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510(k) Data Aggregation

    K Number
    K030887
    Manufacturer
    Date Cleared
    2003-06-13

    (84 days)

    Product Code
    Regulation Number
    882.1275
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    LEKTROGEL™ is an electroconductive gel media used with external electrodes to reduce the impedance (resistance to alternative current) of the contact between the electrode surface and the skin.

    Device Description

    LEKTROGEL™ is an electroconductive gel media used with external electrodes to reduce the impedance (resistance to alternative current) of the contact between the electrode surface and the skin. It is supplied in 250 grams dispensers with a 3-year shelf life.

    AI/ML Overview

    The provided text is a 510(k) Summary for a medical device called LEKTROGEL™ (Model LK3001), an electroconductive gel media. This document primarily focuses on establishing substantial equivalence to a predicate device rather than presenting full performance study data with specific acceptance criteria and detailed study designs.

    Here's an analysis of the acceptance criteria and study information based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    The submission claims identical performance to the predicate device. Therefore, the "acceptance criteria" appear to be defined by the performance characteristics of the predicate device. However, no specific quantitative acceptance criteria or numerical performance metrics are provided for either device.

    CharacteristicAcceptance Criteria (Implied)Reported Device Performance (LEKTROGEL™)
    Indications for useIdentical to predicate device (Contact Conductive Adhesive Gel)Identical
    Target populationIdentical to predicate deviceIdentical
    DesignIdentical to predicate deviceIdentical
    MaterialsIdentical to predicate deviceIdentical
    PerformanceIdentical to predicate deviceIdentical
    SterilityIdentical to predicate deviceIdentical
    BiocompatibilityIdentical to predicate deviceIdentical
    Mechanical safetyIdentical to predicate deviceIdentical
    Chemical safetyIdentical to predicate deviceIdentical
    Anatomical sitesIdentical to predicate deviceIdentical
    Human factorsIdentical to predicate deviceIdentical
    Energy used and/or deliveredIdentical to predicate deviceIdentical
    Compatibility with environmentIdentical to predicate deviceIdentical
    Standards metIdentical to predicate deviceIdentical
    Electrical safetyIdentical to predicate deviceIdentical
    Thermal safetyIdentical to predicate deviceIdentical
    Radiation safetyIdentical to predicate deviceIdentical

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

    The document does not describe a specific test set or a study with a sample size in the traditional sense of clinical or performance testing. The basis for the substantial equivalence claim is the asserted "identical" nature of the device to its predicate. There's no mention of country of origin for test data, or whether it was retrospective or prospective, as no such study is detailed.

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

    Not applicable. As no independent test set with performance evaluation is described, there's no mention of experts establishing ground truth for such a set. The "ground truth" for the submission is the established characteristics and performance of the predicate device.

    4. Adjudication Method for the Test Set

    Not applicable. No test set requiring expert adjudication is described.

    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 an electroconductive gel, not an AI-powered diagnostic tool. Therefore, an MRMC study related to human reader improvement with AI assistance is not relevant and not discussed.

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

    Not applicable. This is a physical medical device (gel), not an algorithm.

    7. The Type of Ground Truth Used

    The "ground truth" for this submission is the established characteristics, safety, and performance of the legally marketed predicate device (Contact Conductive Adhesive Gel from Parker Laboratories, Inc., 510k # K852956). The entire submission argues that LEKTROGEL™ is "IDENTICAL" to this predicate.

    8. The Sample Size for the Training Set

    Not applicable. This device is not an AI/ML algorithm that requires a training set.

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

    Not applicable. This device is not an AI/ML algorithm.

    Summary of the Study that Proves the Device Meets Acceptance Criteria:

    The "study" or evidence provided to prove the device meets acceptance criteria is based on a comparative analysis of technological characteristics between LEKTROGEL™ and a predicate device (Contact Conductive Adhesive Gel from Parker Laboratories, Inc., 510k # K852956). The submission asserts that the new device is "IDENTICAL" to the predicate device across all critical technological characteristics, including indications for use, design, materials, performance, sterility, biocompatibility, safety, and other factors.

    The acceptance criteria are implicitly defined as matching all characteristics of the predicate device. By demonstrating identity, the manufacturer aims to prove substantial equivalence, thereby meeting the regulatory requirements without needing to conduct extensive independent performance studies that would be required for a novel device. The FDA's letter states: "We have reviewed your Section 510(k) premarket notification... and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices..." This indicates the FDA accepted the claim of identical characteristics as sufficient evidence for substantial equivalence in this context.

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