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510(k) Data Aggregation

    K Number
    K202898
    Date Cleared
    2021-12-30

    (457 days)

    Product Code
    Regulation Number
    878.4780
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Tzoar Negative Pressure Wound Therapy (NPWT) System is indicated for wound management via the application of negative pressure to the wound by the removal of wound exudate, infectious materials, and tissue debris from the wound bed. The Tzoar 207 Negative Pressure Wound Therapy (NPWT) System is indicated for the following wound types: chronic, acute, traumatic, subacute and dehisced wounds, partial-thickness burns, ulcers (such as diabetic or pressure), flaps and grafts.

    Device Description

    The Tzoar 207 Negative Pressure Wound Therapy (NPWT) System includes a pump and two types of dressings: Tzoar NPWT Foam Kits and Tzoar NPWT One Piece Dressing. The Tzoar 207 NPWT pump is a portable, battery powered pump which may promote wound healing through the drainage and removal of wound exudates, infectious material, and tissue debris from the wound bed using continuous and/or intermittent negative pressure. The Tzoar NPWT One Piece Dressing and the Tzoar NPWT Foam Kits are both Tzoar Wound Dressings intended to be used with an NPWT device to manage acute and chronic wounds.

    AI/ML Overview

    The provided document is a 510(k) premarket notification for the Tzoar 207 Negative Pressure Wound Therapy (NPWT) System. This type of submission focuses on demonstrating substantial equivalence to a legally marketed predicate device, rather than proving the device meets specific performance acceptance criteria through clinical studies directly, especially for AI/ML devices. Therefore, much of the requested information regarding acceptance criteria for AI models, study design, expert ground truth, and specific performance metrics for AI will not be present in this document.

    The document mainly covers the technological characteristics, performance tests of the device's physical functions, biocompatibility, and electrical safety.

    Here's an analysis based on the available information:

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

    The document does not explicitly state "acceptance criteria" in the context of an overall device performance metric that would be suitable for an AI/ML device. Instead, it lists several performance tests conducted on the physical device components. The conclusion drawn from these tests is that the device is "performing as intended" and is "substantially equivalent to the predicate."

    Here's a table summarizing the tests mentioned and the general conclusion:

    Test Report No.Test Report TitleAcceptance Criteria (Explicitly Stated)Reported Device Performance
    TR27.0006Tzoar 207 NPWT Canister Presence Sensor Test ReportNot explicitly statedPerforming as intended
    TR27.0007Tzoar 207 NPWT Canister Hook TestNot explicitly statedPerforming as intended
    TR27.0008Tzoar 207 NPWT Canister Air-Tightness TestNot explicitly statedPerforming as intended
    TR27.0010Tzoar207 NPWT Canister Air filter water resistance verification TestNot explicitly statedPerforming as intended
    TR27.0011Tzoar 207 NPWT Canister Solidifier Expansion Parameter Test ReportNot explicitly statedPerforming as intended
    TR27.0013Tzoar 207 NPWT System Pressure Accuracy Test ReportNot explicitly statedPerforming as intended
    TR27.0014Tzoar 207 NPWT System Air Flow Rate TestNot explicitly statedPerforming as intended
    TR27.0025Tzoar 207 NPWT System performance test with One Piece Dressing TestNot explicitly statedPerforming as intended
    TR27.0027Tzoar 207 NPWT System Performance test with Foam KitNot explicitly statedPerforming as intended
    TR27.0032Tzoar 207 NPWT System Battery Life Test ReportNot explicitly statedPerforming as intended
    TR27.0033Tzoar 207 NPWT System Battery Performance Testing ReportNot explicitly statedPerforming as intended
    BiocompatibilityISO 10993-5, -10, -11, -6Compliance with ISO standardsMet standards
    Electrical Safety & EMCIEC 60601-1, -1-2, -1-6, -1-11Compliance with IEC standardsMet standards

    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 does not describe a "test set" in the context of data for an AI/ML device. The "tests" mentioned are for the physical components and functionality of the NPWT system. The sample sizes for these physical performance tests are not specified in this summary document. Data provenance is not applicable as this is a device clearance, not an AI model clearance.

    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)

    Not applicable. This device is a Negative Pressure Wound Therapy system, which is a physical medical device. It does not appear to incorporate AI/ML technology that would require expert-established ground truth on a test set of data.

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

    Not applicable, as there is no mention of a test set requiring adjudication for AI/ML performance.

    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. This device is a physical wound therapy system and does not involve human "readers" or AI assistance in interpretation.

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

    Not applicable, as this is a physical medical device, not an algorithm or AI.

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

    Not applicable. The "ground truth" for this device would be its ability to perform its stated functions (e.g., maintain pressure, seal, battery life) according to engineering specifications and relevant standards. This is assessed through physical performance tests, not through expert review of data or pathology.

    8. The sample size for the training set

    Not applicable. This is a physical medical device, not an AI/ML model.

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

    Not applicable. This is a physical medical device, not an AI/ML model.

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