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510(k) Data Aggregation

    K Number
    K014216
    Device Name
    SECCA SYSTEM
    Date Cleared
    2002-03-21

    (90 days)

    Product Code
    Regulation Number
    878.4400
    Why did this record match?
    Device Name :

    SECCA SYSTEM

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

    The Secca™ System is intended for general use in the electrosurgical coagulation of tissue and intended for use specifically in the treatment of fecal incontinence in those patients with incontinence to solid or liquid stool at least once per week and who have failed more conservative therapy.

    Device Description

    Radiofrequency electrosurgical generator and electrosurgical accessories

    AI/ML Overview

    Here's an analysis of the provided text regarding the Secca™ System's acceptance criteria and study, structured to answer your questions.

    It's important to note that the provided text is a 510(k) Summary for a medical device submitted to the FDA in 2002. This document is focused on demonstrating "substantial equivalence" to previously cleared predicate devices, rather than presenting a detailed clinical study report with specific acceptance criteria and performance metrics for a novel AI device. Therefore, many of your requested points, especially those related to AI-specific metrics (like ML model performance, test/training set details, ground truth establishment for ML, MRMC studies, etc.), are not applicable or available within this type of regulatory submission. I will explicitly state where the information cannot be found.


    Acceptance Criteria and Device Performance

    The 510(k) summary for the Secca™ System does not explicitly list quantitative "acceptance criteria" in the way one might see for an AI algorithm's performance (e.g., a specific AUC or sensitivity/specificity threshold). Instead, the primary "acceptance" for a 510(k) submission is demonstrated by substantial equivalence to existing legally marketed predicate devices. This means that the new device (Secca™ System) must be shown to be as safe and effective as the predicates, and not raise new questions of safety or effectiveness.

    The "device performance" reported is the demonstration that its intended use, indications for use, technological characteristics, and principles of operation are substantially equivalent to its predicates.

    Acceptance Criteria (Implied by 510(k) Process)Reported Device Performance (from K014216)
    Intended Use: Substantially equivalent to predicate devices.Met: "The Secca™ System is intended for general use in the electrosurgical coagulation of tissue and intended for use specifically in the treatment of fecal incontinence... The general intended use of the Secca System... is the same as the general intended use of Curon Medical's previously cleared Stretta System... The Secca System's specific indication for use for treatment of fecal incontinence is also substantially the same as for a number of predicate biofeedback devices."
    Indications for Use: Substantially equivalent to predicate devices.Met: "Any minor differences in indications between the Secca System and the predicates do not alter its therapeutic effect, considering the impact on safety and effectiveness. Furthermore, although minor modifications have been made to the technological features of the Secca System... these changes are minimal and do not affect the safety or effectiveness of the Secca System."
    Technological Characteristics & Principles of Operation: Substantially similar to predicate devices, with no new significant questions of safety or effectiveness.Met: "Comparing the principles of operation and the technological characteristics of the Secca System to its predicates, the device and generator design also is substantially similar to the Company's previously cleared Stretta System... Likewise, its design is substantially similar to Curon's cleared Tubular Electrodes... These devices have been designed, tested, and produced by the same manufacturer in much the same manner." "The Secca System presents no new significant technological features compared to the previously cleared predicates."
    Safety and Effectiveness: Demonstrated through comparison to predicates and preclinical/clinical testing (if any was submitted as part of the 510(k) to address minor differences).Met: The FDA cleared the device, implying they found sufficient evidence for substantial equivalence in terms of safety and effectiveness. The document states, "Any minor differences in indications... do not alter its therapeutic effect, considering the impact on safety and effectiveness as not [sic] and met by preclinical and clinical testing." This suggests some testing was performed to support this claim, but details are not provided in this summary.

    Study Details (as inferable from a 510(k) Summary)

    1. Sample size used for the test set and the data provenance:

      • Not applicable/Not provided in this summary. This 510(k) summary describes a regulatory submission for a medical device (radiofrequency electrosurgical system), not an AI algorithm. Therefore, there isn't a "test set" in the context of an AI model. The submission relies on comparison to predicate devices and potentially "preclinical and clinical testing" (mentioned in passing) to support its claim of substantial equivalence. The details of any such testing (sample size, data provenance) are not included in this summary.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

      • Not applicable/Not provided. As this is not an AI algorithm evaluation, there is no "ground truth" to be established by experts for a test set in the sense you are asking. The safety and effectiveness would be evaluated by clinicians/engineers in any underlying studies, but not in the format of "expert consensus ground truth" for an AI model.
    3. Adjudication method (e.g., 2+1, 3+1, none) for the test set:

      • Not applicable/Not provided. This concept is not relevant to a 510(k) submission for a non-AI medical device.
    4. 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. This is a hardware/electrosurgical device, not an AI system. Therefore, an MRMC study comparing human readers with and without AI assistance was not performed.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

      • No. This is a medical device, not an algorithm. Therefore, a standalone algorithm performance evaluation was not performed.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

      • Not applicable/Not provided in this summary. For a device like this, the "ground truth" for its safety and effectiveness would implicitly come from established clinical practice, physiological effects of electrosurgery, and observations in any preclinical/clinical studies (if performed) leading to clinical outcomes. However, the details of how this was established or measured are not in this 510(k) summary. The summary focuses on equivalence to known devices rather than establishing novel ground truth for a new paradigm.
    7. The sample size for the training set:

      • Not applicable/Not provided. This is not an AI device, so there is no training set in the context of machine learning.
    8. How the ground truth for the training set was established:

      • Not applicable/Not provided. As there is no AI training set, this question is not relevant.

    Summary regarding the nature of the document:

    This 510(k) summary is a regulatory document from the year 2002 for an electrosurgical medical device. It predates the widespread regulatory frameworks and expectations for Artificial Intelligence (AI) and Machine Learning (ML) in medical devices. Consequently, it does not contain the specific information you are looking for regarding AI model evaluation, ground truth, test/training sets, or MRMC studies. The "study" referenced in the acceptance criteria is implicitly the demonstration of substantial equivalence through comparison to predicate devices and any internal testing (preclinical and clinical) mentioned briefly.

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