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510(k) Data Aggregation
(204 days)
RADIOMED SOURCE
The RadioMed"10 Source with activities from 0.1 to 5.0mCi per centimeter is indicated for temporary or permanent interstitial implantation or surface application to treat selected localized turnors. They can be used either as primary treatment (such as for prostate cancer or unresectable tumors) or as treatment for residual disease after excision of primary or recurrent tumors. The Pd-103 sources may be used concurrently with or following treatment with other interventions, such as external beam therapy, hyperthermia, or chemotherapy. Tumors of the head, neck, lung, pancreas, prostate and other accessible tumors are commonly treated.
The RadioMed™ source utilizes Pd-103 as the radionuclide for brachytherapy. The RadioMed The Source exists in the form of a coiled rhodium wire. The rhodium matrix also provides the radiopacity of the device. The RadioMed™ Source is a naturally sealed source in the form of a wire.
The RadioMed The Source is packaged non-sterile, single use, and is intended to be sterilized by the end user in accordance with a validated sterilization process. Sterilization is accomplished by exposure to steam autoclave.
The RadioMed" Source will be manufactured. labeled and packaged under GMP controls. Upon completion of the manufacturing and assembly process the device will be inspected to assure compliance to specifications. The devices will be tested in accordance with Standard Operating Procedures.
The sources are delivered in the same manner as brachytherapy seeds currently on the market, i.e. a 17 or 18-gauge needle and stylet.
The provided text describes a 510(k) premarket notification for the "RadioMed™ Source," a brachytherapy radionuclide source. It primarily focuses on demonstrating substantial equivalence to existing predicate devices. Consequently, the document does not detail specific acceptance criteria for performance metrics or present a study proving the device meets those criteria in the way one might expect for a diagnostic or AI-driven device.
Instead, the "Performance Testing" section outlines the standards achieved for different aspects of the device, implying that compliance with these standards serves as the "acceptance criteria" and the "study" is the demonstration of adherence to these standards.
Here's an attempt to structure the information based on your request, acknowledging the limitations of the provided text for certain categories:
Acceptance Criteria and Device Performance Study for RadioMed™ Source
The RadioMed™ Source is a brachytherapy radionuclide source. Its "performance" is subdivided into four categories, and the device's acceptance is based on its compliance with established standards and specifications for these categories and general regulatory requirements.
1. Table of Acceptance Criteria and Reported Device Performance
Category / Performance Aspect | Acceptance Criteria (Standard / Description) | Reported Device Performance |
---|---|---|
General Manufacturing & Quality | FDA QSR 21 CFR Part 820 Good Manufacturing Practices | Manufactured, labeled, and packaged under GMP controls. Device will be inspected to assure compliance to specifications. Devices will be tested in accordance with Standard Operating Procedures. |
Biocompatibility | ISO 10993-1 1992 (E) Biological Evaluation of Medical Devices | Achieved (Summary states "Summary of standards achieved: ISO 10993-1 1992 (E) Biological Evaluation of Medical Devices") |
Radioactive Source Classification | ANSI N43.6-1997: Classification of sealed radioactive sources | Achieved (Summary states "Summary of standards achieved: ANSI N43.6-1997: Classification of sealed radioactive sources") |
Integrity & Test Specifications | ANSI N44.1-1973 Integrity and Test Specifications for selected Brachytherapy Sources | Achieved (Summary states "Summary of standards achieved: ANSI N44.1-1973 Integrity and Test Specifications for selected Brachytherapy Sources") |
Leak Testing | ANSI N44.2-1973 Leak testing radioactive brachytherapy sources / ISO 9978: 1992(E) "Radiation protection - Sealed radioactive sources - Leakage test methods". | Achieved (Summary states "Summary of standards achieved: ANSI N44.2-1973 Leak testing radioactive brachytherapy sources" and "ISO 9978: 1992(E) "Radiation protection - Sealed radioactive sources - Leakage test methods".") The RadioMed™ Source is described as a naturally sealed source. |
Sterilization (by end user) | AAMI Standard 11134-1994 Recommended practice for Steam Autoclave | Intended to be sterilized by the end user in accordance with a validated sterilization process (steam autoclave). |
Radiation Energy | Energy emitted for 103Pd (20-23 keV x-rays) | The energy emitted for the RadioMed™ Source and the Theragenics 103Pd Seed is exactly the same: 20-23 keV x-rays. |
Source Strength Measurement | Calibration and Calibration Accuracy | Performance is subdivided into this category, implying that established calibration and accuracy standards are met (details not provided in the text). |
Dose Comparison | (Implicit comparison to predicate devices for therapeutic effect) | Performance is subdivided into this category, implying that dose characteristics are comparable to predicate devices (details not provided in the text). |
Sealed Source Testing | (Implicit integrity and safety testing for sealed sources) | Performance is subdivided into this category, implying that all necessary tests for sealed sources are conducted (details not provided in the text). The device is described as a "naturally sealed source." |
2. Sample Size Used for the Test Set and Data Provenance
The document does not specify a "test set" in the context of a typical clinical trial or performance study for a diagnostic device. The performance testing appears to refer to engineering and quality assurance tests conducted on manufactured units.
- No specific sample size for a "test set" is mentioned.
- Data provenance (country of origin, retrospective/prospective) is not applicable or provided, as the testing relates to manufacturing and product specifications rather than clinical data.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of those Experts
Not applicable. The ground truth for this device is based on objective measurements against engineering standards, physical properties of the radionuclide, and established regulatory benchmarks, rather than subjective expert interpretation of data.
4. Adjudication Method for the Test Set
Not applicable. Adjudication methods like 2+1 or 3+1 are used for expert consensus on subjective data (e.g., image interpretation). For this device, compliance is determined by objective measurements and adherence to technical standards.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done, and the effect size of how much human readers improve with AI vs without AI assistance
Not applicable. This device is a brachytherapy source, not a diagnostic imaging or AI-driven device intended to assist human readers. Therefore, an MRMC study is irrelevant to its evaluation.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done
Not applicable. The RadioMed™ Source is a physical medical device, not an algorithm.
7. The Type of Ground Truth Used
The "ground truth" for the RadioMed™ Source's performance and safety is:
- Engineering Specifications: Compliance with design blueprints and material properties.
- Physical Standards: Adherence to established physical properties of the radionuclide (Pd-103 energy emission).
- Regulatory Standards: Compliance with national and international standards for medical devices, manufacturing (GMP, QSR), radiation safety (ANSI, ISO), and biocompatibility (ISO).
- Predicate Device Equivalence: The comparison to legally marketed predicate devices serves as a "ground truth" for demonstrating substantial equivalence in function and safety.
8. The Sample Size for the Training Set
Not applicable. This device does not involve machine learning or AI, so there is no "training set."
9. How the Ground Truth for the Training Set was Established
Not applicable, as there is no training set.
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