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510(k) Data Aggregation

    K Number
    K241853
    Date Cleared
    2024-11-07

    (133 days)

    Product Code
    Regulation Number
    892.5700
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Titanium Fletcher-Style Applicator Set Defined Geometry; Smit Cervical Sleeve

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

    The Titanium Fletcher-style Applicator Set - Defined Geometry is indicated for use for cancer treatment of the uterus, cervix, paracervix, endometrium and vagina using HDR or PDR brachytherapy.

    The Smit Cervical Sleeves are indicated for use where any intrauterine tandem is used for HDR or PDR brachytherapy.

    Device Description

    The Titanium Fletcher-style Applicator Set – Defined Geometry is intended for use for cancer treatment of the uterus, cervix, paracervix, endometrium and vagina when performing HDR or PDR brachytherapy.

    The device does not contain or consist of software/firmware. The device does not contain any biologics or drug components. The device has patient-contacting materials. The device is designed for repeated use. No parts of the system are provided sterile. The device can be steam sterilized with common parameters using pre-vacuum sterilization.

    The Titanium Fletcher-Style Applicator Set Defined Geometry includes patients whose cancer can be treated using HDR or PDR brachytherapy, as determined by the prescribing physician. The Titanium Fletcher-Style Applicator Set Defined Geometry is intended to be used in a healthcare or treatment facility by trained and qualified personnel.

    This 510(k) submission is also inclusive of the Smit Cervical Sleeve which is an optional component that may be used with the Titanium Fletcher Style Applicator Set Defined Geometry but is not required to successfully perform the intended use.

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for a medical device, the "Titanium Fletcher-Style Applicator Set Defined Geometry" and "Smit Cervical Sleeves" by Varian Medical Systems, Inc. This document focuses on demonstrating substantial equivalence to a previously cleared predicate device, rather than proving that a new AI/software-based device meets specific acceptance criteria through a clinical study.

    The acceptance criteria and study information requested in your prompt (e.g., sample size for test sets, data provenance, number of experts for ground truth, MRMC study, standalone performance, ground truth types for training/test sets) are highly relevant for AI-powered medical devices (software as a medical device - SaMD). However, this 510(k) submission is for a physical medical device used in brachytherapy, not an AI or software device.

    Therefore, many of the specific questions in your prompt are not applicable to this non-AI medical device submission. The document details the device's technical specifications, intended use, indications for use, and a comparison to a predicate device to argue for substantial equivalence. The "performance testing" mentioned is primarily non-clinical (biocompatibility, MR compatibility, cleaning/sterilization, human factors, mechanical/acoustic testing), focusing on the device's physical properties and safety, not its diagnostic or therapeutic performance in a statistical sense that would require large clinical studies with ground truth derived from experts or pathology.

    Here's a breakdown based on the provided text, addressing the points where information is available and noting where it's not applicable:


    Acceptance Criteria and Device Performance (for a non-AI physical device)

    The concept of "acceptance criteria" for this type of physical device is framed around demonstrating that its design and performance characteristics are equivalent to or do not raise new questions of safety and effectiveness compared to a legally marketed predicate device. The "performance" is primarily assessed through non-clinical laboratory testing to ensure physical integrity, material compatibility, and functionality within its intended use.

    Table of Acceptance Criteria and Reported Device Performance (as inferred for a non-AI device through a 510(k))

    Acceptance Criteria Category (Inferred from 510(k) process for physical devices)Specific Criteria (Implicit for Substantial Equivalence)Reported Device Performance/Compliance
    Intended Use & Indications for Use EquivalenceDevice's intended use and indications for use are substantially similar to predicate, or differences do not raise new safety/effectiveness questions. Added paracervix.Claimed: "Although this change adds an additional anatomical site, the manner in which the device is used is consistent with the anatomical area that was originally cleared and does not introduce an additional risk of being used in a generalized treatment application. The overall intended use to treat cancer with brachytherapy is unchanged." (p. 1
    Material BiocompatibilityMaterials are biocompatible for patient contact.Compliance: Meets ISO 10993-1 and applicable parts.
    MR CompatibilityDevice is safe for use in magnetic resonance environments.Compliance: MR Conditional; complies with ASTM F2503-23.
    Cleaning, Disinfection, and Sterilization (CDS)Device can be effectively cleaned, disinfected, and sterilized; maintains integrity over specified cycles.Demonstrated: Testing conducted to show effective sterilization and durability for specified cycles (e.g., sterilization cycle updated to 250 & 500 times from 100 & 500 times).
    Human Factors/UsabilityDevice performs as intended for intended users, uses, and use environments. (Non-clinical validation)Demonstrated: Human factors validation study conducted per IEC 62366.
    Mechanical Integrity/PerformanceDevice maintains structural integrity and performs its mechanical functions as designed.Demonstrated: Formal design validation testing, design verification testing, and design validation testing confirming performance as intended, in accordance with FDA QSR (21 CFR §820), ISO 13485, and ISO 14971.
    Compatibility with AfterloadersDevice is compatible with specified brachytherapy afterloaders.Confirmed: Compatible with GammaMedplus Series, VariSource Series, and addition of BRAVOS Afterloader System.
    Safety Standards ComplianceDevice conforms to relevant safety and performance consensus standards.Compliance: Utilized FDA-recognized voluntary consensus standards including ISO 13485, ISO 14971, ISO 15223-1, ISO 20417, IEC 62366-1, ISO 11737-2, ISO 17664-1, ISO 11607-1, ISO 17665-1, various ISO 10993 parts, EN 60601-1, and EN 60601-2-17. (p. 10-11)

    Study Information (as applicable to a non-AI physical device 510(k) submission):

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

      • N/A (for clinical performance data): This is a submission for a physical device, not an AI/software device requiring a clinical test set for performance evaluation (e.g., diagnostic accuracy). The "testing" refers to non-clinical lab tests (biocompatibility, MR, mechanical, sterilization, human factors).
      • For the non-clinical tests (e.g., sterilization cycles, human factors study), the sample size would be determined by the specific ISO/ASTM standards referenced, but typically isn't a large "test set" in the sense of clinical cases. The document does not specify these sample sizes.
      • Data Provenance: Not applicable in the context of clinical data for a physical device. Testing is conducted in a laboratory environment, not on patient data from specific countries.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

      • N/A: Ground truth established by medical experts is not listed as a component of this non-AI device's performance testing for 510(k) clearance. The device's "performance" is assessed through engineering testing against physical and safety standards and comparison to a predicate.
    3. Adjudication method (e.g., 2+1, 3+1, none) for the test set:

      • N/A: Not applicable as there is no clinical test set requiring expert adjudication for accuracy or performance.
    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 not an AI-powered device, so an MRMC study comparing human performance with and without AI assistance was not conducted.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

      • N/A: This is a physical medical device, not an algorithm.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

      • N/A: "Ground truth" in the sense of clinical reference standards (pathology, expert consensus) is not applied to this type of 510(k) submission for a non-AI physical device. The "truth" or reference is established by engineering specifications, material standards, and functional test results (e.g., "does it sterilize correctly?", "is it MR compatible?").
    7. The sample size for the training set:

      • N/A: This is not a machine learning/AI device, so there is no training set in the AI sense.
    8. How the ground truth for the training set was established:

      • N/A: Not applicable.

    In summary: The provided document is a 510(k) letter for a physical brachytherapy applicator set, demonstrating substantial equivalence to a predicate device. The regulatory pathway for such devices involves rigorous non-clinical testing (e.g., material testing, mechanical testing, sterilization validation) and a comparison of technical characteristics to a predicate, rather than large-scale clinical performance studies or AI-specific validation methods outlined in your prompt.

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    K Number
    K120731
    Date Cleared
    2012-06-06

    (89 days)

    Product Code
    Regulation Number
    892.5700
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    TITANIUM FLETCHER-STYLE APPLICATOR SET-DEFINED GEOMETRY

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

    The Titanium Fletcher-style Applicator Set with defined geometry was developed for brachytherapy treatment of cancer of the uterus, cervix, endometrium and vagina.

    Device Description

    The GM11006200 Titanium Fletcher-Style Applicator Sets are designed for intracavitary radiotherapy treatments in the uterus, cervix, endometrium and vagina. They are compatible with Varian afterloaders and can be used in combination with the appropriate accessories.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and study information for the "Titanium Fletcher-Style Applicator Set," based on the provided 510(k) summary:

    This device is not an AI/ML device, but a physical medical device. Therefore, the questions related to AI/ML specific studies (MRMC comparative effectiveness study, standalone algorithm performance, training set details) are not applicable. The provided document is a 510(k) summary which focuses on demonstrating substantial equivalence to a predicate device, rather than providing detailed clinical study results of performance against acceptance criteria in the way an AI/ML device would.


    1. Table of Acceptance Criteria and Reported Device Performance

    The 510(k) summary for the Titanium Fletcher-Style Applicator Set does not explicitly state "acceptance criteria" in terms of performance metrics (like accuracy, sensitivity, specificity) as one would expect for a diagnostic or AI-based device. Instead, the "acceptance criteria" are implied by demonstrating substantial equivalence to a predicate device (K980590 Henschke Type GYN Applicator Set) through a comparison of technological characteristics. The performance is measured by compliance with these characteristics and validation of new features.

    Feature/SpecificationPredicate Device (K980590 Henschke Type GYN Applicator Set)New Device (Titanium Fletcher-Style Applicator Set-Defined Geometry)Acceptance Criteria (Implied)Reported Device Performance
    Clearance NumberK980590N/AN/AN/A
    Compatible AfterloaderVariSourceGammaMed plus, GammaMed 12i(t), VariSourceCompatibility with afterloaders for brachytherapy.The new device is compatible with GammaMed plus, GammaMed 12i(t), and VariSource afterloaders, demonstrating broader compatibility while retaining compatibility with the VariSource (like the predicate).
    Intended UseRadiation brachytherapy in the uterus and cervix.To treat cancer of the uterus, cervix, endometrium, and vagina.Same or similar intended use for brachytherapy.The intended use for the new device is consistent with the predicate, with explicit mention of endometrium and vagina, suggesting a slightly expanded, but still within scope, application for brachytherapy.
    Indications for UseHDR radiation treatment of the cervix and uterus.Brachytherapy treatment of cancer of the uterus, cervix, endometrium and vagina.Same or similar indications for use.Indications are for brachytherapy in the uterus and cervix (like predicate) and additionally includes endometrium and vagina. This is considered substantially equivalent.
    DesignRigid intra-uterine tandem and interlocking colpostats.Intrauterine Probe with stopper (30°, lengths: 40mm, 60mm, 80mm; optional 30mm, 50mm, 70mm); Colpostats: 20mm, 25mm, 30mm spread.Functional design for intracavitary radiotherapy.The new device features an intrauterine probe with specific angles and lengths, and colpostats with defined spreads, indicating a compatible and regulated design for intracavitary application.
    MaterialsStainless Steel, Polysulphone, TungstenPEEK Titanium, stainless steel, PPSU.Biocompatible materials suitable for medical devices.Uses PEEK Titanium, stainless steel, and PPSU, which are common and accepted materials for medical devices, expected to be biocompatible and robust.
    PackingIndividualIndividualIndividual packaging for hygiene and sterility maintenance.Consistent with predicate.
    SterilityProvided Non-sterileProvided Non-sterileDevice is intended for post-purchase sterilization by user.Consistent with predicate.
    Sterilization MethodEtO Gas sterilization or Steam sterilizationSteam sterilizationValidated sterilization method suitable for the device materials.Validated for Steam sterilization (15min @ 121°C, 5min @ 134°C, 18min @ 134°C), which is a common and effective method.
    Sterilization Conditions30 minutes ±2 minutes at 250°F±5°F (121°C±1°C).15minutes @121°C, 5 minutes @134°C, 18 minutes @134°CEffective sterilization parameters.Specific steam sterilization parameters are provided, demonstrating validated sterilization efficacy for the device.
    BiocompatibilityNot mentioned.Full biocompatibilityDevice materials are biocompatible for patient contact.Explicitly states "Full biocompatibility," indicating testing and compliance with relevant standards. (This is an improvement/clarification over the predicate but supports safety).
    Anatomical SitesUterus, cervix.Uterus, cervix, endometrium, vagina.Anatomical sites consistent with intended use.Expanded to include endometrium and vagina, which aligns with the slightly broadened indications for use and is considered safe and effective in the context of brachytherapy.
    **Compatibility with environment/
    other devices**Not stated to be CT compatible or MR Conditional for 3 Tesla.CT compatible, MR Conditional for 3 Tesla.Functionality in modern imaging environments.The new device is CT compatible and MR Conditional for 3 Tesla, which are significant improvements over the predicate, enhancing its usability in modern clinical settings. This adds utility without changing the fundamental safety or effectiveness of brachytherapy delivery.
    Rectal RetractorNot included as optional accessory.Included as optional accessory.Provision of necessary accessories for safe and effective use.The inclusion of a rectal retractor as an optional accessory enhances a clinician's ability to protect adjacent organs, improving safety and functionality.

    2. Sample Size Used for the Test Set and Data Provenance

    For a 510(k) submission of a physical medical device like this, there isn't a "test set" in the sense of a dataset of patient images or clinical outcomes used for an algorithm's performance evaluation.

    Instead, "testing" involves:

    • Engineering verification and validation (e.g., material testing, sterilization validation, dimensional accuracy, compatibility with afterloaders).
    • Biocompatibility testing.
    • MR compatibility testing.

    The document does not specify numerical "sample sizes" for these tests in terms of patient data. The provenance of such testing data would typically be from in-house lab testing, vendor testing, and potentially external accredited labs. Such testing is based on established engineering and materials standards, not patient data in the context of a "test set" for an AI device.


    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications

    This question is not applicable. The device is a physical medical instrument, not an AI/ML algorithm that requires expert-established ground truth from diagnostic images or clinical data.


    4. Adjudication Method for the Test Set

    This question is not applicable. There is no "adjudication method" in the context of a physical device's engineering validation or biocompatibility testing. These tests are evaluated against predefined specifications and standards.


    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done

    No, an MRMC comparative effectiveness study was not done. This type of study is relevant for evaluating the impact of an AI diagnostic aid on human reader performance, which is not applicable to a physical brachytherapy applicator.


    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

    No, a standalone algorithm performance study was not done. This is a physical device, not an algorithm.


    7. The Type of Ground Truth Used

    For this physical device, the "ground truth" used for its validation would be:

    • Engineering Specifications and Standards: Compliance with dimensional tolerances, material strength, compatibility interfaces.
    • Biocompatibility Standards: Compliance with ISO 10993 series.
    • Sterilization Validation Protocols: Efficacy of sterilization cycle.
    • MR Compatibility Standards: Performance under MR conditions.

    It's not "expert consensus, pathology, or outcomes data" in the typical sense for a diagnostic device.


    8. The Sample Size for the Training Set

    This question is not applicable. The device is a physical instrument and does not involve a "training set" in the context of machine learning.


    9. How the Ground Truth for the Training Set Was Established

    This question is not applicable. The device is a physical instrument and does not involve a machine learning training set or its associated ground truth establishment.

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