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510(k) Data Aggregation

    K Number
    K211123
    Date Cleared
    2022-04-22

    (372 days)

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

    LUOFUCON Silver Wound Gel, LUOFUCON Silver Antimicrobial Wound Gel

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

    Prescription: LUOFUCON® Silver Wound Gel is under the medical supervision of a healthcare professional for the management of 1st and 2nd degree burns, wounds such as stasis ulcers, pressure ulcers, lacerations, abrasions, skin tears, surgical incision sites, device insertion site wounds, graft sites, and donor sites.

    OTC: LUOFUCON® Silver Antimicrobial Wound Gel is indicated for the topical management of minor cuts, minor lacerations and minor burns.

    Device Description

    LUOFUCON® Silver Wound Gel /LUOFUCON® Silver Antimicrobial Wound Gel is a sterile, water-based amorphous gel composed of hydrophilic polymer and silver compound. The gel helps to maintain a moist wound environment. The silver compound acts as a preservative to inhibit the growth of microorganisms in the gel during shelf storage.

    LUOFUCON® Silver Wound Gel /LUOFUCON® Silver Antimicrobial Wound Gel is supplied in a tube (collapsible, polypropylene tube, sealed on one end and fitted with a screw cap on the other end).

    AI/ML Overview

    The provided document is a 510(k) summary for the LUOFUCON® Silver Wound Gel / LUOFUCON® Silver Antimicrobial Wound Gel. It describes the device, its intended use, and compares it to predicate devices to demonstrate substantial equivalence.

    Based on the content, here's an analysis of the acceptance criteria and study information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly present a "table of acceptance criteria" with numerical targets for clinical performance metrics (like sensitivity, specificity, accuracy) that would be common for AI/diagnostic devices. Instead, it focuses on demonstrating substantial equivalence to a predicate device by comparing various physical, chemical, and biological properties, as well as general performance attributes relevant to wound care gels.

    The table below summarizes the comparative data presented, which implicitly serves as "acceptance criteria" by showing the subject device is comparable to the predicate/reference devices for key properties and performance aspects.

    ItemPredicate Device (K083103)Reference Device (K140483)Subject Device (K211123)Interpretation (Acceptance/Performance)
    Device NameAcryDerm Antimicrobial Silver Gel Wound Dressing Model #B / OTC: AcryDerm Wound Gel Model #BASAP OTC Wound Dressing GelLUOFUCON® Silver Wound Gel / LUOFUCON® Silver Antimicrobial Wound GelSubject device name aligns with product type.
    Classification RegulationUnclassifiedUnclassifiedUnclassifiedAcceptance: Matches predicate and reference.
    Product CodeFROFROFROAcceptance: Matches predicate and reference.
    Indications for Use (Rx)Management of 1st and 2nd degree burns, wounds such as stasis ulcers, pressure ulcers, diabetic ulcers, lacerations, abrasions, skin tears, surgical incision sites, device insertion site wounds, graft sites, and donor sites.N/AManagement of 1st and 2nd degree burns, wounds such as stasis ulcers, pressure ulcers, diabetic ulcers, lacerations, abrasions, skin tears, surgical incision sites, device insertion site wounds, graft sites, and donor sites.Acceptance: Substantially equivalent to predicate Rx indications.
    Indications for Use (OTC)Management of minor abrasions, cuts, lacerations, and scalds.Topical management of minor cuts, lacerations, abrasions, 1st and 2nd degree burns, and skin irritations.Topical management of minor abrasions, minor cuts, minor lacerations and minor burns.Acceptance: Similar to both predicate and reference OTC indications, covering common minor wound types. Minor burns are explicitly included, aligning with the reference device, while the predicate mentioned "scalds." This is considered substantially equivalent.
    CompositionHydrophilic polymers and silver saltCarbopol ETD 2020, triethanolamine, proprietary silver hydrosol suspensionPurified water, Carbopol, glycerol, polyethylene oxide, polyvinyl alcohol, silver compoundAcceptance: While ingredients differ, the overall functional components (hydrophilic polymer, silver compound) are present, supporting a "substantially equivalent" determination based on performance and safety rather than identical formulation.
    MechanismHydrophilic polymer for maintaining high moisture content, ionic silver for reducing microorganism colonization within the dressing during shelf storage.Hydrophilic polymer for maintaining high moisture content, silver for reducing microorganism colonization within the dressing during shelf storage.Hydrophilic polymer for maintaining high moisture content, ionic silver for reducing microorganism colonization within the dressing during shelf storage.Acceptance: Matches predicate and reference mechanism of action.
    Antimicrobial AgentSilver compoundElement silverSilver compoundAcceptance: All use silver in some form as the antimicrobial agent.
    AppearanceSlightly cloudyClear to golden yellow translucent gelColorless to light yellow, transparent to slightly cloudyPerformance: Visually similar, within the range of established devices.
    pH ValueN/A6.5-8.05.0-7.5Performance: Within a physiologically appropriate range for topical applications, comparable to the reference device's range. Implicit acceptance is that it's within a safe and effective range.
    Silver ContentN/A24 ppm0.007%-0.012% w/w (which is approximately 70-120 ppm if density is 1g/mL)Performance: This is a key difference in concentration from the reference device, but the "substantial equivalence" is based on overall performance (e.g., antimicrobial effectiveness, biocompatibility, and non-inhibition of wound healing) rather than exact silver concentration matching.
    Moisture DonationN/AGreater than 5%≥10%Performance: Subject device meets or exceeds the reference device's performance for moisture donation. Implicit acceptance is that higher or comparable donation is favorable.
    Moisture AbsorptionN/AGreater than 5%preservative assurance testingUSP
    SterilizedN/ANot provided sterileSterileAcceptance: Provides sterility, which is an advantage over the reference device and aligns with the general expectations for wound care products for significant wounds (Rx).

    The document states: "Performance tests were conducted to demonstrate that the subject device is as effective as its predicate device." The "acceptance criteria" for these performance tests are implicitly met if the test results demonstrate comparable performance attributes to the predicate/reference devices, supporting the claim of substantial equivalence.

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

    The document does not detail specific sample sizes for the performance tests listed (Appearance, Fluid Affinity, Loss on Drying, pH Value, Preservative Effectiveness). These are typically bench tests or in vitro studies, not requiring human patient test sets.

    For the Animal Study (Porcine Wound Healing Study):

    • Sample Size: Not explicitly stated.
    • Data Provenance: Not explicitly stated (e.g., country or retrospective/prospective). This was an animal study, not human clinical data.

    For Clinical Studies:

    • Sample Size: "No clinical study was conducted."
    • Data Provenance: Not applicable, as no human clinical data was used for direct performance evaluation of this device.

    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 information is not applicable to this submission. The device is a wound care gel, not an AI or diagnostic medical device that requires expert adjudication for a test set. The efficacy (or non-inhibition of wound healing) was assessed in an animal model and through comparative performance testing.

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

    This information is not applicable. As mentioned above, this is not an AI/diagnostic device that relies on expert adjudication for ground truth.

    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. An MRMC study is relevant for AI/diagnostic imaging devices. This submission concerns a wound care gel.

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

    This information is not applicable. This question refers to AI algorithm performance.

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

    For the various performance tests (Appearance, Fluid Affinity, Loss on Drying, pH Value, Preservative Effectiveness):

    • Ground Truth: These properties are determined through standardized laboratory testing methods (e.g., EN 13726-1, USP , USP , USP ). The "ground truth" is the quantitative or qualitative result obtained from these validated methods.

    For the Biocompatibility Testing:

    • Ground Truth: Compliance with ISO 10993 standards. The "ground truth" is the biological response (or lack thereof) observed in standardized in vitro and in vivo biocompatibility tests, interpreted by toxicologists or biologists.

    For the Animal Study (Porcine Wound Healing Study):

    • Ground Truth: Histological and macroscopic assessment of wound healing, and observation for adverse biological reactions. This ground truth is established by veterinary pathologists or researchers.

    8. The sample size for the training set

    This information is not applicable. This device is not an AI algorithm and therefore does not have a "training set."

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

    This information is not applicable. As there is no training set for an AI algorithm, there is no ground truth established for it.

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