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510(k) Data Aggregation

    K Number
    DEN210049
    Date Cleared
    2024-03-27

    (890 days)

    Product Code
    Regulation Number
    878.4795
    Type
    Direct
    Reference & Predicate Devices
    N/A
    Why did this record match?
    Device Name :

    Medline ART Skin Harvesting System

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

    The ART (Autologous Regeneration of Tissue) Skin Harvesting System is intended for the harvesting and application of autologous, full thickness micrografts for wounds where autologous skin grafting would be appropriate.

    Device Description

    The device is a handheld surgical skin tissue harvesting system that uses an array of coring needles to acquire full thickness skin tissue columns (hereafter referred to as "micrografts" or "microcolumns") from an appropriate healthy donor site for deposition onto an appropriate recipient treatment site (Figure 1). The procedure is minimally invasive and both the tissue acquisition (i.e., "harvest") and deposition (i.e., "scatter") processes are automatically performed by a handheld device as described below.

    The device consists of three components: (1) a non-sterile, reusable handheld device; (2) a sterile, single-patient use needle cartridge containing the needle array for harvesting skin micrografts from the patient donor site; and (3) a sterile, single-patient use handheld protective sleeve to cover the handheld device (Figure 2). The handheld device uses embedded software to control the operation of the cartridge using user-activated tactile buttons and trigger (Figure 3). The sterile sleeve protects the handheld device from soilage and provides a physical barrier between the non-sterile handheld device and the patient.

    AI/ML Overview

    The provided text describes the Medline ART Skin Harvesting System, a semi-automated device for autologous skin grafting. The document details the device's description, non-clinical/bench studies, animal wound healing studies, human factors/usability testing, and limited clinical information. It also outlines the risks to health and proposed mitigation measures.

    However, the provided text does not contain explicit acceptance criteria tables or a structured comparative effectiveness study (MRMC) with human readers improving with AI vs. without AI assistance. The evaluation of the device's performance is primarily based on bench testing, animal studies, usability studies, and limited human clinical observations. The core of the evaluation focuses on the device's mechanical function, biocompatibility, sterility, software integrity, electrical safety, and its ability to facilitate wound healing compared to untreated wounds and, to some extent, traditional STSG.

    Therefore, the following response compiles the available information in the format requested, making it clear where specific details (like acceptance criteria tables or MRMC study details) are not explicitly present in the provided document.


    Acceptance Criteria and Device Performance Study for Medline ART Skin Harvesting System

    The provided documentation focuses on a De Novo classification request for the Medline ART Skin Harvesting System. The evaluation of this device is primarily based on demonstrating its safety and effectiveness through various non-clinical (bench, animal) and limited clinical studies, rather than a quantifiable AI-driven performance assessment against explicit numerical acceptance criteria for diagnostic accuracy.

    The document does not explicitly provide a formal table of "acceptance criteria" for the device's performance as if it were an AI diagnostic algorithm. Instead, it outlines performance characteristics that were tested and the results of those tests, demonstrating the device's functionality and safety. The "acceptance criteria" are implied by the successful completion of these tests and their favorable outcomes compared to controls (untreated wounds) or, in some cases, a standard of care (STSG).

    Here's a synthesis of the implicit acceptance criteria and the reported device performance based on the provided text:

    1. Table of Acceptance Criteria (Implicit) and Reported Device Performance

    Acceptance Criteria (Implicit from Study Objectives)Reported Device Performance (Summary)
    Biocompatibility: Patient-contacting components are non-toxic, non-sensitizing, non-irritating, and hemocompatible.Demonstrated to be biocompatible through ISO 10993 series and ASTM F756-13 testing.
    Sterility & Shelf Life: Single-patient use components maintain sterility and integrity over shelf life.Cartridge and sleeve sterilized via gamma radiation to SAL of 10-6. Shelf-life verified to be 1 year.
    Software Functionality & Safety: Software controls device operation safely and as specified; no cybersecurity risks.Software operates as described; hazard analysis characterized risks; V&V testing satisfactory; no cybersecurity risks identified.
    Electrical Safety & EMC: Device operates safely in intended environments; no interference with other devices.Compliant with IEC 60601-1, IEC 62366-1, and IEC 60601-1-2 (4th Ed.) standards. Warning labels for active implanted medical devices.
    Mechanical Performance (Design Verification): Proper setup, visual/dimensional specs met, harvest duration within spec, no excessive particulate shedding, proper door function, cartridge performs for 3+ cycles.All criteria met. Handheld unit functions for at least 1,000 collection and scatter cycles (durability).
    Tissue Harvesting & Deposition: Ability to extract full thickness tissue to intended depth without damage and deposit at recipient site.Demonstrated in animal studies (porcine model) to harvest microcolumns and scatter onto recipient sites. In human studies, deposition of at least 50% of micrografts per harvest/deposition cycle was observed.
    Donor Site Healing: Comparable or improved healing of donor sites compared to STSG.Improved healing: ART donor sites healed at an accelerated rate compared to STSG. Day 4: 61% ART R-E 25-75% vs. 26% STSG (P=0.0395). Day 7: 73% ART R-E 75-100% vs. 33% STSG (P=0.0014). Both reached 75-100% R-E by Day 28. Histologically, ART sites showed better organized collagen and less irritation.
    Recipient Site Healing: Effective wound healing (re-epithelialization) compared to untreated sites and STSG.Equivalent healing to STSG over time, faster than untreated: Complete re-epithelialization by Day 35 for ART and STSG; untreated only 58% by Day 35. STSG showed faster initial re-epithelialization (Day 28: 92% STSG R-E 5, 67% ART R-E 5). Less necrotic tissue/sloughing in ART than STSG (Day 7: 14% ART vs. 72% STSG; Day 14: 0% ART vs. 39% STSG). More wound contracture in ART than STSG.
    User Performance (Human Factors): Users can safely and effectively use the device with training and manual.Simulated use studies (18 HCPs / 15 medical professionals) showed >95% (Study 1) and 97.5% (Study 2) success rates for critical tasks. Risks from poor donor site selection or device jams mitigated by training.

    2. Sample Size and Data Provenance

    • Animal Study:
      • Sample Size: 18 female Yorkshire pigs. Each pig had 6 full thickness wounds created (3 wounds per side), for a total of 108 wounds.
      • Data Provenance: Prospective animal study (porcine model). Location not specified beyond "full thickness porcine wound healing study."
    • Clinical Studies (Supplemental/Confirmatory):
      • Study 1 (Early version): 25 patients (23 completed).
      • Study 2 (Early version): 12 patients (11 completed).
      • Study 3 (Final finished device - NCT05076578):
        • Group A: 10 healthy volunteers (tissue acquisition only).
        • Group B: 10 subjects with chronic wounds.
      • Data Provenance: Retrospective for Study 1 & 2 (early device version, "confirmatory information"). Prospective for Study 3 (final device, limited clinical data, "confirmatory information"). Country of origin for clinical data is not specified.

    3. Number of Experts and Qualifications for Ground Truth

    • Animal Study: The document refers to "scores" for erythema, edema, re-epithelialization, wound contracture, fluid/exudate, slough/necrosis, and other observations. These scores were likely assigned by trained personnel (e.g., veterinarians, researchers). Histological evaluations were also performed. No specific number or qualifications of "experts" are provided for establishing ground truth in the animal study, but the methodology implies trained observation.
    • Human Factors/Usability Testing: The "experts" in this context are the users being tested.
      • Study 1: 18 nurse or doctor (HCPs) users.
      • Study 2: 7 physicians and 8 surgical podiatrists.
      • Their "ground truth" is their ability to perform tasks correctly based on training and the manual.
    • Clinical Studies: For human clinical studies, "complete re-epithelialization" and "percentage area reduction (PAR)" were used as metrics of wound healing. These were likely assessed by the study investigators/clinicians. No specific number or qualifications of experts establishing ground truth for clinical outcomes are provided beyond being "investigators."

    4. Adjudication Method for the Test Set

    • Animal Study: Not explicitly stated, but the "internal scale" for scoring suggests a standardized, single-observer or consensus method. Numerical data and statistical comparisons are reported.
    • Human Factors/Usability Testing: Success rates for tasks were recorded. No explicit multi-rater adjudication method is described.
    • Clinical Studies: Clinical outcomes (re-epithelialization, PAR) were measured. No specific adjudication method across multiple evaluators is mentioned.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    • No MRMC comparative effectiveness study was done or described. The device is a surgical instrument, not an AI-based diagnostic tool that assists human readers in interpreting images. Therefore, the concept of "effect size of how much human readers improve with AI vs. without AI assistance" is not applicable to this submission.

    6. Standalone (Algorithm Only Without Human-in-the-Loop) Performance

    • Not applicable in the context of an AI-driven algorithm. The device itself is a semi-automated surgical tool. Its "standalone performance" is best represented by the effectiveness of the tissue harvesting and deposition process as demonstrated in bench and animal studies (e.g., ability to extract tissue to depth, deposit tissue). The human user remains "in the loop" by controlling the device activation and placement.

    7. Type of Ground Truth Used

    • Animal Study: Ground truth for donor and recipient site healing was established through a combination of:
      • Macroscopic Visual Scoring: (blinded or unblinded, not specified) for erythema, edema, re-epithelialization, wound contracture, fluid/exudate, slough/necrosis based on an internal scale.
      • Measurements: Wound cross-sectional diameters, circumferences, and contracture normalized to Day -2.
      • Histology: Microscopic examination of tissue samples from donor and recipient sites.
    • Human Factors/Usability Testing: The ground truth for usability was the successful completion of pre-defined critical tasks performed by users following instructions.
    • Clinical Studies: Ground truth for wound healing was based on:
      • Clinical Observation/Measurement: Complete re-epithelialization (visual confirmation), Percentage Area Reduction (PAR) of wounds, and observation of adverse events.

    8. Sample Size for the Training Set

    • Not applicable as a traditional "training set" for an AI algorithm. This is a hardware device with embedded software. The software "training" would be its development and testing phases, which are not detailed in terms of "sample size" in the same way as an AI model.
    • The "development" for the device's functionality would be encompassed in the design verification, durability, and performance testing, which utilized various samples (e.g., cadaver legs for durability, porcine model for performance).

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

    • Not applicable as a traditional "training set" for an AI algorithm. The "ground truth" for the device's design and software capabilities would be derived from engineering specifications and objective performance requirements validated through a rigorous design control process, including bench testing, and animal studies used to refine the device's mechanical and software functions. The provided text outlines these extensive verification and validation efforts.
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