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510(k) Data Aggregation
(120 days)
Ultra-Fast Vitri; Ultra-Fast Warm
Ultra-Fast Vitri is indicated for use in the preparation, vitrification and storage of oocytes (MII).
Ultra-Fast Warm is indicated for use in the preparation and warming of vitrified oocytes(MII).
The Ultra-Fast Vitri and Ultra-Fast Warm is composed of a set of three media to vitrify and warm oocytes for assisted reproductive technology (ART) procedures.
The Ultra-Fast Vitri includes two components, Equilibration Solution (ES) and Vitrification Solution (VS), containing the cryoprotectants ethylene glycol and dimethyl sulfoxide. There are two vitrification procedures to choose from. During the vitrification process, oocytes are first exposed to ES then in VS within several minutes. Using this methodology, permeating cryoprotectants can replace water in the oocytes prior to vitrification and storage in liquid nitrogen. The Ultra-Fast Vitri comes prepackaged with 1.5 mL vial or 4 mL vial of ES, three 1.5 mL vials or three 4 mL vials of VS.
Ultra-Fast Warm is composed of one media used for warming and removing cryoprotectants from vitrified oocytes. It is composed of Thawing Solution (TS). The Ultra-Fast Warm comes pre-packaged with four 4.0 ml vials of TS.
All the media in the Ultra-Fast Vitri and Ultra-Fast Warm contain Gentamicin. The media undergoes aseptic filtration, while the vials are sterilized by radiation.
Based on the provided FDA 510(k) Clearance Letter, here's a description of the acceptance criteria and the study that proves the device meets them:
Device: Ultra-Fast Vitri; Ultra-Fast Warm
Description: A set of three media used for the vitrification (cryopreservation) and warming of oocytes (MII) for Assisted Reproductive Technology (ART) procedures.
Acceptance Criteria and Reported Device Performance
The core acceptance criteria for this device, as demonstrated through non-clinical and clinical performance data, revolve around its biological compatibility and effectiveness in preserving and recovering oocytes without compromising their viability or subsequent reproductive outcomes.
Acceptance Criteria Category | Specific Metric (Unit) | Acceptance Criteria | Reported Device Performance (Ultra-Fast Vitri/Warm) |
---|---|---|---|
Non-Clinical Performance | |||
Color/Appearance | Visual inspection | Acceptable appearance | Passed |
pH Testing | pH value (range) | 7.20 – 7.60 | Passed (7.20 – 7.60) |
Endotoxin Testing | Endotoxin level (EU/mL) | Passed (Passes USP ) | |
Gentamicin Test | Gentamicin presence/level | (Not explicitly stated, but implied as conforming to specification) | Passed |
Initial Media Dispensing Validation | Functional dispensing/packaging | (Not explicitly stated, but implied as successful) | Passed |
Mouse Embryo Assay (MEA) | One-cell embryo development (96 hours) | >80% | Passed (>80%) |
Biocompatibility | Biocompatibility with cells | Passes | Passes |
Storage Stability | Temperature range (°C) | 2 – 8°C | 2 – 8°C |
Shelf Life | Duration (months) | 12 months | 12 months |
Clinical Performance | |||
Oocyte Survival Rate | % | (Implied to be comparable to conventional protocol) | 100.0% (Ultra-Fast) vs. 90.9% (Conventional) |
Clinical Pregnancy Rate | % | (Implied to be comparable to conventional protocol) | 65.2% (Ultra-Fast) vs. 54.3% (Conventional) |
Live Birth Rate | % | (Implied to be comparable to conventional protocol) | 56.5% (Ultra-Fast) vs. 52.2% (Conventional) |
Study Proving Device Meets Acceptance Criteria
The provided document describes both non-clinical (bench) and clinical performance studies to demonstrate the safety and effectiveness of the Ultra-Fast Vitri and Ultra-Fast Warm device and its substantial equivalence to the predicate device.
1. Non-Clinical Performance Data (Bench Testing):
- Description: A series of laboratory tests conducted directly on the media to confirm its physical, chemical, and biological properties.
- Specific Tests: Color/Appearance, pH Testing, Endotoxin testing, Osmolality Testing, Sterility Testing, Gentamicin Test, Initial Media Dispensing Validation, Mouse Embryo Assay (MEA), and Biocompatibility.
- Proof of Concept: The device passed all these tests, including achieving >80% one-cell development in the Mouse Embryo Assay, which is a critical biological performance indicator for reproductive media as per FDA guidance.
2. Clinical Performance Data:
- Study Design: A comparative study referenced from literature that evaluated the effectiveness of the ultra-fast vitrification and warming protocols using the subject device against conventional protocols (presumably using the predicate or similar conventional vitrification/warming solutions).
- Study Objective: To demonstrate comparable outcomes (oocyte survival, clinical pregnancy, live birth rates) between the ultra-fast protocol and conventional protocols.
Here's a breakdown of the specific requested information about the clinical study:
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2. Sample Size Used for the Test Set and Data Provenance:
- Sample Size: 1,077 mature oocytes in total.
- 519 oocytes for the conventional vitrification and warming protocols group.
- 558 oocytes for the ultra-fast protocols (subject device) group.
- Data Provenance: The document states "The referenced literature used Kitazato's vitrification and warming solutions (K171748 and K160864)".
- It does not explicitly state the country of origin of the data.
- It does not explicitly state if the study was retrospective or prospective. However, given it's a "study" comparing protocols, it's typically prospective, but this cannot be confirmed from the text.
- Sample Size: 1,077 mature oocytes in total.
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3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications:
- This information is not provided in the document. The study focuses on clinical outcomes (survival, pregnancy, live birth rates) rather than human interpretation of images or other subjective assessments that would require expert consensus for ground truth.
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4. Adjudication Method for the Test Set:
- This information is not applicable/not provided. Adjudication methods (like 2+1, 3+1) are typically relevant for studies involving human interpretation where reviewer disagreement needs to be resolved (e.g., radiology studies). This study measures biological/clinical outcomes.
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5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was Done:
- No, an MRMC study was not done. MRMC studies are used to assess the impact of a device (often AI) on human reader performance, typically in diagnostic imaging. This study evaluated the direct clinical effectiveness of the media itself.
- Therefore, an effect size of how much human readers improve with AI vs. without AI assistance is not applicable.
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6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Study was Done:
- Yes, in a sense, the clinical study assessed the "standalone" performance of the media with its associated protocols. It compared the outcomes from using the media (with its specific ultra-fast protocol) to conventional media/protocols. There isn't an "algorithm" in the traditional sense for this device; it's a chemical formulation and protocol. The "performance" is the biological outcome achieved by the oocytes.
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7. The Type of Ground Truth Used:
- The ground truth was based on clinical outcomes data:
- Oocyte survival rate after vitrification and thawing.
- Clinical pregnancy rate (following embryo transfer resulting from these oocytes).
- Live birth rate (following clinical pregnancy).
- These are considered objective biological and clinical endpoints.
- The ground truth was based on clinical outcomes data:
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8. The Sample Size for the Training Set:
- This information is not applicable/not provided. This device is a media (consumable), not an AI algorithm that requires a separate "training set" of data. The "development" of the media and protocols would be based on laboratory research and refinement rather than a data training paradigm.
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9. How the Ground Truth for the Training Set Was Established:
- This information is not applicable/not provided for the same reasons as #8.
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