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510(k) Data Aggregation
(64 days)
Any gap in the ossicular chain caused by erosion of the incus.
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The provided text is a 510(k) submission for a medical device called the "Mills Sleeve Prosthesis," which is a middle ear prosthesis. This submission focuses on demonstrating substantial equivalence to a predicate device rather than presenting a de novo study with detailed acceptance criteria and performance metrics for a new AI/software device.
Therefore, many of the requested categories for describing an AI-driven study's acceptance criteria and performance cannot be extracted or are not applicable from the provided text. The document is from 1998, predating widespread AI in medical devices and the typical reporting standards for AI performance studies.
Here's an analysis based on the information provided, highlighting what is missing or not applicable:
1. A table of acceptance criteria and the reported device performance
- Not Applicable in the traditional sense for an AI device. The document does not present quantitative acceptance criteria or device performance metrics in the way an AI diagnostic tool would. Instead, it relies on the safety and effectiveness of the material (hydroxylapatite) and the design, as well as the manufacturer's attestation and the FDA's substantial equivalence determination.
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Not applicable. This document describes a physical medical device (a prosthesis), not a software or AI device that relies on a "test set" of data for performance evaluation. There's no mention of a test set, data provenance, or study design for performance. The "summary of safety & effectiveness" is a general statement based on prior experience with similar prostheses and materials.
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)
- Not applicable. No test set or ground truth establishment process is described. The "expertise" mentioned is that of R. P. Mills, MS, MPhil, FRCS, a Consultant ENT Surgeon, who affirms the device's safety and effectiveness based on his "many years' experience" and general knowledge of middle ear prostheses and materials. This is an expert opinion or attestation, not a ground truth establishment process for a performance study.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable. No test set or adjudication process is mentioned.
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 is a physical medical device, not an AI system designed to assist human readers.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not applicable. This is a physical medical device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- Not applicable. There is no "ground truth" established for a performance study in the context of an AI device. The safety and effectiveness are inferred from the known properties of the materials and the design based on existing knowledge and practice.
8. The sample size for the training set
- Not applicable. No training set is mentioned as this is not an AI device.
9. How the ground truth for the training set was established
- Not applicable. No training set is mentioned.
Summary of what can be extracted or inferred from the provided text regarding device acceptance and study (though not in the AI/software context):
- Device: Mills Sleeve Prosthesis
- Intended Use: "Any gap in the ossicular chain caused by erosion of the incus."
- Basis for Acceptance:
- Prior Experience: "Based on previous experience of middle ear prostheses, there is no reason to believe that the proposed prosthesis... will have any detrimental effect."
- Material Safety: "The available data indicate that hydroxylapatite does not alter with time in any way that might have an adverse effect on the patient or on the efficiency of the reconstruction."
- Fail-safe mechanism (implied): "Should the reconstruction fail, it is likely that the prosthesis would be extruded from the ear without causing any harm."
- Expert Attestation: A Consultant ENT Surgeon (R. P. Mills, MS, MPhil, FRCS) attests that the device "will be completely safe and effective in use."
- FDA Substantial Equivalence: The FDA determined the device is "substantially equivalent" to legally marketed predicate devices, meaning it has the same intended use, technological characteristics, and safety and effectiveness concerns as a device already on the market. This is the primary "acceptance criterion" for this type of submission.
Therefore, the "study" proving the device met "acceptance criteria" here is primarily the argument for substantial equivalence presented in the 510(k) submission, supported by expert opinion and general knowledge about the device's materials and design, rather than a clinical trial or performance study typical for an AI device.
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