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510(k) Data Aggregation
(21 days)
SpaceOAR System
SpaceOAR System is intended to temporarily position the anterior rectal wall away from the prostate during radiotherapy for prostate cancer and in creating this the intent of SpaceOAR System to reduce the radiation dose delivered to the anterior rectum.
The SpaceOAR System is composed of biodegradable material and maintains space for the entire course of prostate radiotherapy treatment and is completely absorbed by the patient's body over time.
The SpaceOAR Hydrogel System consists of components for the preparation of a synthetic, absorbable hydrogel spacer and a delivery mechanism provided in a sterile, single use package. The SpaceOAR hydrogel is a synthetic, absorbable polyethylene glycol (PEG)based hydrogel that upon injection creates a space that temporarily positions the anterior rectal wall away from the prostate during radiotherapy for prostate cancer, and in creating this space it is the intent of the perirectal spacer to reduce the radiation dose delivered to the anterior rectum. SpaceOAR hydrogel is completely synthetic with no animal or human derived components. It is composed of biodegradable material and maintains space for the entire course of prostate radiotherapy treatment (approximately 3 months) and is completely absorbed by the patient's body over time (approximately 6 months).
This submission describes a modification to an already cleared device (SpaceOAR Hydrogel System), not a new device requiring a full de novo clearance or a new 510(k) for a substantially different device. Therefore, the "acceptance criteria" and "study" described are focused on demonstrating that the modified device performs equivalently to the predicate device and does not introduce new safety or effectiveness concerns, rather than establishing efficacy of the device from scratch.
Here's a breakdown of the requested information based on the provided text, recognizing the context of a device modification:
Description of Acceptance Criteria and the Study Proving Device Meets Acceptance Criteria
The acceptance criteria for the modified SpaceOAR System are implicitly defined as demonstrating that the changes do not negatively impact the device's functional and performance specifications compared to the predicate device and that it remains biologically safe.
The study described is a series of design verification tests and assessments conducted to confirm that the modified device continues to function as intended and is substantially equivalent to the previously cleared SpaceOAR System (K181465).
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria (Implicit) | Reported Device Performance |
---|---|
Functional and Performance Equivalence to Predicate Device | Verified through repetition of design verification tests, confirming the modified device meets the same functional and performance specifications as the predicate. |
- Sterilization Validation | "Sterilization Validation" was repeated and confirmed. |
- Shelf Life Testing | "Shelf Life Testing" was repeated and confirmed. |
- System Needle to Hub Tensile Strength | "System Needle to Hub Tensile Strength" was repeated and confirmed. |
- Fluid Connection | "Fluid Connection" was repeated and confirmed. |
- SpaceOAR Hydrogel System Prep and Assembly Time | "SpaceOAR Hydrogel System Prep and Assembly Time" was repeated and confirmed. |
- PEG Vial Puncture Force | "PEG Vial Puncture Force" was repeated and confirmed. |
- Packaging Performance Testing | "Packaging Performance Testing" was repeated and confirmed. |
Biological Safety Equivalence | "A risk-based biocompatibility assessment of these limited changes indicates that no new biocompatibility testing is required to assess the proposed device change. The proposed SpaceOAR System is biologically safe for its intended use." This implies the acceptance criterion of not introducing new biocompatibility risks was met. |
No New Issues of Safety or Effectiveness | "The conclusion of the assessments demonstrates that the modified device continues to function as intended in a manner equivalent to the predicate device. The modified device raises no new issues of safety or effectiveness compared to the predicate." This is the overarching conclusion related to meeting general safety and effectiveness acceptance criteria for device modifications. |
2. Sample Size Used for the Test Set and the Data Provenance
The document does not explicitly state the specific sample sizes for each of the repeated design verification tests (e.g., number of units tested for tensile strength, shelf life, etc.). It only mentions that the tests were "repeated."
Data Provenance: The testing appears to be internal design verification and validation testing conducted by Boston Scientific Corporation. The provenance is internal company data, not clinical data from external sources.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts
Not applicable. This device modification submission relies on engineering design verification and validation testing to demonstrate equivalence, not on expert-adjudicated clinical ground truth for a test set. Clinical data and expert ground truth were not used for this specific submission given the "limited changes to device components, packaging and labeling."
4. Adjudication Method for the Test Set
Not applicable. As noted in point 3, this was not a clinical study requiring expert adjudication of a test set. The assessment relied on a risk analysis to determine the necessary verification tests.
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. The SpaceOAR System is a medical device (hydrogel spacer), not an AI-powered diagnostic or assistive technology for human readers. Therefore, an MRMC study comparing human readers with and without AI assistance is irrelevant to this submission.
6. If a Standalone (i.e. algorithm only, without human-in-the-loop performance) Was Done
Not applicable. The SpaceOAR System is a physical medical device, not an algorithm, so standalone algorithm performance is not relevant.
7. The Type of Ground Truth Used
For this specific submission (device modification), the "ground truth" is essentially the established performance specifications and safety profile of the predicate device (K181465). The "study" aims to verify that the modified device continues to meet these same engineering specifications and does not introduce new safety concerns.
8. The Sample Size for the Training Set
Not applicable. This submission concerns a physical medical device and its manufacturing/component changes, not a machine learning model that requires a training set.
9. How the Ground Truth for the Training Set Was Established
Not applicable. As noted in point 8, there is no training set for a machine learning model in this submission.
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(21 days)
SpaceOAR System
SpaceOAR Hydrogel System is intended to temporarily position the anterior rectal wall away from the prostate during radiotherapy for prostate cancer and in creating this space it is the intent of SpaceOAR Hydrogel System to reduce the radiation dose delivered to the anterior rectum. The SpaceOAR Hydrogel System is composed of biodegradable material and maintains space for the entire course of prostate radiotherapy treatment and is completely absorbed by the patient's body over time.
The SpaceOAR® Hydrogel System consists of components for the preparation of a synthetic, absorbable hydrogel spacer and a delivery mechanism provided in a sterile, single use package. The SpaceOAR® hydrogel is a synthetic, absorbable polyethylene glycol (PEG)-base hydrogel that upon injection creates a space that temporarily positions the anterior rectal wall away from the prostate during radiotherapy for prostate cancer and in creating this space it is the intent of the perirectal spacer to reduce the radiation dose delivered to the anterior rectum. SpaceOAR® hydrogel is completely synthetic with no animal or human derived components. It is composed of biodegradable material and maintains space for the entire course of prostate radiotherapy treatment (approximately 3 months) and is completely absorbed by the patient's body over time (about 6 months).
The SpaceOAR® Hydrogel System consists of two syringes containing the PEG Precursor solution and the Accelerator solution (a buffered salt solution). The Precursor solution is formed by the user through the reconstitution of PEG powder with a Diluent (Trilysine buffer) solution (that is provided in a third syringe. The Accelerator solution is provided ready for use. The Syringes filled with the Precursor solution and the Accelerator solution are assembled with other applicator components, including a Yconnector for mixing the Precursor and Accelerator, and a needle to facilitate delivery of the hydrogel by injection to the tissue located between the anterior rectal wall and the prostate.
This document is an FDA 510(k) summary for the SpaceOAR Hydrogel System. It is primarily focused on demonstrating substantial equivalence to a previously cleared predicate device, rather than providing detailed acceptance criteria and study results for a new device's performance.
Therefore, many of the requested items (e.g., sample size for test set, number of experts for ground truth, MRMC study, training set details) are not present in this type of FDA submission. The submission relies on the established performance of the predicate device.
Here's an analysis based on the provided text:
1. A table of acceptance criteria and the reported device performance
The document states: "The subject SpaceOAR® Hydrogel System met all acceptance criteria for verification and validation." However, it does not list specific quantitative acceptance criteria or their corresponding performance results in a table format. It only lists categories of tests performed.
Acceptance Criteria Category | Reported Device Performance |
---|---|
Sterilization Validation | Met all acceptance criteria |
Modulus Testing | Met all acceptance criteria |
Gel Volume (Swell) Testing | Met all acceptance criteria |
Gel Time Testing | Met all acceptance criteria |
Pot Life Testing | Met all acceptance criteria |
Endotoxin Testing | Met all acceptance criteria |
2. Sample size used for the test set and the data provenance
The document does not specify a sample size for a "test set" or provide data provenance in the context of clinical performance for the subject device. The submission relies on equivalence to a predicate device. The performance data listed (sterilization, modulus, etc.) are engineering/laboratory tests.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This information is not provided as the submission does not detail a clinical study with a "test set" requiring expert ground truth in the traditional sense of diagnostic AI or imaging device evaluation.
4. Adjudication method for the test set
This information is not provided for the reasons stated above.
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
An MRMC comparative effectiveness study was not mentioned or provided in this 510(k) summary. This type of study is typically for diagnostic imaging devices and AI systems, not for a physical implantable device like a hydrogel spacer.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
This concept is not applicable to the SpaceOAR Hydrogel System, which is a physical medical device and not an algorithm.
7. The type of ground truth used
For the engineering/laboratory tests listed (Sterilization Validation, Modulus Testing, etc.), the "ground truth" would be established by pre-defined engineering specifications and validated test methods. The submission implies that the results of these tests (e.g., sterilization effectiveness, material properties like modulus, gel volume, gel time, pot life, endotoxin levels) adhered to these specifications.
8. The sample size for the training set
This information is not applicable/not provided as this is a physical device, not an algorithm that requires a training set.
9. How the ground truth for the training set was established
This information is not applicable/not provided as this is a physical device.
Summary of Device Performance (based on this 510(k) summary):
The 510(k) application for the SpaceOAR Hydrogel System (K181465) demonstrates substantial equivalence to its predicate device (cleared under DEN140030). The core argument is that the subject device has identical design, materials, and sterilization cycle to the predicate device.
To support this claim, the manufacturer performed several verification and validation tests:
- Sterilization Validation: Confirmed the device's sterility.
- Modulus Testing: Evaluated the material's stiffness/elasticity.
- Gel Volume (Swell) Testing: Assessed how much the hydrogel swells.
- Gel Time Testing: Measured the time it takes for the components to form a gel.
- Pot Life Testing: Determined how long the mixed components remain viable for use.
- Endotoxin Testing: Ensured the absence of harmful bacterial endotoxins.
The document explicitly states: "The subject device is identical to the predicate device in design, materials and sterilization cycle; therefore, biocompatibility testing, shelf life testing, and clinical data were not required to support a determination of substantial equivalence." This means that the clinical performance and safety of the device are inferred from the predicate device, and the current submission focuses on verifying the manufacturing and design equivalence of the new device to the existing one. The "acceptance criteria" here largely pertain to meeting the engineering specifications and demonstrating manufacturing consistency with the already-cleared device.
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(182 days)
SpaceOAR System
SpaceOAR System is intended to temporarily position the anterior rectal wall away from the prostate during radiotherapy for prostate cancer and in creating this space it is the intent of SpaceOAR System to reduce the radiation dose delivered to the anterior rectum. The SpaceOAR System is composed of biodegradable material and maintains space for the entire course of prostate radiotherapy treatment and is completely absorbed by the patient's body over time.
SpaceOAR System is a polyethylene glycol (PEG) hydrogel that upon injection creates a space that temporarily positions the anterior rectal wall away from the prostate during radiotherapy for prostate cancer with the intent to reduce the radiation dose delivered to the anterior rectum. The SpaceOAR System consists of components for the preparation of a synthetic, absorbable hydrogel spacer and a delivery mechanism provided in a sterile, single use package. Once assembled as shown in the figure above, the Y-connector allows for hydrogel injection via an 18 gauge needle. The spacer is formed by mixing two solutions, the Precursor and the Accelerator. The Precursor solution is formed through the mixing of the Diluent solution (Trilysine buffer solution) with the PEG powder. The Accelerator solution is a salt buffer solution.
This document describes the regulatory decision for the SpaceOAR System, an absorbable perirectal spacer. It outlines the acceptance criteria (defined as "Special Controls" by the FDA) and summarizes the study used to demonstrate the device meets these criteria.
Acceptance Criteria and Reported Device Performance
The FDA's special controls serve as the acceptance criteria for the absorbable perirectal spacer. The device's performance, as reported in the clinical study, is summarized below:
Acceptance Criteria (Special Controls) | Reported Device Performance and Evidence |
---|---|
1. Non-clinical and Clinical Performance Testing | Based on independent Core Lab measurements, 97.3% [95% CI: 93.2, 99.3] of SpaceOAR treated subjects achieved a >25% reduction in rV70. Clinical results showed that the primary effectiveness hypothesis was met (percent of SpaceOAR subjects with 25% reduction in dose in the rectal V70 region was > 70% with statistical significance, p25% reduction in rV70." |
- The specific number and qualifications of experts for the CEC or Core Lab are not detailed in the provided text.
4. Adjudication method for the test set:
- Adverse events were reviewed by an independent Clinical Events Committee (CEC). This suggests an adjudication process, but the specific rules (e.g., majority vote, single expert decision, etc.) for the CEC are not described.
- Rectal V70 reduction measurements were assessed by an independent Core Lab, implying expert review and calculation, but the details of their adjudication (if any across multiple readers) are 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:
- No, this was not an MRMC comparative effectiveness study involving human readers and AI assistance.
- This study was a head-to-head comparison of a physical medical device (SpaceOAR System) versus a control group (no spacer) in the context of prostate cancer radiation therapy, focusing on the device's ability to reduce rectal radiation dose and associated adverse events. It does not involve AI or human interpretation performance.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- No, this is not applicable. The SpaceOAR System is a physical medical device (a hydrogel spacer), not an algorithm or AI system. Therefore, standalone algorithm performance was not relevant or assessed.
7. The type of ground truth used:
- Clinical Outcomes/Measurements:
- Primary Effectiveness Endpoint: Percentage of subjects achieving a >25% reduction in rV70 (rectal volume receiving at least 70Gy). This was measured via "independent Core Lab measurements" and "investigator measurements," which rely on medical imaging (likely CT scans used for treatment planning) and calculation of radiation dose distribution.
- Primary Safety Endpoint: Proportion of subjects with Grade 1 or greater rectal adverse events or procedure adverse events through 6 months. This was based on clinical assessment of adverse events reviewed by an independent Clinical Events Committee.
- Secondary Endpoints included incidence of CTCAE Grade 1 or greater or Grade 2 or greater rectal or procedural events, changes in EPIC Urinary and Sexual domains, and medication changes.
- Non-clinical Ground Truth: Bench testing used predefined performance specifications (e.g., gel time, pot life, swelling, in vitro disappearance). Animal studies used observations of hydrogel behavior, tissue response, and absorption.
8. The sample size for the training set:
- Not applicable in the conventional sense for an AI/algorithm. The clinical study described is the primary clinical evidence for the device's effectiveness and safety, not a training set for an algorithm.
- However, the document does mention "long term follow up from the European and US clinical trials and post market AE data on over 2600 SpaceOAR System since CE Mark approval in 2010 and Australian TGA approval in 2011" as additional supporting evidence for safety, particularly regarding long-term toxicity which could be considered a form of real-world "training" or validation data if one were to stretch the analogy. This data was not described as a formal training set for an algorithm.
9. How the ground truth for the training set was established:
- Not applicable, as there was no AI/algorithm training set. The clinical study formed the basis for establishing the device's performance against its intended use and safety profile through rigorous scientific methodology (randomized controlled trial with pre-defined endpoints and independent review).
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