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510(k) Data Aggregation

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    Product Code :

    OMT

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Pre-B. Seal Lung Biopsy Plug System is indicated for sealing pleural punctures to reduce the risk of pneumothoraces (air leaks) associated with percutaneous, transthoracic needle lung biopsies and to provide accuracy in marking a biopsy needle entry site for visualization during surgical resection.

    The Pre-B. Seal Lung Biopsy Plug System is indicated for use in adult patients (age > 21 years).

    Device Description

    The Pre-B. Seal Lung Biopsy System is a sterile single-use medical device comprised of the following components:

    • Prefilled Hydrogel Syringe
    • Delivery System 15cm length, 16cm length, 20cm length

    The model numbers are:

    • Pre-B. Seal Lung Biopsy Plug System 15cm (Model # FG0001)
    • Pre-B. Seal Lung Biopsy Plug System 16cm (Model # FG0002)
    • Pre-B. Seal Lung Biopsy Plug System 20cm (Model # FG0003)

    The Delivery System is comprised of an introducer pre-assembled with a delivery needle, with depth markings on the external surface of the introducer. The delivery needle and introducer are both constructed of stainless steel. A pebax white depth marker ball sits on the introducer and may be used in addition to the markings as a depth indicator. The delivery system is ethylene oxide (EO) sterilized and is patient contacting (≤ 24 hours (includes transient contact).

    The prefilled syringe contains a sealant (hydrogel) which acts as an absorbable lung biopsy plug. The hydrogel plug consists of gelatin, saline and hyaluronic acid. The plug is provided in ready to use configuration within a prefilled hydrogel syringe. The hydrogel is biodegradable.

    The prefilled hydrogel is steam sterilized. The hydrogel is patient contact (> 30 days (i.e., permanent)) The syringe is indirect patient contacting.

    These components have been designed for use during a CT-guided transthoracic lung biopsy procedure. The syringe is attached to the delivery system and then purged using a standard hypodermic purging technique outside of the patient. The distance from the skin to the pleura surface is measured using CT imaging, and using this information, the device is advanced to the intended deployment location within the lung under CT guidance. The hydrogel plug is deployed via the prefilled syringe below the surface of the lung through the delivery system. The hydrogel plug creates a seal around the delivery system through which a biopsy is conducted. When the biopsy is complete, the delivery system is withdrawn, and the hydrogel plug remains in place to fill the void and marks the biopsy needle entry site for visualization during surgical resection. The hydrogel plug is biodegradable and resorbs over approximately 49 days.

    AI/ML Overview

    The provided FDA 510(k) clearance letter and summary describe the acceptance criteria and a GLP animal study that demonstrates the Pre-B Seal Lung Biopsy Plug System meets these criteria. Since the device is a physical medical device (lung biopsy plug) and not an AI/Software as a Medical Device (SaMD), several of the requested questions related to AI (e.g., number of experts for ground truth, MRMC study, sample size for training set, how ground truth for training set was established) are not applicable.

    Here's the breakdown based on the provided document:


    Acceptance Criteria and Device Performance

    The acceptance criteria for the Selio Medical Limited Pre-B Seal Lung Biopsy Plug System are largely derived from the requirements specified in the Special Controls (21 CFR 878.4755) for absorbable lung biopsy plugs and demonstrated through comparative testing with the predicate device (Bio-Seal Lung Biopsy Tract Plug System, DEN090007).

    Table 1: Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (from 21 CFR 878.4755 Special Controls)Reported Device Performance (as demonstrated by studies)
    SC(1): Design characteristics ensure geometry and material composition are consistent with intended use.Demonstrated through:
    • Description & Principles of Operation
    • Device Design
    • Performance Testing (Bench)
    • Usability Testing
    • GLP Animal Study.
      Conclusion: Device design and materials are appropriate for and consistent with the intended use. |
      | SC(2): Performance testing demonstrates deployment as indicated in labeling, including with indicated introducer needles, and demonstrates expansion/resorption in a clinically relevant environment. | Demonstrated through:
    • Performance Testing (Bench - Injection Force, Component Compatibility, Insertion/Withdrawal Force, Simulated Use, etc.)
    • Usability Testing
    • GLP Animal Study (plug visibility, deployment accuracy, expansion/resorption characteristics, compatibility with biopsy device).
    • Instructions for Use.
      Conclusion: The device successfully deploys, and its expansion/resorption characteristics are acceptable and visually confirmed in animal model. |
      | SC(3): In vivo evaluation demonstrates performance characteristics, including ability of plug to not prematurely resorb or migrate, and the rate of pneumothorax. | Demonstrated through:
    • GLP Animal Study.
      Conclusion: "The data from this study demonstrated that the performance characteristics, including the ability of the plug to not prematurely resorb or migrate, of the Pre-B. Seal Lung Biopsy Plug System were acceptable. The rate and severity of pneumothorax was less than the predicate device." |
      | SC(4): Sterility testing demonstrates sterility and effects of sterilization process on physical characteristics of plug. | Demonstrated through:
    • Sterilization Validation studies (EO for delivery system per ISO 11135:2014, Steam for hydrogel per ISO 17665:2024), achieving SAL of 10-6.
    • Effects on physical characteristics shown via Performance Testing (Bench), Usability Testing, GLP Animal Study.
      Conclusion: Device is sterile, and sterilization methods do not adversely affect physical characteristics. |
      | SC(5): Shelf-life testing demonstrates shelf-life of device including physical characteristics of plug. | Demonstrated through:
    • Shelf-life testing performed.
      Conclusion: Shelf-life testing was successfully completed, demonstrating acceptable shelf-life and physical characteristics. |
      | SC(6): Device demonstrated to be biocompatible. | Demonstrated through:
    • Biocompatibility Testing per ISO 10993-1:2018.
      Conclusion: "Test Results Passed. The results... demonstrates that the proposed device is biocompatible." |
      | SC(7): Labeling includes detailed summary of complications, warnings, and identification of compatible introducer needles. | Demonstrated through:
    • Review of Instructions For Use (IFU).
      Conclusion: Labeling meets these requirements. |
      | Overall Substantial Equivalence to Predicate | Demonstrated through:
    • Extensive side-by-side comparison (Table 1 in 510(k) Summary) showing similar intended use, indications for use, device class, product code, target population, anatomical site, ability to determine depth, environment of use, absorbable nature, sealing function, plug retention at site, and marking function.
    • Differences in components (pre-filled vs. dehydrated hydrogel) and deployment procedure were addressed with supporting data (bench, animal, usability, biocompatibility) to show no new questions of safety/effectiveness.
    • Different resorption time compared to predicate (49 days vs. 20 months) was deemed acceptable based on GLP animal study.
    • Different hydrogel and delivery system materials were supported by biocompatibility testing.
    • Sterilization methods (steam for hydrogel vs. EO for predicate) were validated.
      Conclusion: The proposed device is as safe, effective, and performs as well as the predicate device. |

    Study Details for Device Performance

    The core study proving the device meets the acceptance criteria is the GLP (Good Laboratory Practice) Animal Study, complemented by various non-clinical bench testing.

    1. Sample sizes used for the test set and the data provenance:

      • Test Set (Animal Study): A swine model was used. The exact number of animals or specific 'sample size' for the test set is not explicitly stated in numerical terms (e.g., "n=X animals") within this document. The document states a comparison was done between the proposed device and the predicate device in the swine model.
      • Data Provenance: The study was a prospective animal study, conducted in a GLP (Good Laboratory Practice) environment. The country of origin is not specified, but GLP implies a standardized, regulated conduct of non-clinical safety studies.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

      • Not Applicable (N/A): This refers to Human Factors/AI studies. For a physical device like a biopsy plug, the "ground truth" for performance (e.g., pneumothorax rate, migration, resorption) is established by direct observation, measurement, and pathological analysis in the animal model by trained veterinarians, pathologists, and study scientists in a GLP setting, not through expert consensus on images.
    3. Adjudication method (e.g. 2+1, 3+1, none) for the test set:

      • N/A: Adjudication methods like 2+1 or 3+1 are typically used for establishing ground truth from human reader interpretations (e.g., in radiological studies). In an animal study, endpoints are typically objectively measured and evaluated by the study team, often including pathological assessment. Discrepancies would be resolved through standard GLP study procedures and internal review processes, not specifically these reader adjudication models.
    4. 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:

      • No, N/A: This is not an AI/SaMD study, but a physical medical device. Therefore, MRMC studies are not relevant for proving the performance of the Pre-B Seal Lung Biopsy Plug System. The comparison was the proposed physical device vs. the predicate physical device in an animal model.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

      • No, N/A: This pertains to AI performance. The device is a physical product designed for human interaction and use during a medical procedure.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

      • For the GLP Animal Study, the ground truth for device performance and safety endpoints (e.g., device visibility, deployment accuracy, expansion/resorption characteristics, incidence of pneumothorax, hydrogel plug migration, degradation, embolization, biocompatibility: local and systemic effects, overall animal health) was established through:
        • Direct observation and measurement during the procedure.
        • Imaging (CT guidance for visibility, positioning, deployment).
        • Pathological assessment (for degradation/resorption, local effects, embolization, etc.) by qualified personnel (e.g., veterinary pathologists).
        • Outcomes data based on the animal's health and post-procedure observations.
    7. The sample size for the training set:

      • N/A: This term applies to machine learning or AI models. This is a physical device developed through traditional engineering design and testing, not by training an AI model.
    8. How the ground truth for the training set was established:

      • N/A: As above, this is for AI models. The design of the Pre-B Seal Lung Biopsy Plug System was based on engineering principles, material science, and testing against pre-defined specifications and regulatory requirements, not a training set.
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    K Number
    DEN090007
    Manufacturer
    Date Cleared
    2012-12-19

    (1342 days)

    Product Code
    Regulation Number
    878.4755
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    OMT

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Bio-Seal Lung Biopsy Tract Plug System is indicated to provide accuracy in marking a biopsy location for visualization during surgical resection and to plug pleural punctures associated with percutaneous, transthoracic needle lung biopsies to significantly reduce the risk of pneumothoraces (air leaks).

    Device Description

    The Angiotech Bio-Seal Lung Biopsy Tract Plug System is comprised of (1) a pre-formed hydrogel plug and (2) a delivery system, which together are designed for use in conjunction with Fine Needle Aspiration (FNA) biopsy of the lung. During lung biopsy, a 19 gauge coaxial needle is placed at the site to be biopsied, under fluoroscopic guidance. The stylet is removed and a 20 or 22 gauge FNA biopsy needle or biopsy instrument is inserted to obtain the tissue sample. When the FNA biopsy needle or biopsy instrument is removed. the Bio-Seal Lung Biopsy Tract Plug is deployed using the Bio-Seal delivery system through the coaxial needle into the biopsy tract. Upon deployment into the biopsy tract, the hydrogel plug absorbs extracellular fluid and expands to fill the void of the biopsy tract and remains in place for months to mark the biopsy site.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and the study that proves the device meets them, based on the provided text:

    Acceptance Criteria and Reported Device Performance for Bio-Seal Lung Biopsy Tract Plug System

    1. Table of Acceptance Criteria and Reported Device Performance

    CategoryAcceptance Criteria (Explicit or Implied from Testing)Reported Device Performance
    BiocompatibilityDevice materials (Bio-Seal Plug and modified delivery system components) must be biocompatible (cytotoxicity, sensitization, intracutaneous reactivity, hemolysis, pyrogenicity, genotoxicity, mutagenicity, chromosomal aberrations, chronic toxicity, implantation, acute systemic toxicity, delayed hypersensitivity, materials-mediated pyrogenicity, LAL).Bio-Seal Plug: Acceptable for all critical biocompatibility tests (cross-referenced from K041331). Modified Delivery System: All patient-contacting components (Housing, Stylet, Adapter) shown to be biocompatible per ISO 10993-1:2009.
    SterilityAchieve a Sterility Assurance Level (SAL) of 10⁻⁶ via Ethylene Oxide (EO) gas sterilization.Validated in conformance with ISO 11135:1994 and K90-1 Guidance.
    Shelf Life/StabilityMaintain performance (deployment, protrusion, no premature expansion) for at least three years. The Bio-Seal dimensions must remain within specification, and there should be no premature plug expansion. Plugs must deploy after 60-second hold time and protrude from simulated tissue. Plugs must expand beyond a pre-specified dimension during hydration.Supported a three-year shelf life. All 10 samples for accelerated aging and 10 samples for real-time aging passed all tests. Bio-Seal dimensions were within specification, no premature expansion. All plugs deployed after 60-second hold time and protruded from simulated tissue. All 15 hydrated plugs expanded beyond the pre-specified dimension.
    Functional Performance (Bench - Deployment)Plug must deploy through the coaxial introducer needle.All 120 devices deployed the plug as intended.
    Functional Performance (Bench - Protrusion)Plug must protrude from the simulated lung tissue (pleura).All 120 devices showed plug protrusion (average protrusion above simulated pleura of (b)(4)).
    Functional Performance (Bench - Ease of Deployment)The rating should be acceptable even if not "ideal" as long as the plug deploys correctly.Average ease of plug deployment rating: (b)(4) (which is likely considered acceptable given the context).
    Functional Performance (Bench - Deployment Time)Plug deployment within (b)(4) from attachment to coaxial introducer needle, verified with a (b)(4) hold time.Average deployment time: (b)(4) after a (b)(4) hold time (meets or exceeds requirement).
    Dimensional Accuracy (Plug)Outer diameter (OD) and length must be within acceptable tolerances for housing assembly, coaxial needle fit, and precise positioning.1000 sterile plugs dimensionally inspected for OD and length were found to be within acceptable tolerances.
    Dimensional Accuracy (Adapter/Delivery System)Main Luer assembly length, nylon tube bond strength, support column length and ID, plunger stylet length, and first laser mark must be within acceptable tolerances. Plunger must seat completely within the adapter hole.All tested Main Luer assemblies were within acceptable tolerances for critical length. Nylon tube bond strength met or exceeded specification (pull tested (b)(4) assemblies showed bond strength greater than or equal to (b)(4)). All (b)(4) delivery systems tested for support column length, ID, plunger length, and first laser mark were within acceptable measurements. All depths passed.
    Hydration RateSterilization should not adversely affect hydration rate. Plugs must expand to prespecified dimensions within 1998 seconds and fit the ID of the coaxial needle.Sterilization did not adversely affect hydration rate. Post-sterilization, plugs expanded to prespecified dimensions within 1998 seconds. Time needed to reach a predetermined diameter where the plug would no longer fit the ID of the coaxial needle was also measured, implying it was within acceptable limits for physician deployment time.
    Pneumothorax Rate Reduction (Effectiveness)Significantly reduce the risk of pneumothoraces (air leaks) post-lung biopsy compared to standard procedure.Statistically and clinically significant reduction: ITT population: 75% success (no pneumothorax) with device vs. 57% without (p=0.0008). PP population: 85% success with device vs. 69% without (p=0.0022).
    SafetyComparable or improved safety profile regarding adverse events for procedure-related and non-procedure related events compared to control group. No clinical harm from device malfunction events.Non-procedure related events comparable. Device/procedure-related events higher in control group (44% vs. 25%). 7 device malfunction events reported, but none resulted in clinical harm. 3 deaths (2 control, 1 Bio-Seal) were unrelated to device or procedure.
    Resorption CharacteristicsMinimal inflammation in lung tissue for up to 6 months. Essentially resorbed at 20 months.Swine studies showed minimal inflammation comparable to absorbable sutures at 7, 14, 90, and 180 days. In vitro studies at 37°C indicated theoretical degradation within 15-18 months with two-thirds degradation within 6-9 months (consistent with "essentially resorbed at 20 months" inference from previous animal data).

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

    • Clinical Trial Test Set:

      • Intent-to-Treat (ITT) Population: 339 total patients (170 Bio-Seal, 169 Control)
      • Per Protocol (PP) Population: 287 total patients (150 Bio-Seal, 137 Control)
      • Data Provenance: Multi-centered (15 US centers), prospective, randomized controlled trial.
    • Bench Testing Test Set:

      • Shelf Life: 10 samples for accelerated aging, 10 samples for real-time aging (2 samples at each time point: 1, 1.5, 2, 2.5, 3 years).
      • Hydration Rate: 15 Bio-Seal plugs.
      • Dimensional (Plug): 1000 sterile plugs.
      • Dimensional (Main Luer assembly): (b)(4) assemblies (number redacted but plural).
      • Nylon Tube Bond Strength: (b)(4) assemblies (number redacted but plural).
      • Dimensional (Delivery System): (b)(4) delivery systems (number redacted but plural).
      • Functional (Deployment, Protrusion, Ease, Time): 120 devices.
      • Data Provenance: Bench (laboratory) setting.

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

    • Clinical Trial: The primary effectiveness endpoint (incidence rate of pneumothorax) was "measured by chest x-rays at 0-60 minutes after procedure, 24 hours after discharge and 30 days post discharge. A blinded, independent reader analyzed the x-rays, whose opinion was used in evaluating the primary endpoint."

      • Number of Experts: One (a single "blinded, independent reader").
      • Qualifications: "Independent reader" implies they are qualified to interpret chest x-rays for pneumothorax, likely a radiologist, but specific qualifications (e.g., years of experience) are not provided. The term "blinded" is a critical qualification ensuring objectivity.
    • Animal Studies (Pathology/Inflammation): Not explicitly stated, but for the chronic GLP animal study involving histological evaluation, it can be inferred that veterinary pathologists or similar experts established the ground truth regarding inflammation. The text doesn't specify the number.

    4. Adjudication Method for the Test Set

    • Clinical Trial (Pneumothorax Endpoint): None explicitly mentioned as an adjudication method where multiple readers disagree. It states a "blinded, independent reader analyzed the x-rays, whose opinion was used in evaluating the primary endpoint." This suggests the single reader's opinion was the definitive determination, rather than a consensus or adjudication process among multiple readers.

    • Bench/Animal Studies: Not applicable in the context of human reader adjudication.

    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

    • No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done.
    • This device is a physical medical device (lung biopsy tract plug), not an AI algorithm. Therefore, there is no AI component, and no study measuring human reader improvement with or without AI assistance was conducted.

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

    • No, this device is a physical medical device. It does not involve an algorithm and is not intended for standalone algorithmic performance evaluation. Its use is hands-on by a physician.

    7. The Type of Ground Truth Used

    • Clinical Trial:

      • Effectiveness (Pneumothorax): Expert interpretation of chest x-rays by an independent, blinded reader. This is a form of expert consensus/interpretation of imaging.
      • Safety (Adverse Events): Clinically observed adverse events documented in Case Report Forms (CRFs), including pneumothorax, coughing with blood, infections, etc.
    • Animal Studies:

      • Resorption/Inflammation: Histological evaluation in swine sacrificed at various time points (7, 14, 90, 180 days). This is based on pathology.
    • Bench Studies:

      • Dimensional, Functional, Hydration, Sterility, Shelf-life: Physical measurements, visual inspection, timed observations, and standardized laboratory tests with defined specifications/tolerances.

    8. The Sample Size for the Training Set

    • Training Set for a Physical Device: This concept generally doesn't apply to a physical medical device in the same way it does to an AI algorithm.
      • However, the text mentions "Research and development acute studies included demonstrating expansion characteristics of a prototype plug under inflation, air leakage in the presence of blood, varying depth placements of the plug, physician preference, and techniques for maneuvering the marker, photographic documentation of placement and extension beyond pleura, and feedback for physician training." This iterative R&D likely involved numerous prototypes and tests (a form of "training" for the device's design and manufacturing process), but a specific "training set" sample size for the final product is not applicable in the AI sense.
      • The Bio-Seal Plug itself "was previously cleared as a lung biopsy site marker device under K041331." This prior clearance and continued use/manufacturing would involve a vast dataset of material characterization and performance data that iteratively refined the design and manufacturing processes, but it's not a discrete "training set."

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

    • As above, for a physical device, a "training set" ground truth isn't established in the AI sense. Instead, the design and manufacturing process is refined through:
      • Bench Testing: Extensive iterative testing and characterization of materials, dimensions, and functional performance with defined engineering specifications and physics-based outcomes.
      • Animal Studies: Acute and chronic animal studies provided in-vivo data on tissue reaction, expansion characteristics, and resorption.
      • Physician Feedback: Early prototype evaluations and preference studies guided the design for usability and effectiveness.
      • Prior Regulatory Clearances: Previous successful clearances (e.g., K041331) established a foundational understanding of the device's behavior and safety, confirming ground truth for its core components.

    Essentially, the "ground truth" for developing the device was derived from a combination of scientific principles, engineering validated measurements, and biological responses observed in preclinical models.

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