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PALACOS® R pro is indicated for use in arthroplastic procedures of the hip, knee, and other joints for the fixation of polymer or metallic prosthetic implants to living bone.
PALACOS® R+G pro is indicated for use in the second stage revision for total joint arthroplasty after the initial infection has been cleared.
PALACOS® MV+G pro is indicated for use in the second stage revision for total joint arthroplasty after the initial infection has been cleared.

PALACOS® R pro is a standard-setting, high-viscosity, radiopaque, poly(methyl methacrylate)-based (PMMA) bone cement, pre-filled into a mixing and application system, suitable for use with or without vacuum (ready to mix). It contains the X-ray contrast medium zirconium dioxide. To improve visibility in the surgical field, it has been colored with chlorophyll-copper-complex (E141). The bone cement consists of two components and is prepared immediately before use by mixing the polymer powder (= powder) with the monomer liquid (= liquid). A ductile dough forms that sets within a few minutes.
PALACOS® R+G pro is a standard-setting, high-viscosity, radiopaque, poly(methyl methacrylate)-based (PMMA) bone cement, pre-filled into a mixing and application system, suitable for use with or without vacuum (ready to mix). It contains the aminoglycoside antibiotic gentamicin to protect the cured bone cement and contiguous tissue against colonization by bacteria that are sensitive to gentamicin. It contains the X-ray contrast medium dioxide. To improve visibility in the surgical field, it has been colored with chlorophyll-copper-complex (E141). The bone cement consists of two components and is prepared immediately before use by mixing the polymer powder (= powder) with the monomer liquid (= liquid). A ductile dough forms that sets within a few minutes.
PALACOS® MV+G pro is a standard-setting, medium viscosity, radiopaque, poly(methyl methacrylate)-based (PMMA) bone cement, pre-filled into a mixing and application system, suitable for use with or without vacuum (ready to mix). It contains the aminoglycoside antibiotic gentamicin to protect the cured bone cement and contiguous tissue against colonization by bacteria that are sensitive to gentamicin. It contains the X-ray contrast medium zirconium dioxide. To improve visibility in the surgical field, it has been colored with chlorophyll-copper-complex (E141). The bone cement consists of two components and is prepared immediately before use by mixing the polymer powder (= powder) with the monomer liquid). A ductile dough forms that sets within a few minutes.

This FDA 510(k) Premarket Notification is for PALACOS® R pro, PALACOS® R+G pro, and PALACOS® MV+G pro bone cements. It does not describe an AI/ML device, a clinical study with human readers, or a ground truth established by experts. Instead, it focuses on demonstrating substantial equivalence to previously cleared predicate devices through non-clinical performance testing.

Here's a breakdown based on the provided document:

1. A table of acceptance criteria and the reported device performance

The document does not present a formal table of acceptance criteria with reported numerical performance values in the way you might expect for an AI device (e.g., sensitivity, specificity, AUC). Instead, it states that the devices meet existing industry standards and guidance documents. The "acceptance criteria" are implied by adherence to these standards, and the "reported performance" is that the devices meet them.

• Concluded that possible transfer of leachables is low.
• Cytotoxicity test performed to support this conclusion.
• No negative impact estimated from changes. |
  | Mechanical & Functional | FDA Guidance document Class II Special Controls Guidance Document: Polymethylmethacrylate (PMMA) Bone Cement - Guidance for Industry and FDA (July 17, 2002) (Annex I and Annex II) | - Tests conducted to demonstrate intended function, safety, and effectiveness.
• Data provided to state substantial equivalence to predicate device. |
  | Sterilization | ISO 11135 | - Validation performed using ethylene oxide gassing.
• Cycle designed for sterile units with a sterility assurance level (SAL) of 10⁻⁶.
• Chosen sterilization process considered valid, showing equivalence to predicate device. |
  | Pyrogenicity | ANSI/AAMI ST72 (LAL test) | - Subject device meets endotoxin limit specification of ≤ 20 EU/device.
• Shows equivalence to predicate device. |

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

This document details non-clinical laboratory testing, not a test set of patient data. Therefore, the concepts of "sample size used for the test set" and "data provenance (country of origin, retrospective/prospective)" as they relate to patient data or imagery do not apply. The testing was conducted in a laboratory setting, likely in Germany where the manufacturer is located, or by authorized testing facilities.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

Not applicable. The ground truth for this type of device (bone cement) is not established by human experts in the context of medical image interpretation. The "truth" is determined by established physical, chemical, and biological testing standards and measurements.

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

Not applicable. There is no human adjudication process described, as the testing is based on objective laboratory measurements against defined standards.

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 not an AI-assisted device.

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

Not applicable. This is not an algorithm.

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

The "ground truth" for this submission is based on:

• Established objective standards: International Standards (e.g., ISO 10993-1, ISO 11135, ANSI/AAMI ST72) and FDA Guidance documents (e.g., "Class II Special Controls Guidance Document: Polymethylmethacrylate (PMMA) Bone Cement").
• Laboratory measurements: Results from specific tests (cytotoxicity, mechanical property measurements, sterility assurance level determination, LAL test for endotoxins) designed to objectively evaluate the device's conformance to these standards and demonstrate substantial equivalence to predicate devices.
• Chemical and material analysis: Confirmation of identical (or acceptably different) chemical composition and materials compared to predicate devices.

8. The sample size for the training set

Not applicable. This is not a machine learning device and therefore does not have a "training set" in that context.

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

Not applicable. As above, there is no "training set" for this type of device.

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PALACOS® R is indicated for use in arthroplastic procedures of the hip, knee, and other joints for the fixation of polymer or metallic prosthetic implants to living bone.

PALACOS® R pro is indicated for use in arthroplastic procedures of the hip, knee, and other joints for the fixation of polymer or metallic prosthetic implants to living bone.

PALACOS® R+G is indicated for use in the second stage of a two-stage revision for total joint arthroplasty after the initial infection has been cleared.

PALACOS® R+G pro is indicated for use in the second stage revision for total joint arthroplasty after the initial infection has been cleared.

PALACOS® MV+G is indicated for use in the second stage revision for total joint arthroplasty after the initial infection has been cleared.

A bundled Traditional 510(k) submission is being supplied to the U.S. FDA to gain clearance for modifications to PALACOS® R, PALACOS® R pro, PALACOS® R+G, PALACOS® R+G pro, and PALACOS® MV+G previously cleared in K030902, K150119, K031673, K142157 and K050855.

Modifications include changes of instructions for use (IFU) and labels as well as the addition of MRI safety information.

This submission encompasses multiple devices that have similar intended use and indications for use as well as rely on similar data.

PALACOS® bone cements without Gentamicin:
PALACOS® R and PALACOS® R pro are polymethylmethacrylate (PMMA) bone cements.
PALACOS® R: is a standard-setting, high-viscosity, PMMA-based bone cement for orthopaedic surgery.
PALACOS® R pro: is a PMMA based PALACOS® R bone cement, packed in a closed mixing and application system ready for processing (ready-to-mix).
The bone cements consist of two components, a monomer liquid and a polymer powder. The liquid component contains the monomer, accelerator, and a stabilizer. The powder contains the polymer, X-Ray-opacifier, and initiator. They are intended for single-use and are provided sterile (ethylene oxide and sterile filtration).

PALACOS® bone cements with Gentamicin:
PALACOS® R+G, PALACOS® R+G pro and PALACOS® MV+G are PMMA bone cements, containing the antibiotic Gentamicin.
PALACOS® R+G (previously cleared under the name PALACOS® G); is a standard-setting. high-viscosity, PMMA-based bone cement for orthopaedic surgery.
PALACOS® R+G pro is a PMMA based PALACOS® R+G bone cement, packed in a closed mixing and application system ready for processing (ready-to-mix) and
PALACOS® MV+G (previously cleared under the name PALAMED G) is a standard-setting, medium-viscosity, radiopaque, poly(methyl methacrylate)-based bone cement for orthopaedic surgery.
The bone cements consist of two components, a monomer liquid and a polymer powder. The liquid component contains the monomer, accelerator, and a stabilizer. The powder contains the polymer, X-Ray-opacifier, initiator and the antibiotic Gentamicin. They are intended for single-use and are provided sterile (ethylene oxide and sterile filtration).

The provided document is a 510(k) premarket notification for PMMA bone cements (PALACOS® R, PALACOS® R pro, PALACOS® R+G, PALACOS® R+G pro, and PALACOS® MV+G). This type of submission focuses on demonstrating substantial equivalence to a predicate device rather than establishing new acceptance criteria or conducting a clinical study to prove device performance against specific metrics.

Therefore, the document does not contain the information requested regarding acceptance criteria, a study proving the device meets those criteria, sample sizes for test/training sets, data provenance, number or qualifications of experts for ground truth, adjudication methods, MRMC studies, standalone performance studies, or how ground truth was established for training sets.

Instead, the document states:

"A risk-based assessment was performed as per DIN EN ISO 14971 to evaluate the impact of the modifications to the labelling... The modified IFUs do not alter the previously validated packaging or sterilization data as well as the existing results of non-clinical performance testing and biocompatibility in accordance with the FDA Class II Special Controls Guidance Document 'PMMA Bone Cement'. The risk-based assessment concludes that the IFU changes do not significantly affect the device's risk profile because no new risks or significantly modified existing risks are identifically based rationale has been prepared to designate the bone cements as "MR Safe"."

And, for each device: "No clinical testing... has been conducted."

The substantial equivalence determination is based on a comparison of technological characteristics with predicate devices, confirming that the subject devices are modified versions with no significant changes to their safety or effectiveness.

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PALACOS® R pro is intended for use in arthroplastic procedures of the hip, knee, and other joints for the fixation of polymer or metallic prosthetic implants to living bone.

PALACOS® R pro is an acrylic bone cement for use in orthopedic surgery. It is formed from powder and liquid by exothermic polymerization. It secures the fixation of the grafted artificial joint improving the transfer of forces at the interface implant - bone. The bone cement powder and liquid of PALACOS® R pro are pre-packed in a vacuum mixing and application system. This reduces the user steps and processing time during mixing of the bone cement. It also decreases the exposure to monomer fumes. PALACOS® R pro is available in one size: 75 g and is for single use. The PALACOS® R pro device includes: The mixing and application device pre-packed with the bone cement powder One ampoule of monomer liquid pre-packed in a monomer cartridge Accessories: a nozzle, a femur pressurizer, a vacuum sealed vacuum tube and in a separate box, an adaptor ring for the use with bone cement gun.

The provided document is a 510(k) summary for a medical device called PALACOS® R pro, a PMMA bone cement. It is a submission to the FDA for market clearance, asserting substantial equivalence to a predicate device. The information details non-clinical testing performed to demonstrate this equivalence, rather than a clinical study with acceptance criteria for device performance in human patients.

Therefore, many of the requested categories for acceptance criteria and study details are not directly applicable within the context of this document, as it focuses on demonstrating bio-mechanical and material equivalence to an already approved device.

Here's an attempt to address your request based on the provided text, noting where information is not available or not applicable:

1. Table of Acceptance Criteria and Reported Device Performance

The acceptance criteria here are derived from the standards and tests applied to the predicate device and the reference device. The "reported device performance" indicates that PALACOS® R pro (or its relevant precursors) met these criteria, supporting substantial equivalence.

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

The document does not provide specific sample sizes for the individual non-clinical tests (e.g., number of specimens for compressive strength testing). It states that the tests were performed "per ISO 5833" and "per ISO 10993," which would implicitly define testing protocols and sample sizes within those standards.

• Test set sample size: Not explicitly stated for each test, but implied by adherence to ISO standards.
• Data Provenance: The manufacturer, Heraeus Medical GmbH, is located in Wehrheim, Germany. The tests appear to be conducted as part of the product development and regulatory submission process, which is inherently prospective for demonstrating compliance. The data refers to non-clinical laboratory testing.

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

This concept is not applicable here. The "ground truth" for these tests are the established parameters and thresholds defined by international standards (ISO 5833, ISO 11135, ISO 10993) for bone cement properties and sterilization/biocompatibility. These are objective measurements, not subjective expert assessments.

4. Adjudication Method for the Test Set

Not applicable. Adjudication methods (like 2+1, 3+1) are typically used for reconciling differing expert opinions in clinical ground truth establishment. Here, the "truth" is determined by direct physical and chemical measurements against defined standard limits.

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

No, this was not done. MRMC studies are associated with evaluating diagnostic imaging devices where human readers interpret results, often to assess AI's impact on reader performance. This document concerns a bone cement, which is a therapeutic device, not a diagnostic one.

6. If a Standalone (algorithm only without human-in-the-loop performance) was done

Not applicable. This device is a bone cement, a material used in surgery, not an algorithm.

7. The Type of Ground Truth Used

The "ground truth" for the non-clinical tests is based on established international standards and measurement methodologies for material properties, sterilization efficacy, and biocompatibility. For instance, compressive strength has a defined physical measurement and an acceptable range per ISO 5833.

8. The Sample Size for the Training Set

Not applicable. This device is a material product, not an AI/machine learning algorithm that requires a training set.

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

Not applicable for the same reason as point 8.

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PALACOS® R+G pro is indicated for use in the second stage revision for total joint arthroplasty after the initial infection has been cleared.

PALACOS® R+G pro is an acrylic bone cement for use in orthopedic surgery. It is formed from powder and liquid by exothermic polymerization. It secures the fixation of the grafted artificial joint improving the transfer of forces at the interface implant - bone. The bone cement powder and liquid of PALACOS® R+G pro are pre-packed in a vacuum mixing and application system. This reduces the user steps and processing time during mixing of the bone cement. It also decreases the exposure to monomer fumes. PALACOS® R+G pro is available in one size: 75 g and is for single use. The PALACOS® R+G pro device includes: The mixing and application device pre-packed with the bone cement powder One ampoule of monomer liquid pre-packed in a monomer cartridge Accessories: a nozzle, a femur pressurizer, a vacuum sealed vacuum tube and in a separate box, an adaptor ring for the use with bone cement gun

Based on the provided text, the device is PALACOS® R+G pro, a radiopaque bone cement with gentamicin. This document is a 510(k) summary for its premarket notification.

Here's the breakdown of the acceptance criteria and the study information:

1. Table of acceptance criteria and the reported device performance

The document does not explicitly state "acceptance criteria" in a quantitative format as would be seen for diagnostic performance metrics (e.g., sensitivity, specificity, AUC). Instead, it describes a series of nonclinical tests performed according to international standards (ISO standards) to demonstrate that the PALACOS® R+G pro is substantially equivalent to a legally marketed predicate device (PALACOS® R+G, K031673). The reported device performance is that it characterized per ISO 5833, measured according to Dynstat test method, validated per ISO 11135, and performed per ISO 10993. The conclusion is that it is "substantial equivalent to PALACOS® R+G."

Given the nature of this medical device (bone cement), the "acceptance criteria" are implied by compliance with these standards and the demonstration of substantial equivalence.

2. Sample size used for the test set and the data provenance

The document indicates that nonclinical tests were performed. No specific sample sizes for these tests (e.g., number of test specimens for mechanical strength) are detailed in this summary. The data provenance is from Heraeus Medical GmbH, Germany. The tests are inherently prospective as they are conducted specifically for the purpose of demonstrating equivalence for this new product.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

This question is not applicable. The device is a bone cement, not a diagnostic or AI device that requires expert adjudication for ground truth establishing. The "ground truth" for this device's performance is established through physical and biological testing against established standards, not expert consensus on medical images or clinical outcomes.

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

This question is not applicable for the same reasons as point 3. Testing of physical properties and biocompatibility does not involve human adjudication in the described manner.

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 question is not applicable. The device is a bone cement, not an AI or diagnostic tool. No MRMC study was performed or is relevant for this device.

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

This question is not applicable. The device is a bone cement, not an algorithm.

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

For a bone cement, the "ground truth" for its performance and safety is established through:

• Compliance with international standards: ISO 5833 for mechanical properties, ISO 11135 for sterilization, and ISO 10993 for biocompatibility.
• Physical and chemical characterization: Direct measurements of properties like stability, temperature, setting time, strength, etc.

8. The sample size for the training set

This question is not applicable. There is no concept of a "training set" for a physical medical device like bone cement. The manufacturing process and formulation are developed, and then the final product is tested against standards.

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

This question is not applicable for the same reason as point 8.

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Palacos® G with gentamicin is indicated for use as bone cement in arthroplasty procedures of the hip, knee and other joints to fix plastic and metal prosthetic parts to living bone when reconstruction is necessary because of revision of previous arthroplasty procedures due to joint infection. The cement is intended for use to affix a new prosthesis in the second phase of a two-stage revision after the initial infection has been cleared.

Palacos® G (with gentamicin) is a fast setting polymer (polymethylmethacrylate) bone cement. Mixing the two sterile components, consisting of a powder and a liquid, initially produces a paste, which is used to anchor the prosthesis or to fill an anatomical cavity. The hardened bone cement allows stable fixation of the prosthesis and transfers stresses produced on movement to the bone via the large interface. Insoluble zirconium (IV) oxide is included in the cement powder as an x-ray contrast medium. The chlorophyll additive serves as optical marking of the bone cement at the site of the operation. The gentamicin component is a broad-spectrum antibiotic.

The provided text is a 510(k) Summary of Safety and Effectiveness for the Palacos® G Bone Cement with Gentamicin. It describes a medical device, and 510(k) submissions typically focus on demonstrating substantial equivalence to a predicate device rather than presenting detailed acceptance criteria and studies in the way one might for a novel AI/software device.

Based on the information provided, it's clear that this is not a study of a software or AI device, but rather a submission for a medical device (bone cement) under the 510(k) pathway, which emphasizes substantial equivalence. Therefore, many of the requested categories (like sample sizes for test/training sets, expert ground truth, MRMC studies, standalone performance) are not applicable in the context of this specific document.

However, I can extract the relevant information and indicate where categories are not applicable.

Acceptance Criteria and Study for Palacos® G Bone Cement with Gentamicin

The core "acceptance criteria" for Palacos® G Bone Cement with Gentamicin, as per this 510(k) submission, is its substantial equivalence to a previously approved predicate device, Palacos® R (PMA No. P810020). The "study" proving this equivalence is a comparison of material composition and performance characteristics against the predicate device.

1. Table of Acceptance Criteria and Reported Device Performance

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 (N/A) in the context of an AI/software device test set.
• The comparison is based on the known characteristics and regulatory approval of the predicate device (Palacos® R) and the material specifications of Palacos® G. It's a device submission, not a study involving patient data in the sense implied by this question.
• The document mentions "comparative testing to Palacos® R" but does not detail the nature or sample size of this testing.
• It notes that Gentamicin has been "used in Europe for approximately 20 years," indicating a historical clinical use provenance for one of the active ingredients.

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)

• N/A. This information is for AI/software device validation, not for a bone cement 510(k) submission.

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

• N/A. This information is for AI/software device validation, not for a bone cement 510(k) submission.

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

• N/A. This is a medical device (bone cement) submission, not an AI/software device. No MRMC study was performed or is relevant here.

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

• N/A. This is a medical device (bone cement) submission, not an AI/software device.

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

• The "ground truth" for this 510(k) submission is the established safety and effectiveness profile of the predicate device (Palacos® R), as well as the chemical and mechanical specifications for bone cements of this type, and the long clinical history of gentamicin-containing bone cements in Europe.
• The effectiveness and safety conclusions are drawn by comparing Palacos® G's characteristics and intended use to these established standards and the predicate device.

8. The sample size for the training set

• N/A. This information is for AI/software device validation, not for a bone cement 510(k) submission.

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

• N/A. This information is for AI/software device validation, not for a bone cement 510(k) submission.

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Palacos® R is intended for use in arthroplastic procedures of the hip, knee, and other joints for the fixation of polymer or metallic prosthetic implants to living bone.

Palacos® R is an acrylic bone cement for use in orthopedic surgery. It is formed from powder and liquid by exothermic polymerization. It secures the fixation of the grafted artificial joint improving the transfer of forces at the interface implant - bone.

The provided text is a 510(k) summary for the Palacos® R bone cement, which is a medical device. This type of document is for regulatory clearance and does not contain the detailed study information typically associated with establishing acceptance criteria and proving device performance in the way a clinical trial or a machine learning model's validation study would.

Specifically, for a medical device cleared via the 510(k) pathway, the "acceptance criteria" are typically related to demonstrating substantial equivalence to a legally marketed predicate device rather than meeting specific performance metrics from a de novo clinical study. The "study that proves the device meets the acceptance criteria" refers to the submission of data (often pre-clinical testing or a review of existing literature/predicate device data) that supports this claim of substantial equivalence.

Therefore, many of the requested points are not applicable or cannot be extracted from this document, as it is not a report of a performance study in the context of AI/ML or a new clinical device.

Here's a breakdown based on the information provided in the 510(k) summary:

1. A table of acceptance criteria and the reported device performance:
   • Acceptance Criteria: "Substantial Equivalence" to the legally marketed predicate device, PALACOS® R BONE CEMENT (PMA Number: P810020). The specific criteria for substantial equivalence typically involve demonstrating similar technological characteristics, intended use, and safety/effectiveness profiles.
   • Reported Device Performance: The document states, "This is the well known Palacos® R being marketed for more than 25 years (PMA by Merck)." This implies that its long-standing market history and prior PMA approval serve as evidence of its performance. The 510(k) summary confirms that the device meets the requirements for substantial equivalence to its predicate.

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

   • Not applicable. This is a 510(k) summary for a bone cement, not a study involving a test set of data like in an AI/ML context. The clearance is based on comparison to a predicate device, not primary clinical data for "testing" in this manner.

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. This is not an expert-driven validation study. The "ground truth" here is the established safety and effectiveness of the legally marketed predicate device as determined by the FDA (through its PMA process).

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

   • Not applicable. There is no "test set" and no adjudication process in the context of comparing human readers or AI in this 510(k) submission.

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 medical device (bone cement), not an AI/ML-driven diagnostic tool that would involve human readers or MRMC studies.

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

   • Not applicable. This is a physical medical device (bone cement), not an algorithm.

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

   • The "ground truth" for this 510(k) clearance is the established safety and effectiveness of the identified predicate device, PALACOS® R BONE CEMENT (PMA Number: P810020), which has been marketed for over 25 years and previously approved under a PMA. The substantial equivalence argument relies on the predicate's known performance rather than new, primary ground truth data from this submission.

8. The sample size for the training set:

   • Not applicable. This is not an AI/ML device that requires a training set.

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

   • Not applicable. No training set is relevant for this type of device and submission.

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