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510(k) Data Aggregation
(195 days)
MAXIFLEX FIBER OPTIC ENERGY DELIVERY SYSTEM
The MaxiFlex - Fiberoptic Energy Delivery System is designed to deliver lase energy to perform: general surgical, dermatological, intraoral soft tissue, orthopaedic, maxillo-facial, and cosmetic surgery. The MaxiFlex fiber is intended for energy delivery for ablating, incising, excising, vaporization and coagulation of soft tissues within the medical/surgical specialties noted above using a contact fiber optic based laser system.
The device is suitable for use for all applications for which the laser output unit is cleared, including: general and cosmetic surgery, intraoral soft-tissue, otolaryngology, arthroscopy, gastroenterology, general surgery, dermatology & plastic surgery, neurosurgery, gynecology, urology, ophthalmology and pulmonary surgery.
The delivery fiber cables, consist of multi-mode, single core optical fibers available in 200, 400, and 1000um diameters. The standard SMA 905 fiber connector terminates one end of the delivery fiber, which is attached to the SMA union at the rear panel of the laser box. The fiber is stripped of its protective jacket in accordance with the laser manufacturers instructions and is cleaved to provide laser radiation output.
Here's an analysis of the provided text regarding the acceptance criteria and study for the MaxiFlex Fiberoptic Energy Delivery System:
This document is a 510(k) premarket notification for a medical device seeking substantial equivalence to already legally marketed devices. It's important to understand that 510(k) submissions generally do not involve new clinical studies or elaborate performance testing to establish novel acceptance criteria. Instead, they demonstrate that a new device is as safe and effective as a predicate device through comparison of features, materials, and intended use.
Therefore, the concept of "acceptance criteria" in this context is primarily about demonstrating that the MaxiFlex Fiberoptic Energy Delivery System's features, functional specifications, and intended uses are substantially equivalent to those of the identified predicate devices without raising new questions of safety or effectiveness. The "study" proving this is essentially the comparative analysis presented in the document itself.
Here's the breakdown based on your request:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria (Demonstrated Equivalence to Predicate Devices) | Reported Device Performance (MaxiFlex Fiberoptic Energy Delivery System) |
---|---|
Type of laser compatibility: Compatible with various surgical laser types (e.g., Diode, crystal fiber-optic based lasers, any surgical laser equipment fitted with an SMA 905 connector, Nd:YAG, HO:YAG or Argon). | Diode & crystal fiber-optic based lasers. Implicitly compatible with SMA 905 connector lasers due to connector type. |
Wavelength range: Ability to deliver energy across relevant surgical laser wavelengths (e.g., 532-1400 nm, 532-1054 nm). | 532-2100 nm. (Broader range than predicate devices, which implies equivalence or improvement within relevant spectrum). |
Maximum output power: Capable of handling relevant maximum laser output powers (e.g., 100 Watts, 60 Watts). | 100 Watts. (Matches or exceeds predicate device capabilities). |
Operation mode: Supports common laser operation modes (Continuous wave and pulsed). | Continuous wave and pulsed. (Matches predicate device capabilities). |
Delivery system (fiber core sizes): Offers fiber core sizes suitable for surgical applications (e.g., 200, 400, 600, 800, 1000 um core quartz fiber). | Multi-mode 200, 400, 600 and 1000 um core quartz fiber. (Offers comparable range to predicate devices, including all listed sizes from the predicates). |
Sterility: User sterilized via steam at specific parameters (270°/10min. exposure). | User sterilized - Steam - 270°/10min. exposure. (Matches predicate device method). |
Connector Type: Standardized connector for laser systems (SMA 905 connector). | SMA 905 connector. (Matches predicate device connector type). |
Intended Use and Indications for Use: Broad application in various medical/surgical specialties for tissue ablation, incision, excision, vaporization, and coagulation. | Designed to deliver laser energy to perform: general surgical, dermatological, intraoral soft tissue, orthopaedic, maxillo-facial, and cosmetic surgery. |
Intended for energy delivery for ablating, incising, excising, vaporization and coagulation of soft tissues within the medical/surgical specialties noted above using a contact fiber optic based laser system. | |
Suitable for use for all applications for which the laser output unit is cleared, including: general and cosmetic surgery, intraoral soft-tissue, otolaryngology, arthroscopy, gastroenterology, general surgery, dermatology & plastic surgery, neurosurgery, gynecology, urology, ophthalmology and pulmonary surgery. (Demonstrates substantially equivalent and, in some cases, broader indications than predicate devices). |
Study Proving Acceptance Criteria:
The "study" presented here is a premarket notification (510(k)) submission's comparative analysis for substantial equivalence. It does not involve a traditional clinical efficacy study with quantitative patient outcomes.
2. Sample Size Used for the Test Set and Data Provenance
- Test Set Sample Size: Not applicable in the context of a 510(k) substantial equivalence submission for this type of device. There isn't a "test set" of patient data in the sense of a clinical trial. The "test" is the comparison of the new device's specifications and intended use against those of legally marketed predicate devices.
- Data Provenance: The data provenance comes from the publicly available specifications and intended uses of three predicate devices: StrateFire, InnovaQuartz, and one labeled "SE?". These are legally marketed devices in the United States. The data about the MaxiFlex device is provided by the manufacturer (Technology Delivery Systems, Inc.). This is a retrospective comparison against existing device information.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
- Number of Experts: Not explicitly stated or applicable in the traditional sense. The "ground truth" for a 510(k) comparison is regulatory clearance of the predicate devices and the technical specifications provided by their manufacturers (and the applicant for the new device). FDA reviewers (medical officers, engineers, etc.) with relevant expertise are the ones who assess the substantial equivalence.
- Qualifications of Experts: FDA scientific and regulatory staff are the "experts" who determine if the device is substantially equivalent to predicates based on the provided technical and descriptive information. Their qualifications would include relevant scientific and medical backgrounds (e.g., engineering, medical physics, clinical specialties).
4. Adjudication Method for the Test Set
- Adjudication Method: Not applicable. There is no qualitative assessment of a test set by multiple experts requiring adjudication. The comparison is based on objective technical specifications and intended uses as detailed in the submission. The FDA makes the final determination of substantial equivalence.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
- MRMC Study: No, an MRMC comparative effectiveness study was not done. This type of study is typically performed to assess human reader performance (e.g., radiologists interpreting images) with and without AI assistance, which is not relevant for a surgical fiberoptic energy delivery system in a 510(k) submission.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
- Standalone Performance Study: No, a standalone performance study (algorithm only) was not done. This device is a physical instrument (fiberoptic cable) for delivering laser energy, not an algorithm or AI system.
7. The Type of Ground Truth Used
- Type of Ground Truth: The ground truth used here is the established regulatory clearance and publicly available specifications/intended uses of the predicate devices. The manufacturer of the MaxiFlex device asserts that its device is equivalent to these legally marketed devices in terms of its characteristics and intended applications. The FDA then verifies this assertion based on the submitted documentation.
8. The Sample Size for the Training Set
- Training Set Sample Size: Not applicable. As this is not an AI/machine learning device, there is no "training set" in that context. If interpreted as internal testing data for the MaxiFlex fiber itself, this document does not specify any sample sizes for design verification or validation testing. A 510(k) relies on comparison to predicates and adherence to recognized standards, rather than new extensive clinical trials for devices of this nature.
9. How the Ground Truth for the Training Set Was Established
- Ground Truth for Training Set: Not applicable, as there is no "training set" for an AI/ML algorithm involved. For the predicate devices, their "ground truth" (i.e., their safety and effectiveness) was established through their own regulatory clearance processes, which might have involved different types of testing or comparisons depending on their original classification and pathway to market.
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