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510(k) Data Aggregation

    K Number
    K222354
    Date Cleared
    2022-10-03

    (60 days)

    Product Code
    Regulation Number
    876.4410
    Reference & Predicate Devices
    N/A
    Why did this record match?
    Product Code :

    QSW

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

    The Elastic Traction System is indicated for adult only for use in flexible Endoscopy to provide retraction to assist in tissue resection, exposure, and removal of tissue within the stomach and colon.

    Device Description

    The proposed device, Elastic Traction System, consists of 2 components, an Elastic Traction Device, and a clipping device (Fig. 1). Two components are single use device.

    The Elastic Traction Device is a single use tissue traction device. It is consisting of clip assembly, silicone band and delivery system. The silicone band is consisting of three rings. Ring A is preloaded with the clip.

    The Clipping Device is a single use device, and its purpose is to use it as a second clip. The second clip is used to engage the silicone band of the previously anchored clip of Elastic Traction Device.

    AI/ML Overview

    The provided text describes the Micro-Tech (Nanjing) Co., Ltd. Elastic Traction System, an endoscopic traction device. The information details the device's characteristics, its comparison to a predicate device, and the non-clinical performance data used to establish substantial equivalence.

    Here's an analysis of the acceptance criteria and the study information based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria appear to be framed around demonstrating substantial equivalence to the predicate device, ProdiGI Traction Wire (DEN220006), across various performance aspects that confirm safety and effectiveness for its intended use. While explicit numerical acceptance criteria values are not given in this summary, the document states that tests were performed to demonstrate that the device performs as intended under anticipated conditions of use and is considered safe and effective for its intended use.

    Acceptance Criteria CategoryReported Device Performance
    Bench TestsPerformed as intended under anticipated conditions of use for:
    Dimension
    Release Force
    Clamping Strength
    Tensile Strength
    Elastic Performance
    Rotation Performance
    Repeated Opening/Closing
    Clip Opening/Closing Forces
    Endoscope Compatibility
    Endoscope Damage
    UsabilityIntended user can safely and correctly use the proposed device.
    Shelf-LifeDemonstrated 2-years aging stability (according to ASTM F1980-16).
    SterilizationValidated according to ISO 11135:2014+A1:2019.
    BiocompatibilityComplies with ISO 10993-1.
    Animal StudyPerforms as intended under anticipated conditions of use.

    2. Sample Size for the Test Set and Data Provenance

    • Sample Size for Test Set: The document does not specify the exact sample sizes used for each individual bench test. It mentions that "bench tests below were tested and evaluated." For the animal study, it states an "animal test" was conducted, implying one study, but the number of animals or procedures is not specified.
    • Data Provenance: The data provenance is from non-clinical studies (bench tests, animal study, usability assessment, shelf-life, sterilization, biocompatibility testing) conducted by Micro-Tech (Nanjing) Co., Ltd. The animal study was conducted according to 21 CFR §58 (GLP Regulations), suggesting it was a prospective study. The bench tests are laboratory-based.

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

    • This information is not provided in the document. For non-clinical performance tests, "ground truth" is typically established by engineering specifications, validated test methods, and regulatory standards rather than expert consensus on observational data.

    4. Adjudication Method for the Test Set

    • This information is not applicable/provided as the performance data is derived from objective, replicable tests (bench, animal, etc.) rather than subjective assessments requiring adjudication.

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

    • No MRMC comparative effectiveness study was done. The document explicitly states: "No clinical study is included in this submission."

    6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study

    • This information is not applicable. The device is a physical medical device (an endoscopic traction system), not an AI algorithm. Therefore, "standalone" performance in the context of an algorithm is not relevant. The performance data presented refers to the device's physical and functional characteristics.

    7. Type of Ground Truth Used

    • For the non-clinical performance tests (bench tests), the ground truth is based on engineering specifications, established test methods, and compliance with relevant international standards (e.g., ASTM F1980, ISO 11135, ISO 10993-1).
    • For the animal study, the ground truth for safety and effectiveness would be established through direct observation of the device's performance in vivo and histological examination or other relevant biological assessments, evaluated against pre-defined success criteria.

    8. Sample Size for the Training Set

    • This information is not applicable. The device is a physical medical device, not an AI algorithm that requires a training set.

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

    • This information is not applicable as there is no training set for a physical medical device.
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    K Number
    DEN220006
    Device Name
    ProdiGI
    Manufacturer
    Date Cleared
    2022-06-13

    (150 days)

    Product Code
    Regulation Number
    876.4410
    Type
    Direct
    Reference & Predicate Devices
    N/A
    Why did this record match?
    Product Code :

    QSW

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

    ProdiGI Traction Wire: The Medtronic ProdiGI Traction Wire is indicated to grasp tissue within the esophagus, stomach, and colon of adults during an Endoscopic Submucosal Dissection (ESD) procedure.

    ProdiGI Traction Magnet: The Medtronic ProdiGI Traction Magnet is indicated to grasp tissue within the stomach and colon of adults during an Endoscopic Submucosal Dissection (ESD) procedure.

    Device Description

    The ProdiGI Traction System includes the Traction Wire and Traction Magnet devices. The Traction Wire and Traction Magnet are not intended to be used together. Both devices are used in adults only and are used to provide improved visualization of the submucosal space during an endoscopic submucosal dissection (ESD) procedure.

    ProdiGI Traction Wire Device: The Traction Wire consists of two graspers: a primary tissue grasper with traction wire attached (ERD-TW20 and ERD-TW35), and a secondary tissue grasper (ERD-TWSG) without a wire. The secondary tissue grasper is used to secure the distal end of the traction wire. The traction wire is a nitinol shape-memory loop (2.0 cm or 3.5 cm in length) that provides tension to the attached tissue after deployment. The nitinol wire is attached to the grasper with a stainless-steel crimp.

    ProdiGI Traction Magnet Device: The traction magnet (ERD-TMST and ERD-TMLG) consists of two identical tissue graspers with a permanent neodymium magnet attached to the grasper via a suture. The sutured magnet provides tension to the attached tissue after deployment.

    AI/ML Overview

    Here's an analysis of the provided text to describe the acceptance criteria and the study proving the device meets them, based on your requested format:

    Acceptance Criteria and Device Performance for ProdiGI

    The ProdiGI device underwent non-clinical/bench studies and usability testing to demonstrate its safety and effectiveness. Importantly, no clinical data was provided. The primary studies proving the device meets acceptance criteria are summarized in the "Performance Testing - Bench", "Usability Testing", and "Performance Testing - Animal" sections of the provided document.

    1. Table of Acceptance Criteria and Reported Device Performance

    The provided document presents acceptance criteria and reported performance in a narrative and tabular format for both bench and usability testing. I will consolidate the key performance criteria for each device type into a single table. Note that specific numerical results (e.g., 'b)(4)') were often redacted in the original text, so I will indicate where this occurs.

    Table 1: Consolidated Acceptance Criteria and Reported Device Performance (Bench and Usability)

    Test CategorySpecific Test / Needs IDAcceptance CriteriaReported Device Performance
    BiocompatibilityGeneralConformance to ISO 10993-1:2003 for cytotoxicity, sensitization, irritation, material-mediated pyrogenicity, and acute systemic toxicity.PASS: "The results supported the biocompatibility of the ProdiGI device." (Tests performed on final finished devices.)
    Shelf Life/SterilitySterilizationConformance to ANSI/AAMI/ISO 11135:2014, ensuring a sterility assurance level of 10^-6.PASS: "Sterilization was evaluated for conformance..." (Implied successful validation as no issues reported and device granted.)
    Accelerated AgingSupport 1.5-year shelf life per ASTM F1980-16, demonstrating packaging integrity (gross leak, pouch seal strength).PASS: "Accelerated aging to support a 1.5-year shelf life was performed... The shelf life was verified by demonstrating packaging integrity..." (Implied successful validation.)
    Bench/Mechanical (Traction Wire)Tensile Test (Grasper to Wire)Grasper to wire tensile force should be above (b)(4) lbf.PASS: "The device passed all the tests in Tables 1 and 2." (Table 1 states "The grasper to wire tensile force should be above (b)(4)" for both, implying the criteria was met.)
    Tensile Test (Crimp to Wire)Crimp to wire tensile test must be above (b)(4). lbf.PASS: "The device passed all the tests in Tables 1 and 2." (Table 1 states "The crimp to wire tensile test must be above (b)(4)" for both, implying the criteria was met.)
    Torque TestTorque to rotate device (b)(4) lbf; 2nd grasper > (b)(4) lbf; 2nd grasper arms not come out of capsule; force to remove 2nd graspers from tissue (b)(4) lbf and = (b)(4) lbf; force to remove magnet from suture >= (b)(4) lbf; force to separate crimp from suture >= (b)(4) lbf; force to remove magnet from grasper body (b)(4) lbf; arms not come out of capsule during detachment; force to remove grasper from tissue = (b)(4) prior and after being opened/closed (b)(4).PASS: "The device passed all the tests in Tables 1 and 2." (Implied compliance with all criteria based on "passed all tests" statement.)
    Deployment ForceForce to deploy by squeezing handle: > (b)(4) lbf and (b)(4) lbf (lower); = (b)(4).PASS: "The device passed all the tests in Tables 1 and 2." (Implied compliance with all criteria based on "passed all tests" statement.)
    Usability (Traction Wire)N1.1 (Visualization)Average visualization score (dissection with traction wire) >= average visualization score (without traction wire). (3-point scale: 1=unacceptable, 2=acceptable, 3=exceeds expectations)PASS: Test: 15/24, Control: (b)(4) (Specific average values are redacted, but "PASS" indicates the criterion was met. This implies the average score with the device was at least as good as without.)
    N1.2 (Procedure Time)Average procedure time (with traction device) = average visualization score (without traction magnet). (5-point scale: 1=unacceptable, 2=poor, 3=clinically acceptable, 4=good, 5=exceeds expectations)PASS: (Specific score values redacted, but "PASS" indicates the criterion was met. This implies the average score with the device was at least as good as without.)
    NL2 (Procedure Time)Average procedure time (with traction device) 5 years of experience and three or more ESD cases per month.
    *   For the **Traction Wire**, "skilled by moderate and provice physicians participated."
    *   For the **Traction Magnet**, "two skilled, two moderate and two novice physicians participated."
    *   The observations and ratings from these physicians formed the basis of the usability ground truth.
    
    • Animal Testing: Bleeding, perforation, mucosal laceration, visualization, ease of removal, and ease of procedure were assessed by "study physicians intraoperatively via endoscopic visualization." No specific number of physicians is given for the animal studies, but they are implied to be experts in therapeutic endoscopy and ESD.

    4. Adjudication Method for the Test Set

    The document does not explicitly describe an adjudication method (e.g., 2+1, 3+1) for the usability or animal studies. It appears that the expert physicians directly provided the ratings and assessments which were then used to calculate means and comparisons. For perforation in the animal study, it notes a singular assessment that was then reviewed for causality ("unrelated to the device use or design or the control procedure").

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

    While not explicitly termed an "MRMC study," the usability testing and animal (in vivo) testing were designed as comparative effectiveness studies where human readers (physicians/experts) performed procedures with and without AI (device) assistance. The "AI" here refers to the device itself as providing assistance, not an AI algorithm in the traditional sense of image analysis.

    • Effect Size of Human Readers (with device vs. without):
      • Visualization: For both Traction Wire and Traction Magnet, the device showed PASS for visualization, meaning the average visualization score with the device was equal to or better than without. This indicates a positive effect on visualization compared to unassisted procedures. For the animal study, Visualization (Start, Mid, End) was consistently rated as Traction better than Control for both devices.
      • Procedure Time: For the Traction Wire, procedure time was PASS (device time
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