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510(k) Data Aggregation
(23 days)
U by Kotex**®** Click**®** Unscented Menstrual Tampons
U by Kotex® Click® Unscented Menstrual Tampon is an unscented tampon inserted into the vagina to absorb menstrual fluid.
The U by Kotex® Click® Unscented Menstrual Tampon is a conventional unscented menstrual tampon consisting of an absorbent pledget and a telescoping three-piece plastic applicator. The device will be manufactured in Regular, Super, and Super Plus absorbencies. The absorbent pledget consists of an absorbent core of radially wound rayon ribbon compressed into a grooved cylinder with a rounded, bullet-like tip, a non-woven overwrap cover, and a rayon-polyester blend withdrawal string. The three-piece applicator consists of an outer insertion tube (barrel) with a textured grip and formed with a closed, rounded tip in a petal-like design, a clear middle telescopic tube (telescope), and an elongated insertion tube (plunger). Each tampon is individually sealed in a plastic film primary wrapper and then packaged in sealed multi-unit containers for retail sale.
The document describes a 510(k) submission for a medical device, which generally means comparing a new device to a legally marketed predicate device to demonstrate substantial equivalence. For this type of submission, extensive acceptance criteria and detailed clinical studies as might be found for novel technologies are often not present in the same format. Instead, the focus is on showing that the modified device performs as safely and effectively as the predicate.
Based on the provided text, here's a breakdown of the requested information:
1. A table of acceptance criteria and the reported device performance
The document does not explicitly present a table of acceptance criteria with corresponding performance for a test set. Instead, it states that the device was assessed against various standards and guidance documents. The "Performance" column in Table 05-02 indicates the outcome of the tests, rather than specific numerical acceptance criteria. Similarly, for other performance characteristics, the document states they "were assessed in accordance with the 2005 FDA guidance document," implying compliance with the requirements within that guidance, but without listing specific numerical targets.
However, we can infer some "performance" outcomes from the biocompatibility tests:
Acceptance Criteria (Implied) | Reported Device Performance |
---|---|
Non-Genotoxic (MLA) | Non-Genotoxic |
Non-Genotoxic (AMES) | Non-Genotoxic |
Non-Genotoxic (Mouse Micronucleus) | Non-Genotoxic |
Non-cytotoxic | Non-cytotoxic |
Non-irritating | Non-irritating |
Non-sensitizing | Non-sensitizing |
Not Systemically Toxic | Not Systemically Toxic |
Absorbency range in accordance with FDA guidance | Assessed and implies compliance |
Chemical residues in accordance with FDA guidance | Assessed and implies compliance |
Withdrawal string strength in accordance with FDA guidance | Assessed and implies compliance |
Fiber Shedding in accordance with FDA guidance | Assessed and implies compliance |
Wet and Dry Tampon Integrity in accordance with FDA guidance | Assessed and implies compliance |
Expulsion Force in accordance with FDA guidance | Assessed and implies compliance |
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 states, "No clinical tests were performed as part of this device modification." Therefore, there is no clinical test set, sample size, or specific data provenance (country, retrospective/prospective) for clinical performance in the traditional sense. The performance data discussed relates to non-clinical laboratory testing. The document does not specify sample sizes for these non-clinical tests (e.g., how many tampons were tested for absorbency, string strength, etc.).
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable. Since no clinical tests were performed and no human interpretation of data for diagnostic purposes is relevant to this device, no "experts" in the context of establishing ground truth for a test set are mentioned. The testing was conducted against regulatory standards and guidelines by presumably qualified laboratory personnel.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. This device is a menstrual tampon, and the performance assessment is based on physical and chemical properties and biocompatibility, not on a diagnostic interpretation requiring adjudication of results from multiple readers.
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 menstrual tampon and does not involve AI or human readers for diagnostic purposes.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
Not applicable. This device is a physical medical device (menstrual tampon), not an algorithm or software.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
For the non-clinical tests, the "ground truth" is defined by the established regulatory standards and guidance documents (e.g., ISO 10993 series for biocompatibility, 2005 FDA guidance for tampons for performance characteristics). Compliance with these standards indicates acceptable performance. There isn't a "ground truth" derived from expert consensus, pathology, or outcomes data in the typical sense applied to diagnostic devices.
8. The sample size for the training set
Not applicable. This is a 510(k) submission for a physical medical device, not an AI or machine learning device requiring a training set.
9. How the ground truth for the training set was established
Not applicable for the reason mentioned above.
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