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510(k) Data Aggregation

    K Number
    K102827
    Manufacturer
    Date Cleared
    2011-11-02

    (399 days)

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

    Medical Maggots are indicated for debriding non-healing necrotic skin and soft tissue wounds, including pressure ulcers, venous stasis ulcers, neuropathic foot ulcers, and non-healing traumatic or post surgical wounds.

    The accessory maggot confinement dressings, Creature Comforts™, and LeFlap™ and LeSoc™, are indicated for confining the medicinal maggots on the area of treatment during debridement therapy for the conditions mentioned above.

    Device Description

    Phaenicia sericata larvae (see Figure 1)
    Common names: Maggot dressings; green blow fly maggots; disinfected maggots; sterile maggots; therapeutic maggots; debriding maggots; maggot debridement therapy. Accessories: MDT dressings; maggot confinement dressings; maggot cage dressings.
    "Proprietary" name: Medical Maggots; to be used with Creature Comforts or LeSoc (the latter being the new accessory featured in this Special PMN)

    Maggot therapy is essentially a controlled wound myiasis (maggot infessation). The maggots macerate their food with their mouth hooks, release their digestive enzymes into the local environment, and ingest the liquefying and semi-solid tissue. As they grow, they molt twice. When satiated, the maggots leave their food source, burry themselves in a suitably protected area, and pupate. Adult flies emerge (eclose) approximately 1-3 weeks later. Maggot therapy dressings contain the medical grade larvae on the wound during the period of debridement, and facilitate easy and controlled removal when the patient and therapist determine they have completed their work.

    The proposed modified accessory ("LeSoc") has the same basic structure and use as the previously approved "Sterile Nylon Stocking," with the exception that we will make the stocking out of a different polyester fabric: the same polyester monofilament fabric that we currently use in the production of our approved Creature Comforts dressing (our flat, non-stocking dressing). This means that the stocking weave will be fixed, not free to move or stretch.

    The structure, function, technology and indications are the same as in the currently marketed products. The only difference will be the offering of a hybrid dressing accessory to create a stocking-like dressing out of our currently used fixed-weave polyester net instead of the stretch-weave polyester of our Sterile Nylon Stockings.

    AI/ML Overview

    The provided text is a 510(k) summary for a medical device (Medical Maggots and maggot confinement dressings), specifically addressing a modification to an accessory (the "LeSoc" dressing). The document largely focuses on demonstrating substantial equivalence to previously cleared devices rather than presenting a detailed study report with specific acceptance criteria and performance metrics in the typical format for AI/ML device evaluations.

    Therefore, many of the requested elements for describing acceptance criteria and a study proving device performance are not present or applicable in this submission. This is common for predicate device submissions, where the focus is on showing the new device is as safe and effective as devices already on the market, often through addressing minor modifications and validating that the change does not negatively impact performance or create new risks.

    Here's an attempt to extract and interpret the information provided, while noting where details are absent:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance CriteriaReported Device Performance
    Penetration & Durability: Maggots would not escape during normal operation. (For the modified "LeSoc" accessory)Demonstrated that maggots would not escape during normal operation.
    Sterilization Validation: Steam sterilization is an adequate method of sterilization.Demonstrated steam sterilization to be an adequate method of sterilization.
    Biocompatibility: Material not toxic nor induces contact hypersensitivity.Demonstrated the material not to be toxic nor to induce contact hypersensitivity in mice.
    Efficacy (comparative): No change in efficacy as the underlying technology remains unchanged.Implied: Efficacy is maintained because the underlying technology (debridement by medical grade larvae) remains unchanged.
    Safety (comparative): Decreased opportunity for escaping maggots with the new accessory.Implied: The new accessory (LeSoc) is expected to increase safety by preventing maggot escape, which occasionally happened with the previous nylon stocking.

    Missing Information: The document does not provide quantitative acceptance criteria (e.g., "X% of maggots should not escape") or specific numerical performance metrics. The statements are qualitative affirmations of successful validation.

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

    • Sample Size for Test Set: Not explicitly stated. The "Penetration & Durability Feasibility Study" is mentioned, but no sample size (e.g., number of dressing prototypes tested, number of maggots used) is given.
    • Data Provenance: The studies appear to be internal validations performed by the manufacturer, Monarch Labs, LLC. There's no mention of external data or specific geographical origin beyond the company's location in Irvine, CA. The "Penetration & Durability Feasibility Study" and sterilization validation were performed by the manufacturer. Biocompatibility data was "supplied by manufacturer."
    • Retrospective or Prospective: These appear to be prospective validation studies performed specifically for this 510(k) submission, confirming the performance of the modified accessory.

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

    • Not applicable/Not mentioned. This type of information (expert consensus for ground truth) is typically relevant for diagnostic imaging AI/ML devices. For a physical medical device like this maggot dressing, the "ground truth" for the penetration and durability study would likely be directly observed maggot escape, not expert interpretation.

    4. Adjudication Method for the Test Set

    • Not applicable/Not mentioned. Adjudication methods (like 2+1) are for resolving discrepancies in expert interpretations, which is not relevant for the types of studies described here.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done

    • No, an MRMC study was not done. This type of study is primarily for evaluating the impact of AI on human reader performance in diagnostic tasks, which is not relevant for this physical device.

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

    • No, a standalone AI algorithm performance study was not done. This device does not incorporate an AI algorithm. The "device" itself is the physical maggot dressing and the biological maggots.

    7. The Type of Ground Truth Used

    • For Penitration & Durability: Direct observation of maggot escape (or lack thereof) from the dressing.
    • For Sterilization Validation: Laboratory testing to confirm sterility parameters were met.
    • For Biocompatibility: Results from standard biological evaluation tests (e.g., in vivo or in vitro tests using mice/cells) based on regulatory standards.

    8. The Sample Size for the Training Set

    • Not applicable/Not mentioned. This device does not involve a "training set" in the context of machine learning. The "training" for the maggots is their natural biological behavior, and the dressings are physical containment systems.

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

    • Not applicable. See point 8.

    Summary of Device and its Purpose based on the Text:

    The device consists of "Medical Maggots" (Phaenicia sericata larvae) and associated confinement dressings. This submission focuses on a new dressing accessory called "LeSoc," which is a hybrid of existing approved dressings. The primary purpose of the maggots is debriding non-healing necrotic skin and soft tissue wounds. The dressings are to confine the maggots to the treatment area. The modification to the LeSoc dressing involves using a fixed-weave polyester fabric (similar to another approved dressing, "Creature Comforts") instead of a stretch-weave fabric (used in "Sterile Nylon Stockings") to prevent maggots from escaping. The studies described are validations of this material change, focusing on preventing maggot escape, ensuring proper sterilization, and confirming biocompatibility, to demonstrate substantial equivalence to previously cleared devices.

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