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510(k) Data Aggregation

    K Number
    K190119
    Date Cleared
    2019-11-01

    (281 days)

    Product Code
    Regulation Number
    878.4780
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Foryou NPWT Dressing Kit is intended to be used with Foryou NPWT Device to manage wounds through removal of fluids, and the NPWT system is indicated for patients who would benefit from a suction device, particularly as it may promote wound healing by removal of fluids, excess exudate, infectious material, and tissue debris. Foryou NPWT Dressing Kit is indicated for use in patients with the following wounds: traumatic, dehisced wounds, partial-thickness burns, chronic wounds including pressure ulcers, diabetic foot ulcers and venous leg ulcers, acute wounds, flaps and grafts.

    Device Description

    Foryou NPWT Dressing Kit is the wound dressing kit to be used with Foryou NPWT Device for negative pressure wound therapy. It consists of three key components: the foam dressing, the tube unit, and the transparent film. The components are kitted into medical pouch and sterilized, or individually packaged and sterilized. Foryou NPWT Dressing Kit is single-use and sterile. It is available in different sizes: small, medium, large and extra large. The foam dressing should not be used for more than 24 hours and should be replaced with other dressings compatible with Foryou NPWT pump as stated in the Foryou NPWT pump labeling.

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for a medical device, the "Foryou NPWT Dressing Kit." This type of submission relies on demonstrating substantial equivalence to a legally marketed predicate device rather than providing extensive clinical data often seen with novel Class III devices or those requiring a de novo classification.

    Therefore, the information you're requesting regarding acceptance criteria, study details, sample sizes, expert involvement, and ground truth establishment, particularly in the context of an AI/ML device, is largely not present in this document. This document focuses on demonstrating that the new device performs similarly to an existing one through non-clinical performance and biocompatibility testing.

    Here's a breakdown of why your specific questions cannot be fully answered by the provided text:

    • This is not an AI/ML device. The device described is a Negative Pressure Wound Therapy (NPWT) Dressing Kit, which is a physical consumable for wound management.
    • The submission is a 510(k). For 510(k) clearances, the primary goal is to show substantial equivalence to a predicate device. This often involves performance testing (non-clinical) and comparison of specifications, rather than full-blown clinical trials or detailed AI model validation studies.
    • Clinical tests were explicitly stated as NOT performed. (Section 10)

    However, I can extract the information that is available related to acceptance criteria and performance, translating it to your requested table structure where possible, and explain what is missing.


    Acceptance Criteria and Reported Device Performance (as inferred for a non-AI medical device 510(k))

    For a physical device like a wound dressing kit, "acceptance criteria" primarily relate to product specifications, safety (biocompatibility, sterility), and core functional performance (e.g., ability to conduct pressure, remove exudate). These are typically verified through bench testing.

    Acceptance Criteria (Inferred from 510(k) Requirements for this Device Type)Reported Device Performance (from Section 9: "Discussion of Non-Clinical Tests")
    Sterilization & Packaging Integrity: Maintain sterility and physical integrity over shelf life.Package Integrity Tests: "The tests results show that the pouch can meet the requirements of package integrity."
    Shelf-Life: Demonstrate stability and functionality for a specified duration.Shelf-life Test: "Based on the evaluation of the results of the testing data, the Shelf life of Foryou NPWT Dressing Kit is 3 years." (Evaluated via accelerated aging per ASTM F1980-16).
    Biocompatibility: Materials are safe for contact with human tissue.Biocompatibility Tests: "Foryou NPWT Dressing Kits are biocompatible for the intended use for a 'limited' contact duration." (Tested per ISO 10993).
    Functional Performance (Pressure Conduction & Exudate Removal): Device effectively performs its intended function in conjunction with an NPWT pump.Performance tests: "The Foryou NPWT Dressing Kit met all pre-defined acceptance criteria and passed the tests for pressure conduction and exudate removal."

    Information NOT Present in the Document (and why, given it's a 510(k) for a physical device, not AI)

    Given this is a 510(k) for a physical medical device (NPWT dressing kit) and explicitly states "Clinical tests were not performed" (Section 10), the following information relevant to AI/ML device studies would not be found:

    1. Sample size used for the test set and the data provenance: Not applicable in the context of an AI model's test set. The "test set" here refers to physical samples for engineering/bench tests. Data provenance (country of origin, retrospective/prospective) is typically for patient data used in clinical studies, which were not performed.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. Ground truth for a physical device's performance tests would be established by validated measurement standards and equipment, not human expert consensus.
    3. Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable for performance bench testing results.
    4. 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, as this is not an AI-assisted device.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable, as there is no algorithm.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.): For this device, ground truth for performance relates to physical measurements and material properties confirmed by laboratory testing (e.g., pressure values, material composition analysis, sterility validation).
    7. The sample size for the training set: Not applicable, as there is no AI model.
    8. How the ground truth for the training set was established: Not applicable, as there is no AI model.

    In summary: The provided FDA document is a 510(k) clearance letter and summary for a physical medical device (NPWT dressing kit). It demonstrates substantial equivalence primarily through non-clinical performance and safety testing, not through clinical trials or the type of AI/ML performance studies you are asking about.

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