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510(k) Data Aggregation

    K Number
    K190677
    Device Name
    EndoClot
    Date Cleared
    2021-01-29

    (686 days)

    Product Code
    Regulation Number
    878.4456
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    EndoClot® PHS is used for hemostasis of nonvariceal gastrointestinal bleeding, excluding Forrest Ia classification of bleeding.

    Device Description

    EndoClot® Polysaccharide Hemostatic System (EndoClot® PHS) is a sterilized single use medical device that is composed of Absorbable Modified Polymer (AMP®) particles in a PE bellow and an EndoClot® Applicator (K162197). The device contains no human or animal components. AMP® particles are biocompatible, non-pyrogenic and derived from plant starch.

    AI/ML Overview

    The provided text describes the 510(k) premarket notification for the EndoClot® Polysaccharide Hemostatic System (EndoClot® PHS), seeking substantial equivalence to predicate devices, primarily Hemospray®. It does not describe a study involving an AI/Machine Learning device or a Multi-Reader Multi-Case (MRMC) study. The performance data presented are for the medical device itself, demonstrating its physical and biological equivalence to the predicate, rather than the performance of an algorithm or human readers.

    Therefore, many of the requested criteria related to AI/ML device performance, expert ground truth establishment, adjudication methods, and MRMC studies, cannot be extracted from this document.

    However, I can provide information based on the device's performance tests and studies, framed as acceptance criteria and proof of meeting them:


    Acceptance Criteria and Device Performance for EndoClot® PHS

    The EndoClot® PHS is a medical device intended for hemostasis of nonvariceal gastrointestinal bleeding. The studies presented aim to demonstrate that the proposed device is substantially equivalent to its predicate devices (Hemospray® and EndoClot® Applicator) by meeting specific performance, biocompatibility, and safety criteria.

    1. Table of Acceptance Criteria and Reported Device Performance

    The document states that the properties of EndoClot® PHS were evaluated and compared to the predicate device Hemospray®. The acceptance criteria were implicitly set as being "similar to or better than" the predicate device.

    Acceptance Criteria CategorySpecific Metric/TestAcceptance Criteria (Implicit)Reported Device Performance
    PerformancePressure of Gas SourceSimilar to or better than predicate (Hemospray®)Similar to or better than predicate
    Spray PatternSimilar to or better than predicate (Hemospray®)Similar to or better than predicate
    Delay TimeSimilar to or better than predicate (Hemospray®)Similar to or better than predicate
    Powder Feeding RateSimilar to or better than predicate (Hemospray®)Similar to or better than predicate
    Water AbsorbencySimilar to or better than predicate (Hemospray®)Similar to or better than predicate
    pHSimilar to or better than predicate (Hemospray®)Similar to or better than predicate
    BiocompatibilityCytotoxicity, Sensitization, Intracutaneous Reactivity, Acute Systemic Toxicity, Pyrogen, Systemic Toxicity, Genotoxicity, Hemocompatibility, EndotoxinsIn accordance with FDA guidance and recognized international standards (e.g., ISO10993) to demonstrate safetyAll tests indicated substantial equivalence to the predicate
    Chemical Characterization(Specific parameters not detailed)In accordance with FDA guidance and recognized international standards (e.g., ISO10993) to demonstrate safetyMet standards, indicating substantial equivalence to the predicate
    Sterility(Specific parameters not detailed)In accordance with recognized international standards (e.g., ISO11737-2)Met standards, indicating substantial equivalence to the predicate
    In Vivo Animal StudyEfficacy and Safety in Swine Model for GI Bleeding ControlDemonstrate efficacy and safety comparable to predicate (Hemospray®) in a swine modelResults demonstrated substantial equivalence to the predicate

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

    The document does not explicitly state the sample sizes for the performance tests (e.g., number of units tested for spray pattern, pressure). For the in vivo animal study, it specifies a "swine model" but does not give the number of animals used. The provenance of the data is from testing conducted by the manufacturer (EndoClot Plus Co., Ltd. and their correspondent Med-wheat Shanghai) to support their 510(k) submission. The type of study is prospective testing of the device's physical, chemical, biological, and functional properties. The country of origin for the submitter is China (Shanghai).

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

    This information is not applicable to the type of device and studies described. The "ground truth" here is objective physical, chemical, and biological measurements, and observed hemostatic performance in an animal model, rather than expert interpretation of medical images or patient outcomes for an AI algorithm.

    4. Adjudication Method for the Test Set

    This information is not applicable as the studies are device performance tests and animal studies, not interpretative studies requiring human expert adjudication.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    An MRMC study was not done. This type of study is relevant for AI/ML diagnostic or interpretative devices where human performance with and without AI assistance is evaluated. The EndoClot® PHS is a medical device for direct therapeutic intervention, not an AI/ML algorithm.

    6. Standalone (Algorithm Only) Performance

    This is not applicable as the device is a physical medical device, not an algorithm.

    7. Type of Ground Truth Used

    The "ground truth" used for this device evaluation consisted of:

    • Objective physical measurements: For parameters like gas source pressure, spray pattern, delay time, powder feeding rate, water absorbency, and pH.
    • Adherence to standardized biological safety tests: Biocompatibility, sterility, and chemical characterization tests following ISO and FDA guidelines.
    • Observed physiological outcomes: In the in vivo swine model, the ability of the device to achieve hemostasis when applied to gastrointestinal bleeding. This can be considered a form of "outcomes data" in an animal model.
    • Comparison to predicate device: The ultimate "ground truth" for substantial equivalence is the demonstration that the proposed device performs "similar to or better than" the legally marketed predicate device.

    8. Sample Size for the Training Set

    This information is not applicable. There is no "training set" as this is not an AI/ML device.

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

    This information is not applicable as it refers to an AI/ML context that is not relevant to this device.

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