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510(k) Data Aggregation

    K Number
    K132920
    Manufacturer
    Date Cleared
    2014-06-10

    (266 days)

    Product Code
    Regulation Number
    874.3620
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    SPIROX INEX DEVICE

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

    The Spirox INEX absorbable implant is indicated for supporting nasal septal cartilage.

    Device Description

    The Spirox INEX implantable sheet is an absorbable device comprised of a poly (L-lactide) 70:30. The product is provided as a perforated sheet comprised of multiple "rod" like elements. The sheet is nominally 24.5 x 20.0 mm with a thickness of 1.1 mm. The bridge sections are nominally 3.0 x 1.9 mm and the voids are nominally 2.4 x 1.9 mm. The implant can be trimmed and shaped to dimensions suitable for the surgical need. The device is implanted using standard surgical tools and techniques The Spirox INEX implantable sheet is a sterile, single use device.

    AI/ML Overview

    The manufacturer, Spirox, Inc., did not conduct a study to prove the device met acceptance criteria in the traditional sense of a clinical trial or comparative effectiveness study with specific performance metrics. Instead, the submission focuses on demonstrating substantial equivalence to predicate devices through non-clinical performance data.

    Here's an analysis of the provided text in direct reference to your questions:

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

    The document does not provide a table of acceptance criteria with specific quantitative performance metrics (e.g., sensitivity, specificity, accuracy) or a direct comparison to acceptance thresholds. The "reported device performance" is described qualitatively as:

    Acceptance CriteriaReported Device Performance
    Mechanical PerformanceConfirmed that the Spirox INEX Device performs according to product specifications.
    Functional PerformanceConfirmed that the Spirox INEX Device performs according to product specifications.
    BiocompatibilityComplies with ISO 10993 "Biological Evaluation of Medical Devices" and FDA's recent guidance.
    SterilizationComplies with the requirements prescribed in ISO 11137 for radiation sterilization.
    Packaging and Shipping ValidationConducted pursuant to the applicable ISO and ISTA 3A guidelines.

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

    The document mentions "Design verification testing," "comparative testing with the cited predicate devices," and a "GLP animal study." However, it does not specify the sample sizes for any of these tests. The provenance of the data (country of origin, retrospective/prospective) is also not mentioned.

    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)

    This information is not applicable as the device is an absorbable implant for nasal septal cartilage support, not an AI/diagnostic device requiring expert ground truth establishment for a test set. The validation relies on physical and biological testing.

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

    This information is not applicable for the same reasons as #3.

    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 MRMC comparative effectiveness study was done. This type of study is relevant for diagnostic or AI-powered devices where human interpretation is involved. The Spirox INEX Device is a physical implant.

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

    This question is not applicable. The device is an implant, not an algorithm.

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

    The "ground truth" for the non-clinical performance tests was based on established engineering specifications, regulatory standards (ISO 10993, ISO 11137, ISO/ISTA 3A), and the outcomes of the GLP animal study. For the biocompatibility and sterilization, the "ground truth" aligns with the requirements outlined in the respective ISO standards and FDA guidance.

    8. The sample size for the training set

    This information is not applicable as there is no mention of a "training set" in the context of this device's evaluation. The device is not learning-based.

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

    This information is not applicable for the same reasons as #8.

    In summary:

    The approval of the Spirox INEX Device was based on demonstrating substantial equivalence to existing predicate devices through non-clinical performance data. This included mechanical and functional testing against product specifications, biocompatibility testing according to ISO standards and FDA guidance, sterilization validation, and packaging/shipping validation. A GLP animal study was also conducted to verify device safety, biocompatibility, and use. There was no mention of specific acceptance criteria with quantitative thresholds nor a study involving human readers or AI algorithms.

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