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510(k) Data Aggregation
(134 days)
Purastat is indicated for the symptomatic management of rectal mucositis, such as radiation proctitis that may be caused by chemotherapy or radiotherapy.
PuraStat is a sterile gel composed of a synthetic peptide and sterile water for injection. It is provided as a prefilled syringe (2.5% peptide content) ready for use as a mucoadhesive hydrogel that provides a protective barrier over rectal mucosa. The gel is delivered to the intended application site(s) via a commercially available endoscopic catheter that is attached to the gel-filled syringe via the polypropylene adapter (Class 1 - 510k Exempt) also commercially available (Class 1. 510k Exempt).
PuraStat is completely non-animal and non-plant derived and contains no preservatives that might present a risk of allergic reaction or skin irritation.
Exposure to physiological fluids such as blood causes the peptide solution to quickly form a transparent gel without expansion in volume.
The provided text does not contain detailed information about the acceptance criteria or a specific study proving the device meets those criteria, as typically found in clinical trial reports or detailed performance studies for medical devices.
Instead, this document is an FDA 510(k) clearance letter and an associated 510(k) Summary. It focuses on demonstrating substantial equivalence to a previously cleared predicate device (PuraStat-RM, K213552). The key assertion is that the subject device (PuraStat) is identical to the predicate device in most aspects, with the only exception being the final sterilization method (gamma radiation sterilization).
Therefore, the "performance data" referred to in the document is not a clinical study to prove new performance criteria but rather:
- Bench testing: To demonstrate that the change in sterilization method does not alter the physical or functional properties of the device.
- Biocompatibility testing: To ensure that the modified sterilization method does not introduce new biocompatibility concerns.
The document explicitly states: "The subject device is identical to the predicate device and has the same intended use, and an equivalence demonstration was performed following the final sterilization change. The bench testing and biocompatibility testing provided in this submission assess the equivalence demonstration."
Given this, the requested information elements related to a and clinical study with performance metrics, sample sizes, expert ground truth, adjudication, MRMC studies, standalone performance, and training sets are not available in this document. The document relies on the predicate device's prior clearance to establish safety and effectiveness.
Here's what can be extracted based on the provided text, while acknowledging the limitations:
1. A table of acceptance criteria and the reported device performance
The document does not explicitly state quantitative acceptance criteria or specific numerical performance metrics for the subject device based on a new study. Instead, the "acceptance criteria" are implicitly met by demonstrating substantial equivalence to the predicate device. The performance reported is that the subject device is "identical in material, formulation and manufacturing, and so final product specification" to the predicate, with the exception of the sterilization method.
| Acceptance Criteria (Implicit from Equivalence) | Reported Device Performance |
|---|---|
| Maintain material, formulation, manufacturing, and final product specifications as the predicate device. | "PuraStat is identical in material, formulation and manufacturing, and so final product specification to the predicate PuraStat-RM (K213552)." |
| No new questions of safety and effectiveness due to the change in sterilization method. | "The difference in technological characteristics (Final sterilization) of the subject and the predicate device... do not raise any new questions of safety and effectiveness." |
| Biological compatibility is maintained after sterilization change. | Biocompatibility testing was performed. (Specific results not detailed here). |
| Physical/functional properties are maintained after sterilization change. | Bench testing was performed. (Specific results not detailed here). |
2. Sample size used for the test set and the data provenance
Not applicable/Not provided in this document as it pertains to a new clinical performance study. The "test set" in this context refers to the samples used for bench and biocompatibility testing, but their specific sizes and provenance are not detailed.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable/Not provided. This type of information is typically for clinical performance studies, which were not the basis for this 510(k) clearance beyond the predicate's original clearance.
4. Adjudication method for the test set
Not applicable/Not provided.
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 device is a medical product (a gel) for symptomatic management, not an AI-assisted diagnostic or imaging device. Therefore, MRMC studies are not relevant here.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
Not applicable. This is not an AI algorithm.
7. The type of ground truth used
Not applicable in the context of a new clinical performance study. For the equivalence demonstration, the "ground truth" (or reference) is the established safety and effectiveness profile of the predicate device previoiusly cleared by the FDA. The current submission's "truth" is that the modified device remains functionally and biologically equivalent to that predicate.
8. The sample size for the training set
Not applicable. This is not an AI algorithm requiring a training set.
9. How the ground truth for the training set was established
Not applicable.
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(83 days)
PuraStat is intended for hemostasis of mild and moderate bleeding post ESD or EMR, as an adjunct, bridge, prophylactic or rescue therapy for intraprocedural venous bleeding or prophylactic therapy to prevent post procedure bleeding, and for primary non-variceal gastrointestinal (GI) bleeding. PuraStat is not indicated for arterial Forrest 1a bleeding.
PuraStat is a sterile gel composed of a synthetic peptide and sterile water for injection. It is provided as a prefilled syringe (2.5% peptide content) ready for use as a hemostat. The gel is delivered to the intended application site(s) via a commercially available endoscopic catheter that is attached to the gel-filled syringe via the polypropylene adapter (Class 1 - 510k Exempt) also commercially available (Class 1, 510k Exempt). PuraStat is completely non-animal and non-plant derived and contains no preservatives that might present a risk of allergic reaction or skin irritation. Exposure to physiological fluids such as blood causes the peptide solution to quickly form a transparent gel without expansion in volume. PuraStat achieves hemostatic effects by forming a hydrogel matrix barrier that blocks the flow of blood at the site of application.
The provided text is a 510(k) summary for the PuraStat device. It states that the subject device (K242250) is identical to the predicate device (K222481) except for the final sterilization method. The document explicitly states that the "device is identical to the predicate device and has the same intended use."
Therefore, the performance data provided is to demonstrate equivalence to the predicate device, not to establish new performance criteria for the subject device. It relies on the predicate's performance to establish substantial equivalence.
Based on the provided information, I can answer some of your questions and explain why others cannot be answered from this specific document:
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A table of acceptance criteria and the reported device performance
- This document does not provide a table of acceptance criteria and reported device performance for the new device in the general sense of clinical performance or accuracy for an AI/diagnostic device.
- Instead, it states, "The subject device is identical to the predicate device...an equivalence demonstration was performed following the final sterilization change. The bench testing and biocompatibility testing provided in this submission assess the equivalence demonstration."
- The "acceptance criteria" here are to show that the change in sterilization does not alter the device's fundamental properties or safety, ensuring it performs identically to the predicate device. Specific numerical performance metrics for hemostasis are not detailed in this filing, as they would have been established and accepted for the predicate device.
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Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- This information is not provided in this 510(k) summary. The testing mentioned (bench testing and biocompatibility) is related to the change in sterilization, not a clinical trial to establish new efficacy for the device's intended use.
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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)
- This is not applicable and is not mentioned. The device is a hemostatic gel, not an AI or diagnostic device that requires expert ground truth for image interpretation or diagnosis.
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Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable as this is not an AI/diagnostic device based on expert interpretation.
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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 diagnostic device.
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If a standalone (i.e. algorithm only without human-in-the loop performance) was done
- Not applicable. The device is a physical hemostatic gel, not an algorithm.
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The type of ground truth used (expert concensus, pathology, outcomes data, etc)
- Not applicable in the context of an AI/diagnostic ground truth. The "ground truth" for this filing is that the subject device, with its new sterilization, is functionally identical and safe compared to the predicate through bench and biocompatibility testing. Clinical efficacy would have been established for the predicate device, likely through clinical studies demonstrating hemostatic success (e.g., control of bleeding, resolution of bleeding events), which would have served as the "ground truth" for its performance.
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The sample size for the training set
- Not applicable. This is not an AI device that requires a training set.
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How the ground truth for the training set was established
- Not applicable. This is not an AI device that requires a training set.
Summary of Relevant Information from the Document:
- Device Name: PuraStat
- Intended Use: Hemostasis of mild and moderate bleeding post ESD or EMR, as an adjunct, bridge, prophylactic or rescue therapy for intraprocedural venous bleeding or prophylactic therapy to prevent post procedure bleeding, and for primary non-variceal gastrointestinal (GI) bleeding. Not indicated for arterial Forrest 1a bleeding.
- Key Change from Predicate: Final sterilization method (replaced by gamma radiation sterilization).
- Performance Data Provided: Bench testing and biocompatibility testing to demonstrate equivalence between the subject device (with new sterilization) and the predicate device.
- Conclusion: The subject device is substantially equivalent to the predicate (K222481) as the change in sterilization does not raise any new questions of safety and effectiveness, and the device remains identical in material, formulation, manufacturing, and final product specifications. The performance of the predicate device is implicitly relied upon.
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(195 days)
PuraStat is intended for hemostasis of mild and moderate bleeding post ESD or EMR, as an adjunct, bridge, prophylactic or rescue therapy for intraprocedural venous bleeding or prophylactic therapy to prevent post procedure bleeding, and for primary non-variceal gastrointestinal (GI) bleeding. PuraStat is not indicated for arterial Forrest 1a bleeding.
PuraStat is a sterile gel composed of a synthetic peptide and sterile water for injection. It is provided as a prefilled syringe (2.5% peptide content) ready for use as a hemostat. The gel is delivered to the intended application site(s) via a commercially available endoscopic catheter that is attached to the gel syringe via the polypropylene adapter. PuraStat is completely non-animal and non-plant derived and contains no preservatives that might present a risk of allergic reaction or skin irritation. Exposure to physiological fluids such as blood causes the peptide solution to quickly form a transparent gel without expansion in volume. PuraStat achieves hemostatic effects by forming a hydrogel matrix barrier that blocks the flow of blood at the site of application.
The provided document is a 510(k) Premarket Notification from the FDA for a device called PuraStat. It does not contain information about the acceptance criteria or a study that proves the device meets those criteria in the typical sense of a diagnostic or AI-driven medical device evaluation.
The document states that the PuraStat device is identical to its predicate device (PuraStat-GI, K210098). Therefore, most performance data, including bench testing, animal testing, and biocompatibility testing, were referenced from the predicate device's filing.
However, there is an additional indication for PuraStat: "primary non-variceal gastrointestinal (GI) bleeding." To address this new indication, the submission references a clinical study found in the literature. This study evaluates the safety and effectiveness of PuraStat for this specific use, which can be interpreted as demonstrating the device's acceptable performance for this particular indication.
Based on the provided text, here's a breakdown of the requested information, focusing on the Branchi et al. Study which supports the additional indication:
1. A table of acceptance criteria and the reported device performance
The document does not explicitly state "acceptance criteria" with numerical thresholds for performance. Instead, it defines primary and secondary endpoints for the clinical study, and the reported results of these endpoints demonstrate the device's performance that was deemed acceptable by the FDA for the new indication.
| Acceptance Criteria (Study Endpoints) | Reported Device Performance (PuraStat) |
|---|---|
| Primary Endpoint: Achievement of hemostasis during the procedure (procedure success) | 94% of patients (74/79, 95% CI 88-99%) when used as primary application. 75% of patients (24/32, 95% CI 59-91%) when used as secondary hemostatic product. |
| Secondary Endpoint: Prevention of rebleeding (therapy success) at 3 days | 91% after primary use. 87% in all study patients. |
| Secondary Endpoint: Prevention of rebleeding (therapy success) at 7 days | 87% after primary use. 81% in all study patients. |
| Secondary Endpoint: Rebleeding rate at 30-day follow-up | 16% (18/111) overall. 12% at 7 days and 16% at 30 days in the whole patient collective (specifically for patients with active oozing bleeding, where literature reports up to 50%). |
| Risk and side effect profiles | No adverse events due to application of PuraStat or technical failures were reported. |
2. Sample size used for the test set and the data provenance
- Sample Size: 111 patients with gastrointestinal bleeding.
- Data Provenance: Retrospective and prospective. The study was a "prospective, consecutive open-label, multi-center study" conducted between July 2017 and December 2018 at 15 endoscopy departments in Germany.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
The document does not provide details on the number or qualifications of experts establishing ground truth within the Branchi et al. Study. The study design indicates a multi-center observational study, suggesting that treating physicians at each of the 15 endoscopy departments made the assessments of hemostasis and rebleeding. These would presumably be "experts" in gastrointestinal endoscopy, but no specific qualification (e.g., "radiologist with 10 years of experience") or number is detailed.
4. Adjudication method for the test set
The document does not specify an adjudication method (like 2+1, 3+1). The nature of the study (observational, multi-center) suggests that assessments were likely made by the treating clinicians at each site. There is no mention of independent adjudication of outcomes.
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
No, a multi-reader multi-case (MRMC) comparative effectiveness study was not done. This document describes a hemostatic device, not an AI-driven diagnostic or assistive technology for human readers. Therefore, the concept of improving human readers with AI assistance is not applicable.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
No, PuraStat is a physical hemostatic gel, not an algorithm. Its performance is always in a "human-in-the-loop" scenario, as it is applied by an endoscopist.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
The ground truth for the Branchi et al. Study was based on clinical outcomes and expert observation during and after endoscopic procedures:
- Procedure success (hemostasis): Assessed by the endoscopist during the procedure.
- Therapy success (prevention of rebleeding): Defined by the absence of clinical signs of gastrointestinal bleeding (hematemesis, melena, hematochezia) in association with cardiovascular stability or a stable hemoglobin level, assessed at 3 and 7 days after application.
- Adverse events: Recorded over 30 days post-procedure.
8. The sample size for the training set
The document does not describe a "training set" in the context of machine learning. The Branchi et al. Study is a clinical trial evaluating the device's performance, not training an algorithm.
9. How the ground truth for the training set was established
Not applicable, as there is no "training set" in the context of this device.
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(144 days)
PuraStat-RM is indicated for the symptomatic management of rectal mucositis, such as radiation proctitis that may be caused by chemotherapy or radiotherapy.
PuraStat-RM is a sterile gel composed of a synthetic peptide and sterile water for injection. It is provided as a prefilled syringe (2.5% peptide content) ready for use as a mucoadhesive hydrogel that provides a protective barrier over rectal mucosa. The gel is delivered to the intended application site(s) via a commercially available endoscopic catheter that is attached to the gel syringe via the polypropylene adapter.
PuraStat-RM is completely non-animal and non-plant derived and contains no drugs or biologics that might present a risk of allergic reaction or skin irritation.
Exposure to physiological fluids such as blood causes the peptide solution to quickly form a transparent gel without expansion in volume.
The provided text does not contain information about acceptance criteria for a device's performance, nor does it describe a study proving the device meets such criteria in the format requested.
The document is an FDA 510(k) premarket notification letter and summary for a device called PuraStat-RM. It focuses on demonstrating substantial equivalence to predicate devices based on intended use, technological characteristics, and non-clinical as well as some clinical performance data.
Here's what can be extracted from the text, addressing the requested points where possible, and noting when information is not available:
1. Table of Acceptance Criteria and Reported Device Performance
- Not Available: The document does not specify quantitative acceptance criteria for device performance (e.g., sensitivity, specificity, accuracy, or a specific clinical outcome threshold) in the typical sense for an AI/diagnostic device. The clinical data presented focuses on improvement in symptoms rather than meeting pre-defined statistical endpoints for device performance against a gold standard or comparator.
2. Sample Size Used for the Test Set and Data Provenance
- Test Set Sample Size: 21 patients.
- Data Provenance: United Kingdom, prospective, single-center case series.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of Those Experts
- Not Available: The document does not describe the establishment of a "ground truth" by experts for the clinical study in the context of device performance evaluation. The study assessed patient-reported and physician-reported improvement in symptoms.
4. Adjudication Method for the Test Set
- Not Available: An adjudication method for a test set, typically involving multiple expert readers, is not described as this was a clinical outcome study rather than an AI diagnostic device evaluation.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- No: The document does not mention an MRMC comparative effectiveness study, nor does it involve AI assistance for human readers. The clinical study evaluated the device's effect on patients.
6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study
- Not Applicable: PuraStat-RM is a physical hydrogel device, not an algorithm, so a standalone algorithm performance study is not relevant.
7. Type of Ground Truth Used
- Clinical Outcomes / Patient and Physician Reported Symptoms: The "ground truth" in this context was effectively patient-reported bleeding diaries and physician-reported rectal bleeding scores, indicating symptomatic improvement rather than a definitive diagnostic truth established by an independent gold standard.
8. Sample Size for the Training Set
- Not Applicable / Not Available: Since PuraStat-RM is a physical medical device and not an AI algorithm, there is no "training set" in the context of machine learning.
9. How the Ground Truth for the Training Set Was Established
- Not Applicable / Not Available: As above, this concept does not apply to this device.
Summary of the Clinical Study Presented:
- Study Design: Prospective, consecutive, open-label, single-center case series.
- Participants: 21 patients (18 men; 17 prostate, 2 vaginal, 2 rectal; median age 76 years) with severe refractory radiation proctopathy (RP) causing rectal bleeding.
- Intervention: PuraStat-RM applied endoscopically at four-weekly intervals, with more as required.
- Outcomes:
- Median time from first treatment to follow-up: 12 months (range 3-18).
- No patients lost to follow-up.
- Only one patient had recurrence of significant bleeding among those >12 months beyond their first treatment.
- 14 out of 16 patients observed post-treatment showed marked improvement in bleeding volume and frequency (subjectively patient-reported and objectively via 7-day bleeding diaries).
- Median number of treatments: 3 (range 2-7).
- Median amount of PuraStat-RM used: 5 mL (range 3-5 mL).
- Rectal bleeding episodes (into toilet bowl) reduced from a median of 4.5 (range 0-27) prior to first treatment to 2 (range 0-16) prior to the third treatment.
- Conclusion drawn in the document: This data supports the safety and effectiveness for its intended use, contributing to the substantial equivalence determination.
In essence, the document details a clinical study that demonstrated the device's ability to reduce symptoms of rectal bleeding in patients with radiation proctopathy, based on patient and physician reports, rather than a study designed to meet specific statistical acceptance criteria for a diagnostic/AI performance measure.
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(254 days)
PuraStat-OM adheres to oral tissue and forms a protective barrier over the wound to prevent further irritation and contamination. It provides a moist wound environment required for optimal wound healing.
Manages pain of, for example:
- All types of oral wounds, mouth sores, injuries and ulcers of the oral mucosa
- Canker sores and cold sores
- Irritation and traumatic ulcers such as those caused by various appliances such as braces, brackets, full and partial dentures and palatal expanders
- Soft tissue pain from orthodontics
- Aphthous ulcers
- Extraction site pain
- Oral mucositis and stomatitis (may be caused by chemotherapy or radiotherapy)
PuraStat-OM is a sterile gel composed of a synthetic peptide and sterile water for injection. It is provided as a prefilled syringe (2.5% peptide content) ready for use as an oral hydrogel wound dressing with the sterile application nozzle. The gel's primary mode of action is that it adheres to the wound surface, conforms to the contours of the wound, and protects the wound from contamination and irritation by forming a protective barrier that is similar to the natural mucosa. It also creates and maintains a moist wound environment, which is necessary for the natural healing process.
PuraStat-OM is completely non-animal and non-plant derived and contains no drugs or biologics that might present a risk of allergic reaction or skin irritation.
Exposure to physiological fluids such as blood causes the peptide solution to quickly form a transparent gel without expansion in volume.
Here's an analysis of the provided text, focusing on acceptance criteria and supporting study details:
Device: PuraStat-OM (an oral hydrogel wound dressing)
Predicate Device: McMerlin Dental Company's SOCKIT!® Oral Hydrogel Wound Dressing (K063148)
1. Table of Acceptance Criteria and Reported Device Performance
The provided document does not explicitly state "acceptance criteria" in a pass/fail quantifiable manner for the purpose of demonstrating substantial equivalence. Instead, it describes a comparison of technological characteristics and performance data between the subject device (PuraStat-OM) and the predicate device (SockIt!® Gel) to argue for their substantial equivalence. The "criteria" are implicitly defined by the properties measured and compared.
| Characteristic Measured/Compared | Acceptance Criteria (Implicit) | Reported Device Performance (PuraStat-OM) | Reported Predicate Performance (SockIt!® Gel) | Conclusion/Implication (PuraStat-OM vs. Predicate) |
|---|---|---|---|---|
| Biocompatibility | No toxic, sensitizing, irritating, acute systemic, subchronic/subacute, or material-mediated pyrogenic effects; normal inflammatory response resolving to capsular fibrosis. (Based on ISO 10993-1 and FDA Guidance) | Met all biocompatibility tests (Cytotoxicity, Sensitization, Irritation, Acute Systemic Toxicity, Subchronic / Subacute Toxicity, Implantation, Material-Mediated Pyrogenicity). Device deemed to not give rise to toxic effects. | Not directly tested for this submission (predicate is already cleared), but the predicate is also a medical device with established biocompatibility. | Device does not raise different questions of safety; it performs adequately in biocompatibility. |
| Primary Mode of Action | Adheres to wound, forms protective barrier, conforms to contours, prevents contamination/irritation, provides moist wound environment. | Adheres to wound surface, conforms to contours, forms protective barrier, provides moist wound environment. | Adheres to wound surface, conforms to contours, forms protective barrier, provides moist wound environment. | Same primary mode of action. |
| Complex Modulus (Simulated Body Fluid) | Should demonstrate sufficient physical strength to form an effective physical barrier, comparable to or greater than the predicate. | Greater than the predicate device. | Lower than the subject device. | PuraStat-OM forms a physical barrier that is as at least as effective as the predicate due to its increased physical strength. |
| Complex Viscosity (Simulated Body Fluid) | Should demonstrate sufficient physical strength to form an effective physical barrier, comparable to or greater than the predicate. | Greater than the predicate device. | Lower than the subject device. | PuraStat-OM forms a physical barrier that is as at least as effective as the predicate due to its increased physical strength. |
| Viscosity | Needs to allow for easy injection onto the wound, potentially lower than predicate for ease of use. | Lower than SockIt!® Gel. | Higher than PuraStat-OM. | Easier to inject the product onto the wound site. |
| Injection Force | Should be manageable for clinical use, comparable to or lower than the predicate for ease of use. | Required less force than the predicate SockIt!® Gel. | Required more force than PuraStat-OM. | Easier to use/inject. |
| pH (after 10 min in human saliva) | Biocompatible pH range, comparable to predicate. | 6.2 | 7.7 | Comparable pH after exposure to physiological fluids, indicating similar physiological interaction. |
| pH (after 10 min in human blood) | Biocompatible pH range, comparable to predicate. | 6.0 | 7.6 | Comparable pH after exposure to physiological fluids, indicating similar physiological interaction. |
2. Sample Size Used for the Test Set and Data Provenance
The study described is nonclinical performance (bench testing) and GLP biocompatibility testing.
- Sample Size for Test Set: Not explicitly stated with a specific number of units for each test. The document refers to "PuraStat-OM" and "SockIt!® Gel" being tested, implying samples of each device were used. For biocompatibility, testing is typically done on multiple samples.
- Data Provenance: The biocompatibility testing was conducted as per ISO 10993-1 and consistent with FDA Guidance, indicating standard laboratory practices. The bench testing (complex modulus, viscosity, pH, etc.) was a "side-by-side comparison" of the subject and predicate devices. This is retrospective in the sense that it compares a new device to an already marketed predicate, but the testing itself would have been conducted prospectively for the submission. The origin of the data is laboratory testing.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
N/A. This document describes nonclinical, laboratory-based performance testing and biocompatibility assessments, not a study requiring human readers or expert-established ground truth for diagnostic accuracy.
4. Adjudication Method for the Test Set
N/A. Not applicable to nonclinical performance or biocompatibility testing.
5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study Was Done
No. An MRMC study is not mentioned as this submission focuses on nonclinical and bench testing to demonstrate substantial equivalence based on technological characteristics and biocompatibility, not comparative effectiveness with human readers.
6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done
N/A. This is a physical medical device (hydrogel), not an imaging/AI algorithm.
7. The Type of Ground Truth Used
For the biocompatibility tests (e.g., Cytotoxicity, Sensitization, Irritation), the "ground truth" is defined by established biological safety standards and methodologies (ISO 10993-1). For the bench tests (e.g., Complex Modulus, Viscosity, pH), the "ground truth" is the measured values obtained using validated laboratory methods and instruments. These are objective physical and chemical properties.
8. The Sample Size for the Training Set
N/A. This is not an AI/machine learning device that requires a training set.
9. How the Ground Truth for the Training Set Was Established
N/A. Not applicable.
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(162 days)
PuraStat-GI is intended for hemostasis of mild and moderate bleeding post ESD or EMR, as an adjunct, bridge, prophylactic or rescue therapy for intraprocedural venous bleeding or prophylactic therapy to prevent post procedure bleeding.
PuraStat-GI is a sterile gel composed of a synthetic peptide and sterile water for injection. It is provided as a prefilled syringe (2.5% peptide content) ready for use as a hemostat. The gel is delivered to the intended application site(s) via a commercially available endoscopic catheter that is attached to the gel syringe via the polypropylene adapter.
PuraStat-GI is completely non-animal and non-plant derived and contains no preservatives that might present a risk of allergic reaction or skin irritation.
Exposure to physiological fluids such as blood causes the peptide solution to quickly form a transparent gel without expansion in volume. PuraStat-GI achieves hemostatic effects by forming a hydrogel matrix barrier that blocks the flow of blood at the site of application.
The provided text describes a 510(k) premarket notification for the device PuraStat-GI, a hemostatic device for intraluminal gastrointestinal use.
It details bench testing, animal studies, and clinical studies of the device. However, it does not explicitly state specific acceptance criteria (e.g., "The device must achieve hemostasis in X% of cases with Y% confidence interval"). Instead, it presents reported device performance and implies that these results demonstrate substantial equivalence to a predicate device, thereby meeting the FDA's requirements for market clearance.
Therefore, the response below will present the reported device performance from the provided text and note the absence of explicitly stated numerical acceptance criteria.
Acceptance Criteria and Study Details for PuraStat-GI
While the document does not explicitly list specific numerical "acceptance criteria" that the device must meet (e.g., "hemostasis rate must be >X%"), it presents the performance data of PuraStat-GI from three clinical studies, alongside a comparison to a predicate device in bench and animal testing, to demonstrate substantial equivalence. The implied acceptance is that the device's performance is comparable to or better than established benchmarks in terms of safety and effectiveness for its intended use.
1. Table of Acceptance Criteria (Implied) and Reported Device Performance
| Performance Metric | Implied Acceptance Criterion (Comparable to predicate/clinically acceptable) | Reported PuraStat-GI Performance (from Clinical Studies) |
|---|---|---|
| Hemostasis Rate | High rate of initial hemostasis for mild to moderate GI bleeding | Subramaniam (2019): 75%de Nucci (2020): 90%Subramaniam (2020): 92.6% |
| Delayed Bleed Rate | Low incidence of delayed bleeding post-endoscopic resection | Subramaniam (2019): 3%Subramaniam (2020): 4.3% |
| Re-bleed Rate | Low incidence of re-bleeding post-acute GI bleeding | de Nucci (2020): 10% |
| Mortality | 0% or very low | All studies reported: 0% |
| Adverse Events | No adverse events related to device use | No adverse events related to PuraStat-GI in 223 patients |
Note: The acceptance criteria are "implied" based on the presentation of data to support device clearance, rather than explicit numerical targets defined in the document.
2. Sample Size Used for the Test Set and Data Provenance
The provided text details three clinical studies that serve as the "test set" for human performance data for PuraStat-GI:
- Subramaniam (2019): N=100 patients
- de Nucci (2020): N=77 patients
- Subramaniam (2020): N=46 patients
Total clinical patients: 223 patients.
Data Provenance: The document states these are "results of three clinical studies of the use of PuraStat® that have been reported in the literature." This indicates these were likely retrospective analyses of previously conducted and published clinical trials. The specific countries of origin for these studies are not specified in the provided document.
Additionally, a GLP gastrointestinal mucosal defect study was conducted in a porcine model with a comparative side-by-side assessment against the predicate device. The sample size for this animal study is not specified.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
The document does not provide information on the number of experts used to establish ground truth in the clinical studies, nor their specific qualifications. Typically, clinical study results (like hemostasis success, re-bleed rates, and adverse events) are determined by the treating physicians and study investigators, who are medical professionals specializing in endoscopy and gastroenterology, but their specific roles in "ground truth" establishment are not detailed here.
4. Adjudication Method for the Test Set
The document does not specify any adjudication method (e.g., 2+1, 3+1, none) for the clinical studies presented.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and Effect Size
No, a multi-reader multi-case (MRMC) comparative effectiveness study was not done. The clinical studies presented solely evaluate the performance of PuraStat-GI itself. There is no mention of human readers (clinicians) assessing cases with and without AI assistance, as would be typical for an MRMC study comparing AI-assisted performance to human-only performance.
6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done
Yes, the clinical studies presented, along with the animal and bench testing, represent "standalone" performance of the PuraStat-GI device. The device is a physical hemostatic agent, not an AI algorithm. Its performance metrics (hemostasis rate, re-bleed rate, etc.) are a direct measure of the device's efficacy without human-in-the-loop assistance in the sense of an AI diagnostic. The human "in the loop" delivers the device, but the device's hemostatic action is independent.
7. The Type of Ground Truth Used
The ground truth for the clinical studies appears to be based on clinical outcomes and physician assessment during and after endoscopic procedures. This includes:
- Observation of hemostasis during endoscopy.
- Follow-up for delayed bleeding or re-bleeding events.
- Reporting of adverse events.
For the animal study, the ground truth was also based on direct observation of hemostasis and re-bleeding rates in the porcine model.
8. The Sample Size for the Training Set
The document does not mention a training set for PuraStat-GI. PuraStat-GI is a medical device (hemostatic gel), not a machine learning or AI algorithm that typically requires a training set. The clinical studies, animal studies, and bench tests are for validation and performance assessment, not for training.
9. How the Ground Truth for the Training Set Was Established
As PuraStat-GI is not an AI algorithm, there is no "training set" in the conventional sense, and thus no ground truth was established for a training set. The development of the device itself would have involved extensive research and pre-clinical testing, but these are not referred to as a "training set" in the context of this document.
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