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510(k) Data Aggregation
(295 days)
Ecocel® is a hydrosoluble lacquer indicated to protect intact or damaged nails from the effects of moisture, friction (rubbing) or shear (tearing), relieving symptoms and signs of nail dystrophy (i.e. nail splitting and fragility).
Ecocel® is a water-soluble lacquer contained in a glass bottle (1.5 or 3.3 mL) with a nylon brush fitted on the polypropylene screw cap.
The provided documentation for the Ecocel® device (K083087) does not contain sufficient information to describe specific acceptance criteria or a detailed study proving the device meets acceptance criteria in the format requested.
The document is a 510(k) summary for a Class I liquid bandage, Ecocel®, seeking substantial equivalence to existing predicate devices. It primarily focuses on the regulatory submission process and the determination of substantial equivalence by the FDA.
Here's an analysis based on the available information:
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A table of acceptance criteria and the reported device performance
- Not provided. The document states that Polichem submitted "summaries of preclinical studies, including biocompatibility and laboratory studies, and the reports from clinical studies as well as the post market experience in Europe that substantiate Ecocel's performance both in vitro as well as its in vivo use." However, no specific acceptance criteria (e.g., minimum efficacy rates, safety thresholds, or performance metrics) or corresponding reported performance data are detailed.
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Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Not provided. The summary mentions "clinical studies" and "post market experience in Europe" but does not specify sample sizes, design (retrospective or prospective), or the exact country of origin for the data.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
- Not applicable/Not provided. This type of information is typically relevant for medical imaging or diagnostic devices where expert consensus is used to establish ground truth for classification tasks. For a liquid bandage, ground truth would likely be established through objective measures of efficacy (e.g., reduction in nail splitting) or patient-reported outcomes, rather than expert interpretation of images. The document does not detail how outcomes were assessed or by whom.
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Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable/Not provided. Similar to point 3, adjudication methods are usually applied to expert reviews in diagnostic studies. For a liquid bandage, if patient-reported outcomes or clinical assessments were used, the method of resolving discrepancies would be detailed, but this is not present in the summary.
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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
- Not applicable. MRMC studies are specific to diagnostic devices where human readers interpret cases, often with or without AI assistance. This device is a liquid bandage, not an AI-powered diagnostic tool. Therefore, an MRMC study would not be relevant.
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If a standalone (i.e. algorithm only without human-in-the loop performance) was done
- Not applicable. This device is a topical medical product, not an algorithm, so a standalone algorithm performance study is not relevant.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
- Inferred to be outcomes data and possibly subjective assessments. The indications for use state "relieving symptoms and signs of nail dystrophy (i.e. nail splitting and fragility)." "Relief of symptoms and signs" would likely be measured through patient diaries, clinical assessments (e.g., visual scores of nail integrity), or other objective measures of nail health. The document does not explicitly state the methodology.
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The sample size for the training set
- Not applicable/Not provided. As this is not an AI/machine learning device, there is no "training set" in the conventional sense. If clinical studies were performed, the number of subjects in those studies would be the relevant "sample size," but this is not specified.
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How the ground truth for the training set was established
- Not applicable/Not provided. As there is no training set for an algorithm, this question is not relevant. For the clinical studies mentioned, the "ground truth" (i.e., whether the treatment was effective) would be based on the pre-defined endpoints and measurement methodologies of those studies, which are not detailed.
In summary, the provided 510(k) summary for Ecocel® confirms its regulatory clearance based on substantial equivalence. However, it does not offer the granular detail on acceptance criteria, study methodologies, sample sizes, or ground truth establishment that would be present in a comprehensive study report, especially one for an AI or diagnostic device. The document states that the device's performance was substantiated by "preclinical studies" and "clinical studies," but the specifics of these studies are not disclosed in this summary.
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