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510(k) Data Aggregation

    K Number
    K210481
    Date Cleared
    2021-12-14

    (298 days)

    Product Code
    Regulation Number
    880.2800
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Instant 20s Indicator

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

    The True Indicating Instant 20s Indicator, a multiple, interactive, bacterial enzyme indicator, is used for monitoring saturated steam sterilization processes operating at: 121°C, 30 minutes (Gravity), 132°C, 4 minutes (Pre- Vacuum), 135°C, 3 minutes (Pre-Vacuum).

    Device Description

    The True Indicating Instant 20s Indicator consists of a polycarbonate vial, polypropylene cap, a silicone vented cap which serves as a base, a vinyl sealant, and a biological tablet produced using cellulose, and enzymes from Geobacillus stearothermophilus ATCC® 7953.

    AI/ML Overview

    The provided text describes the nonclinical tests conducted for the "Instant 20s Indicator" device (K210481), a sterilization process indicator. The information pertains to the device's performance in laboratory settings to ensure it meets the required safety and effectiveness standards for its intended use.

    Here's an analysis of the acceptance criteria and study that proves the device meets them, based on the provided text:

    1. A table of acceptance criteria and the reported device performance

    Name of TestPurpose and Guidance Document/StandardAcceptance CriteriaSubject Device Result
    D value Based on Enzymatic ActivityDetermine the resistance of the Instant 20s Indicator following ISO 11138-1 and 11138-3D121 ≥ 1.5 min
    D132 ≥ 10 s
    D135 ≥ 8 sPASS
    D121 ≥ 1.7 min
    D132 ≥ 12 s
    D135 ≥ 12 s
    z value Based on Enzymatic ActivityDetermine the z-value of the Instant 20s Indicator per ISO 11138-1 and 11138-3≥10PASS
    ≥13.6
    Survival Time Based on Enzymatic ActivityDetermine the exposure time for all Instant 20s Indicator to retain viable spores (Survival Time) per ISO 11138-1, 11138-3 and Guidance for Industry and Staff - Biological Indicator (BI) Premarket Notification [510(k)] SubmissionMeets the longer of FDA and ISO 11138-3 requirementsPASS
    121°C ≥ 5.1 min
    132°C ≥ 1.0 min
    135°C ≥ 40 sec
    Kill Time Based on Enzymatic ActivityDetermine the exposure time for all Instant 20s Indicator to inactivate all spores (Kill Time) per ISO 11138-1, 11138-3 and Guidance for Industry and Staff - Biological Indicator (BI) Premarket Notification [510(k)] SubmissionMeets the shorter of FDA and ISO 11138-3 requirementsPASS
    121°C ≤ 15.3 min
    132°C ≤ 1.8 min
    135°C ≤ 1.8 min
    Hold TimeDetermine the length of time that an exposed Instant 20s Indicator can be held before incubation (Hold Time) per Guidance for Industry and Staff – Biological Indicator (BI) Premarket Notification [510(k)] SubmissionPerformance not affected if used within 72 hours of exposure to steam sterilizationPASS
    Growth InhibitionDetermine if positive result is achieved when primary packaging is subject to worst case steam exposure per Guidance for Industry and Staff – Biological Indicator (BI) Premarket Notification [510(k)] Submission100% Positive ResultsPass
    Shelf LifeResistance and Survival/Kill must meet above criteria at each stability time point per ISO 11138-1, 11138-3 and Guidance for Industry and Staff - Biological Indicator (BI) Premarket Notification [510(k)] SubmissionD value = see above
    Survival = see above
    Kill = see abovePASS
    Chemical Indicator PerformanceDetermine the pass/fail criteria for each critical cycle parameter and provide the pass/fail results to show how the chemical indicator reacts to all the critical parameters in the sterilization cycle for which it is intended according to ANSI/AAMI/ISO 11140-1:2014 Sterilization of health care products - Chemical indicators - Part 1: General requirements and Guidance for Industry and FDA Staff - Premarket Notification [510(k)] Submissions for Chemical IndicatorsPass result at Stated Value for each temperature claimed:
    121°C, 30 minutes (Gravity)
    132°C, 3 minutes (Pre-Vac)
    135°C, 3 minutes (Pre-Vac)

    Fail Result at 15% less time and -1°C of Stated Value | PASS |
    | Endpoint Stability of Positive Result Color | Determine the endpoint stability of developed color due to a positive result (failure) per Guidance for Industry and FDA Staff - Premarket Notification [510(k)] Submissions for Chemical Indicators | 7 Days | PASS |
    | Endpoint Stability of Negative Result Color | Determine the endpoint stability of color due to a negative result (pass) per Guidance for Industry and FDA Staff - Premarket Notification [510(k)] Submissions for Chemical Indicators | 30 Minutes | PASS |
    | Simulated Use | Determine the simulated use of the Instant 20s Indicator in a sterilizer per Guidance for Industry and FDA Staff - Biological Indicator (BI) Premarket Notification [510(k)] Submission | Demonstrates a survival (positive) result when exposed to abbreviated cycle, and all kill (negative) in full and half cycles | PASS
    Abbreviated cycles - positive
    Half cycles - negative
    Full cycles - negative |
    | Biocompatibility (In Vitro Cytotoxicity) | To determine if the device is cytotoxic to mammalian cells in vitro | Under conditions of the study, did not show potential toxicity to L-929 cells. | PASS |

    2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    The document is a 510(k) submission for a non-clinical device (sterilization indicator). The testing described is not related to patient data or clinical studies in the traditional sense of medical imaging or diagnostic devices. Instead, it involves laboratory verification of the physical and biological characteristics of the "Instant 20s Indicator."

    • Sample Size: The document does not specify exact numerical sample sizes (e.g., number of indicators tested for each criterion). It mentions "multiple lots of True Indicating Instant 20s Indicator over the range of the shelf life" were used for testing on page 5.
    • Data Provenance: The data is generated from nonclinical laboratory tests of the device itself.
      • Country of Origin: Not explicitly stated, but the company (True Indicating LLC) is based in Toledo, Ohio, USA, which implies the testing was likely conducted in the US or by US-affiliated labs.
      • Retrospective or Prospective: Not applicable in the context of clinical studies. These are prospective laboratory tests conducted specifically for the 510(k) submission to demonstrate compliance with standards and guidance documents.

    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 question is not applicable to this type of device and study. The "Instant 20s Indicator" is a physical product designed to provide a direct, observable biological or chemical reaction (color change) based on exposure to a sterilization process. Ground truth is established by:

    • Objective physical measurements: Temperature, time, and steam conditions in the sterilization chambers used for testing.
    • Biological viability (spores): Growth or inhibition of "Geobacillus stearothermophilus ATCC® 7953" enzymes. This "ground truth" is determined by established microbiological methods and is not subject to expert consensus in the way a medical image diagnosis would be.
    • Chemical reaction: The color change observed.

    There are no human "experts" establishing a subjective ground truth, as would be the case in image interpretation studies. The process is objective and measurable against established physical and biological standards.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    Not applicable. This is not a study involving human interpretation or subjective assessments that would require an adjudication process. The results are based on objective laboratory measurements and observations (e.g., color change, growth/no growth, D-value calculation).

    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 device is a sterilization indicator, not an AI-powered diagnostic tool. There are no human "readers" or AI assistance involved in its function or the testing described. Its output is a direct, observable color change or a measurable biological/chemical response, not an interpretation of complex data.

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

    Not applicable. There is no algorithm for this device. The device itself performs its function (indicating sterilization efficacy) in a "standalone" manner in that it is placed in the sterilizer and then removed and activated to provide a result. There is no human required during the sterilization process for the device to function.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    The ground truth for this device is based on:

    • Physical Parameters: Precisely controlled and measured temperature, time, and steam conditions in the sterilization test chambers. These parameters are rigorously defined by international standards (e.g., ISO 11138 series).
    • Microbiological Viability: The known resistance characteristics of the Geobacillus stearothermophilus spores/enzymes used in the indicator. The "kill" or "survival" of these biological entities under defined conditions constitutes the ground truth.
    • Chemical Reaction: The expected color change of the indicator solution when it reacts with viable or inviable enzymes, as per the device's design.

    Essentially, the "ground truth" is the known effect of specific sterilization conditions on the indicator's biological and chemical components, established through adherence to recognized consensus standards and guidance documents.

    8. The sample size for the training set

    Not applicable. As a physical sterilization indicator, this device does not use machine learning or require a "training set" in the computational sense. Its function is based on inherent biological and chemical properties, not learned patterns from data.

    9. How the ground truth for the training set was established

    Not applicable, as there is no training set for this device.

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