulated use testing demonstrated the feasibility of safely deploying multiple, serially placed, Plicator implants. |
Safety and Effectiveness for Symptoms of GERD (Multiple Implants) | Clinical testing demonstrated that serial placement of multiple, Plicator implants to form multiple, serial, full-thickness plications of the gastric cardia in close proximity to the anterior gastroesophageal junction safely and effectively treats the symptoms of gastroesophageal reflux disease. The submission concludes that "The serial placement of multiple Plicator implants... is equivalent in safety and effectiveness to single Plicator implant placement for the treatment of symptomatic gastroesophageal reflux disease." |
Study Information
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Sample Size used for the test set and the data provenance:
- Bench Testing: Not explicitly stated, but typically involves a specified number of samples for each test (e.g., a certain number of leak tests, implant deployments). The provenance is likely internal lab testing by NDO Surgical, Inc.
- Biocompatibility Testing: Not explicitly stated, but subject to ISO standards for medical device materials. The provenance refers to "patient contact materials" and comparisons to "predicate instrument and implant cartridge."
- Simulated Use Testing: Not explicitly stated regarding sample size. Provenance is likely in-house testing.
- Clinical Testing: Not explicitly stated regarding the number of patients or implants. The data provenance is "clinical experience with the predicate device" which implies a prospective or retrospective analysis of human use data, but the "clinical testing" for the modified device would be prospective. The statement "Clinical testing demonstrated that serial placement of multiple, Plicator implants... safely and effectively treats..." strongly suggests a clinical study was performed.
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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 for bench, biocompatibility, and simulated use testing which rely on objective measurements and established protocols.
- For the clinical testing, the "ground truth" would be the patient's GERD symptoms and their response to treatment, assessed by clinicians (likely gastroenterologists) as part of the study. The number of experts or their specific qualifications (e.g., years of experience) are not detailed in this summary.
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Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- Not applicable for the types of tests described (bench, biocompatibility, simulated use).
- For clinical studies, adjudication methods (like independent review panels for adverse events or efficacy endpoints) are common, but this detail is not provided in this 510(k) summary.
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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 surgical instrument, not an imaging or diagnostic AI device.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. This is a manual surgical device with a human operator.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- Bench Testing: Objective physical measurements and functional performance tests (e.g., water ingress, implant deployment mechanics).
- Biocompatibility Testing: Compliance with established biocompatibility standards (e.g., ISO 10993).
- Simulated Use Testing: Observational data on successful and safe deployment in a controlled environment.
- Clinical Testing: Patient-reported symptoms of GERD, physician assessment of treatment response, and safety outcomes (adverse events). This falls under outcomes data and clinical assessment.
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The sample size for the training set:
- Not applicable. This is not a machine learning/AI device, so there is no "training set."
-
How the ground truth for the training set was established:
- Not applicable. No training set is involved.
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(43 days)
MODIFICATION TO ENDOSCOPIC PLICATION SYSTEM
The NDO EPS System is indicated for the treatment of the symptoms of chronic gastroesophageal reflux disease (GERD) in patients who require and respond to pharmacological therapy.
The NDO Surgical Endoscopic Plication System is a device intended to deliver an implant in the stomach near the Gastroesophageal Junction that creates a full thickness plication for the treatment of Gastroesophageal Reflux Disease (GERD). The EPS consists of three components: the Endoscopic Plication Instrument, the Retractor and the Implant Cartridge. The Implant Cartridge and retractor are loaded onto the instrument; this is then passed transorally into the stomach to create the plication. The instrument's shaft, which comes into contact with the patient, is made of polyvinyl chloride coated with parylene. The retractor is made of surgical grade stainless steel, with a polycarbonate sheath. The implant is comprised of two titanium tees, 2.0 polypropylene suture and two ePTFE pledgets. The implant is housed in a disposable cartridge. Once the system has been introduced into the stomach, the retractor is engaged into the gastric mucosa and the tissue is retracted into the arms of the instrument. The arms of the instrument are closed and the implant is deployed, creating the full thickness, serosa-to-serosa plication.
The provided document is a 510(k) premarket notification letter and a 510(k) summary for the NDO Surgical Endoscopic Plication System. It discusses the device's substantial equivalence to a predicate device and mentions performance data were submitted, but it does not provide specific acceptance criteria or an explicit study description with detailed results that prove the device meets these criteria.
Therefore, I cannot populate the table and answer the questions as requested, because this information is not present in the provided text. The document states that "Bench top, In-Vivo simulated use and ex-vivo performance testing were completed in support of the substantial equivalence determination," but it does not detail these tests, their acceptance criteria, or their results.
Key Missing Information:
- Specific acceptance criteria for the device's performance.
- Detailed results from any studies (bench top, in-vivo, or ex-vivo).
- Sample sizes for test sets or training sets.
- Data provenance.
- Information about expert involvement for ground truth, adjudication, or MRMC studies.
- Details on standalone performance or ground truth type.
Without this information, I cannot fulfill your request for a table of acceptance criteria, reported performance, and the details of a study proving compliance.
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(32 days)
ENDOSCOPIC PLICATION SYSTEM, MODEL 160-00760
The NDO EPS System is indicated for the treatment of the symptoms of chronic gastroesophageal reflux disease (GERD) in patients who require and respond to pharmacological therapy.
The NDO Surgical Endoscopic Plication System is a device intended to deliver an implant in the stomach near the Gastroesophageal Junction that creates a full thickness plication for the treatment of Gastroesophageal Reflux Disease (GERD). The EPS consists of three components: the Endoscopic Plication Instrument, the Retractor and the Implant Cartridge. The Implant Cartridge and retractor are loaded onto the instrument; this is then passed transorally into the stomach to create the plication. The instrument's shaft, which comes into contact with the patient, is made of polyvinyl chloride. The retractor is made of surgical grade stainless steel. with a polycarbonate sheath. The implant is comprised of two titanium tees, 2.0 polypropylene suture and two ePTFE pledgets. The implant is housed in a disposable cartridge. Once the system has been introduced into the stomach, the retractor is engaged into the gastric mucosa and the tissue is retracted into the arms of the instrument. The arms of the instrument are closed and the implant is deployed, creating the full thickness, serosa-to-serosa plication.
This document describes the NDO Surgical Endoscopic Plication System (EPS) for treating GERD. However, it is a 510(k) summary for a substantial equivalence determination and does not contain a detailed study with acceptance criteria and reported device performance metrics in the format requested.
The document states that the device is "substantially equivalent" to a predicate device (K023234) and that "Bench top, In-Vivo simulated use and ex-vivo performance testing was provided in support of the substantial equivalence determination. The testing demonstrates substantially equivalent performance between the two devices." This implies that the acceptance criteria and performance data were assessed against the predicate device's performance, but the specific details are not provided in this public document.
Therefore, I cannot provide the detailed information requested in the prompt, such as specific acceptance criteria, sample sizes, expert qualifications, or details about MRMC or standalone studies.
Here's what can be extracted from the document, though it's limited in scope for your request:
1. Table of Acceptance Criteria and Reported Device Performance:
- Acceptance Criteria: Not explicitly stated in this document. The document refers to "substantially equivalent performance" to the predicate device (NDO Surgical Endoscopic Plication System K023234). This would imply passing various bench-top, in-vivo simulated use, and ex-vivo performance tests to demonstrate comparable safety and effectiveness, but the specific metrics and thresholds are not included.
- Reported Device Performance: "The testing demonstrates substantially equivalent performance between the two devices." No specific quantitative metrics (e.g., accuracy, sensitivity, specificity, clinical outcomes) are provided in this summary.
2. Sample size used for the test set and the data provenance:
- Not specified in this document. The testing mentioned (Bench top, In-Vivo simulated use and ex-vivo) implies test sets were used, but their size and provenance (country, retrospective/prospective) are not detailed.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable as this is a medical device for treatment, not an AI/diagnostic device where ground truth is typically established by experts for image interpretation. The "ground truth" here would relate to the successful and safe deployment and function of the device, likely assessed by engineers, clinicians, and researchers through various performance tests.
4. Adjudication method for the test set:
- Not applicable/ Not specified.
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 a medical device for a physical procedure, not an AI-assisted diagnostic tool involving human readers.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done:
- Not applicable. This is a physical endoscopic device, not a software algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc):
- For this type of device, "ground truth" would generally be related to engineering specifications, successful deployment, structural integrity, and functional outcomes in simulated and ex-vivo environments, and ultimately, clinical outcomes in human studies (though not detailed here). The document refers to "Bench top, In-Vivo simulated use and ex-vivo performance testing," which would evaluate these aspects against predefined criteria, likely derived from the predicate device's performance and established engineering standards.
8. The sample size for the training set:
- Not applicable/ Not specified. This device is not an AI algorithm that requires a "training set."
9. How the ground truth for the training set was established:
- Not applicable.
In summary, as this is a 510(k) summary for a medical device (Endoscopic Plication System) seeking substantial equivalence, it focuses on demonstrating that the updated device is as safe and effective as a previously cleared predicate and does not provide the detailed performance metrics, acceptance criteria, or study specifics typically found in a clinical trial report or a submission for a novel AI/diagnostic device.
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(202 days)
ENDOSCOPIC PLICATION SYSTEM
The NDO EPS System is indicated for the treatment of the symptoms of chronic gastroesophageal reflux disease (GERD) in patients who require and respond to phamacological therapy.
The Endoscopic Plication System consists of an instrument, retractor, overtube and implant.
The instrument is passed transorally to create a plication in close proximity to the gastroesophageal junction.
The implant is designed to help pass and secure the suture.
The retractor is designed to secure and retract the tissue during the placement of the implant. It is placed down a working channel of the instrument prior to the procedure.
The overtube is designed to protect the esophagus during the procedure.
I am sorry, but the provided text does not contain the detailed information necessary to answer your request about the acceptance criteria and the specific study proving the device meets those criteria.
The document is a 510(k) premarket notification letter and a 510(k) summary for the NDO Surgical Endoscopic Plication System. While it mentions "Clinical evaluation" under performance data and states "The clinical comparison shows that the NDO Endoscopic Plication System to be at least as safe and effective as the Bard EndoCinch," it does not provide any specific details about:
- Acceptance criteria: What specific metrics (e.g., success rates, complication rates, improvement in GERD symptoms) were considered, and what thresholds defined acceptance.
- Reported device performance: The actual numerical results from the clinical study.
- Sample size: For either the test set or training set.
- Data provenance: Country of origin, retrospective/prospective.
- Number and qualifications of experts: For ground truth establishment.
- Adjudication method.
- MRMC comparative effectiveness study: No mention of human reader performance or AI assistance.
- Standalone algorithm performance: No mention of an algorithm, only a device.
- Type of ground truth: Not specified beyond "clinical comparison."
- How ground truth was established for training or testing.
The document primarily focuses on establishing substantial equivalence to a predicate device (Bard EndoCinch Suturing System) based on similar intended use, technical characteristics, and the lack of new safety/effectiveness questions from bench and animal testing.
Therefore, I cannot generate the table or answer the specific questions you posed based on the provided text.
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