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510(k) Data Aggregation

    K Number
    K171935
    Date Cleared
    2017-12-01

    (156 days)

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

    Rx Indication: Alevicyn SG Antimicrobial Gel is intended to moisten the wound bed and facilitate autolytic debridement of acute and chronic dermal lesions. Alevicyn SG Antimicrobial Gel is indicated to manage and relieve the burning, itching, erythema, scaling, and pain experienced with various types of dermatoses, including atopic dermatitis, radiation dermatitis, seborthea and sebortheic dermal irritation, sores, injuries, and ulcers of dermal tissue in addition to moistening and lubricating absorbent wound dressings. The Alevicyn SG Antimicrobial Gel may also be used to manage partial or full thickness wounds such as first and second degree burns, stage I - IV pressure ulcers, diabetic and stasis ulcers, abrasions and skin irritations, surgical wounds (donor and graft sites, incisions), and trauma wounds. Alevicyn SG Antimicrobial Gel helps to relieve dry waxy skin by maintaining a moist wound & skin environment, which is beneficial to the healing process.

    OTC Indications for Use: Alevicyn SG Antimicrobial Gel is intended for OTC use to relieve itch and pain from minor skin irritations, minor cuts, exit sites, minor abrasions and minor burns, including sunburns. Hydrogel is also intended to moisten and lubricate absorbent wound dressings and moisten the wound bed. A moist wound and skin environment facilitates autolytic debridement and is beneficial to wound management and the healing process.

    Device Description

    The Alevicyn SG Antimicrobial Gel is an opaque gel, slightly chlorinated odor, low viscosity spray gel. The product will be supplied in polyethylene terephthalate (PET) round-bottles with polypropylene (PP) screw-top closure and a finger pump sprayer. Ingredients: Water, sodium lithium magnesium fluorosilicate, dimethicone, sodium phosphate, sodium bicarbonate, sodium chloride, sodium sulfate, with hypochlorous acid and sodium hypochlorite as gel preservatives.

    AI/ML Overview

    The document provided describes a 510(k) Premarket Notification for the Alevicyn SG Antimicrobial Gel. This type of submission aims to demonstrate that a new device is "substantially equivalent" to a legally marketed predicate device, rather than proving its safety and effectiveness from scratch. Therefore, the information provided focuses on showing equivalence through comparison and specific performance data, rather than detailing a direct study to "prove acceptance criteria" in the way one might for a novel device.

    However, I can extract the acceptance criteria (specifications) and reported performance data based on the provided "Performance Data" section.

    Here's the breakdown of the requested information:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Specification)Reported Device Performance
    Biocompatibility:
    CytotoxicityMet (Evaluated in accordance with FDA guidance and ISO 10993-1)
    IrritationMet (Evaluated in accordance with FDA guidance and ISO 10993-1)
    SensitizationMet (Evaluated in accordance with FDA guidance and ISO 10993-1)
    Toxicological RiskMet (Toxicological risk assessment conducted to support prolonged use)
    Bench Testing:
    Visual InspectionMeets specification (Opaque, colorless semi-viscous gel, slightly chlorinated odor)
    pHMeets specification
    ViscosityMeets specification
    Free Available Chlorine (FAC)Meets specification
    Antimicrobial Preservative EffectivenessMeets specification (Effective against Proteus mirabilis, Serratia marcescens, antibiotic resistant Methicillin-Resistant Staphylococcus aureus (MRSA), and Acinetobacter baumannii while on the shelf, conforming to USP <51>)

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

    The document does not specify a sample size for any of the biocompatibility or bench tests. It also does not specify the country of origin or whether the data was retrospective or prospective. The nature of these tests (e.g., in-vitro toxicology, chemical property testing) typically involves lab-based experiments rather than human clinical trials with "test sets" in the traditional sense.

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

    This information is not applicable and not provided in the document. For device submissions based on predicate equivalence and bench/biocompatibility testing, the "ground truth" is established by adherence to recognized standards (e.g., ISO 10993-1, USP <51>) and internal specifications for chemical and physical properties. There are no "experts" establishing ground truth in the context of clinical interpretation, as would be the case for an AI diagnostic device.

    4. Adjudication Method for the Test Set

    This information is not applicable and not provided. Adjudication methods (like 2+1, 3+1) are typically used in clinical studies where expert consensus is needed to resolve discrepancies in diagnoses or assessments, particularly for AI image interpretation. The studies described here are laboratory-based performance and safety evaluations.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and Effect Size with AI vs. Without AI Assistance

    This information is not applicable and not provided. MRMC studies are relevant for evaluating diagnostic imaging systems (often AI-powered) where human readers interpret cases. The Alevicyn SG Antimicrobial Gel is a topical medical device, not an imaging or diagnostic AI system.

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

    This information is not applicable and not provided. "Standalone performance" refers to the performance of an algorithm without human intervention, again typically for AI-driven diagnostic tools. This device is not an algorithm.

    7. The Type of Ground Truth Used

    For biocompatibility, the ground truth is established by:

    • Adherence to recognized international standards like ISO 10993-1 ("Biological Evaluation of Medical Devices - Part 1: Evaluation and Testing Within a Risk Management Process").
    • FDA biocompatibility guidance (issued June 16, 2016).

    For bench testing, the ground truth is established by:

    • Internal specifications defined for pH, viscosity, FAC.
    • Adherence to recognized pharmacopeial standards like USP <51> for antimicrobial preservative effectiveness.

    8. The Sample Size for the Training Set

    This information is not applicable and not provided. This device is a physical product (gel) and does not involve AI or machine learning models that require training sets.

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

    This information is not applicable and not provided, for the same reason as above (no AI/ML training set).

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