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510(k) Data Aggregation

    K Number
    K200452
    Device Name
    Meril-Bonewax
    Date Cleared
    2023-03-27

    (1127 days)

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

    MERIL - BONEWAX™ is intended to be used in the control of bleeding from bone surfaces during surgical operations.

    Device Description

    MERIL - BONE WAX™ is ivory white, intended to aid mechanically in the control of bleeding of bone injuries, whether attributable to trauma or surgical intervention. It is composed of refined beeswax with Iso propyl myristate added as softening agent, and is supplied sterile in thin sheets. It is opaque and has a waxy odor. It is available as 2 or 2.5gm bone wax per pack. MERIL - BONE WAX™ achieves local hemostasis of bone by acting as a mechanical (tamponade) barrier. It does not act biochemically and is nonabsorbable.

    AI/ML Overview

    This document, K200452, pertains to the FDA 510(k) premarket notification for MERIL-BONEWAX™. As a 510(k) submission, it aims to demonstrate substantial equivalence to a predicate device rather than providing extensive clinical study data that would be typical for a new device requiring a PMA.

    Therefore, the information regarding acceptance criteria and a study proving the device meets these criteria is limited to performance tests designed to establish substantial equivalence.

    Here's a breakdown of the available information based on your request:

    1. Table of Acceptance Criteria and Reported Device Performance

    This document does not provide a table of precise quantitative acceptance criteria with corresponding performance values for parameters like sensitivity, specificity, or quantifiable clinical outcomes. Instead, the acceptance criteria are generally qualitative or based on demonstrating equivalence to predicate devices and adherence to established standards.

    Acceptance Criteria CategoryDescription of Performance TestReported Performance / Outcome
    UsabilityKneadability TestDemonstrated device usability
    Spreadability TestDemonstrated device usability
    Hemostasis EffectivenessAnimal Performance Test (Porcine Model)Effective in control of bleeding from the bone surface
    BiocompatibilityTests according to ISO 10993-1Test results suggest the device is biocompatible
    SterilizationAssessed via ISO 11137-1:2006 and ISO 11137-2:2013Sterilization method (Gamma irradiation) is established as per standards
    Bacterial EndotoxinLimulus amebocyte lysate (LAL) test by Gel Clot TechniqueTest results met the specification of < 20 EU/Device
    Packaging & Shelf LifePackaging validation (ISO 11607), Shelf life validation (ICH Q1A (R2) & ISO 11607), Transportation Study (ASTM D 999 & ASTM D 5276)Ensured package integrity throughout the shelf life
    Substantial EquivalenceComparison to predicate devices regarding: Intended Use, Material composition, Mechanism of action, Physical Characteristics, Single use, Sterilization, Packaging, BiocompatibilityMERIL - BONE WAX™ is "substantially equivalent" and "as safe and as effective" as the predicate device

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

    The document does not specify exact sample sizes for the "kneadability and spreadability tests." For the "animal performance test," it mentions a "porcine model" but does not provide the number of animals used.

    • Test Set Sample Sizes: Not explicitly stated for non-animal tests. For the animal performance test, it indicates a "porcine model" without specifying the number of animals.
    • Data Provenance: Not explicitly stated whether the data is retrospective or prospective, or the country of origin. Given the submitter's address in Gujarat, India, and the use of ISO/ASTM standards, it's plausible the testing was conducted in India or by a contract research organization adhering to these international standards.

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

    This information is not provided in the document. The type of device (bone wax for hemostasis) and the nature of the preclinical tests (bench, animal model) for a 510(k) submission typically do not involve establishing ground truth through expert consensus on diagnostic images or clinical outcomes in the same way as, for example, an AI diagnostic device for radiology. The "ground truth" here is objective performance in mechanical tests, hemostatic efficacy in an animal model, and compliance with recognized standards.

    4. Adjudication Method for the Test Set

    Not applicable. The tests described (kneadability, spreadability, animal hemostasis, biocompatibility, sterilization, endotoxin, packaging) are objective measurements and do not typically involve human adjudication in the way clinical diagnostic studies might.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was Done

    No. An MRMC comparative effectiveness study is not mentioned. Such a study would be relevant for devices that involve human interpretation of medical data (e.g., radiologists reading images) and the impact of AI assistance. This device is a bone wax, which is a surgical aid, not a diagnostic or AI-driven interpretive tool.

    6. If a Standalone Performance Study (Algorithm Only Without Human-in-the-Loop Performance) was Done

    Yes, in essence, the preclinical tests described are "standalone" performance evaluations of the device itself (the bone wax) without human intervention in its function (beyond application in the animal model). The device is not an algorithm, so the term "algorithm only" does not apply. The performance tests evaluate the physical properties and biological interactions of the bone wax directly.

    7. The Type of Ground Truth Used

    The "ground truth" for the various tests mentioned typically refers to:

    • Objective measurements and observable outcomes: For kneadability, spreadability, hemostasis in the animal model (e.g., cessation of bleeding, time to hemostasis).
    • Established biological and chemical standards: For biocompatibility (ISO 10993-1), sterilization (ISO 11137), and bacterial endotoxin (ANSI/AAMI ST72:2019).
    • Engineering and packaging standards: For packaging and shelf life validation (ISO 11607, ICH Q1A (R2), ASTM D 999, ASTM D 5276).

    There is no mention of pathology, expert consensus on diagnostic interpretations, or long-term clinical outcomes/data as "ground truth" in this submission.

    8. The Sample Size for the Training Set

    Not applicable. This device is a physical medical device (bone wax), not an AI algorithm that requires a training set.

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

    Not applicable, as this device is not an AI algorithm and does not have a training set.

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