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510(k) Data Aggregation

    K Number
    K082601
    Date Cleared
    2008-10-09

    (31 days)

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

    K081183, K070010, K061079, K070211, K071578

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

    Prescription, Rx UltraClot™ is intended as a hemostatic dressing for emergency external use and temporary wound treatment to achieve hemostasis of moderate to severe bleeding.

    Over the Counter, OTC

    UltraClot™ OTC is intended as a topical hemostatic dressing for the local management of bleeding from minor cuts, lacerations, and abrasions.

    Device Description

    UltraClot™ is a hemostatic agent comprising a clay-based powder contained in a dissolving pouch with a non-stick gauze pad backing that is placed on a moderate to severe wound and held in place until hemostasis is achieved. The device is packaged in a vacuum sealed foil bag and is provided sterile.

    AI/ML Overview

    The provided text is a 510(k) summary for the UltraClot™ and UltraClot™ OTC devices. These documents are typically for medical devices seeking FDA clearance based on substantial equivalence to a predicate device, rather than requiring extensive clinical trials to prove efficacy against defined acceptance criteria in the same way a new drug or high-risk medical device might.

    The key information regarding "acceptance criteria" and "study that proves the device meets the acceptance criteria" in the context of this 510(k) is related to demonstrating substantial equivalence to a predicate device through non-clinical testing, particularly animal models and biocompatibility.

    Here's an analysis of the provided text in relation to your questions, noting that many of the requested details for AI/software studies are not applicable to this type of device submission:

    1. A table of acceptance criteria and the reported device performance

    The document does not explicitly state "acceptance criteria" in a quantitative, tabular format as one might find for a software-based diagnostic AI. Instead, the "acceptance criteria" for this 510(k) are implicitly met by demonstrating substantial equivalence to the predicate device, Quikclot®, in terms of mechanism, safety, and efficacy.

    Acceptance Criteria (Implied for Substantial Equivalence)Reported Device Performance (UltraClot™)
    Similar adsorptive mechanismHas a similar adsorptive mechanism to Quikclot®.
    Equivalent speed of hemostasisFound to be at least substantially equivalent to Quikclot® in terms of speed of hemostasis.
    Equivalent efficacy of hemostasisFound to be at least substantially equivalent to Quikclot® in terms of efficacy.
    Absence of exothermiaDemonstrates absence of exothermia.
    Reduced blood lossDemonstrates reduced blood loss.
    Biocompatibility (safety for intended use)Biocompatibility testing demonstrated UltraClot™ to be safe for its intended use (mutagenicity, cytotoxicity, intracutaneous studies).
    Similar indications for useIntended as a hemostatic dressing for emergency external use and temporary wound treatment to achieve hemostasis of moderate to severe bleeding (similar to predicate).
    OTC version labeling conformanceLabeling modified in conformance with 21CFR 801 Subpart C, consistent with other legally marketed OTC wound management devices.

    2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    • Sample Size for Test Set: The document mentions "animal models" for testing speed and efficacy. However, it does not specify the number of animals (sample size) used in these models.
    • Data Provenance: Not explicitly stated, but clinical studies are generally prospective. Animal studies are experimental. The document does not specify the country of origin. This is a non-clinical study.

    3. 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)

    This is not applicable to the type of device and study described. The evaluation in animal models would typically be based on physiological measurements (e.g., clotting time, blood loss) rather than expert interpretation of images or clinical assessments requiring a panel of human experts to establish "ground truth."

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    Not applicable. This is not a study involving human readers or adjudicators of a test set in the context of diagnostic AI.

    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

    Not applicable. This is a physical hemostatic device, not an AI or software-based diagnostic tool. No MRMC study was performed.

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

    Not applicable. This is a physical hemostatic device.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    The "ground truth" in the animal model studies would be objective physiological measures of hemostasis, such as:

    • Time to hemostasis
    • Volume of blood loss
    • Presence/absence of exothermic reaction

    These are direct measurements of the device's physical and physiological effect in a controlled animal setting, rather than subjective expert consensus or pathology in the context of diagnostic performance.

    8. The sample size for the training set

    Not applicable. This is not a machine learning or AI-based device that requires a training set.

    9. How the ground truth for the training set was established

    Not applicable, as there is no training set for this type of device.

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    K Number
    K081183
    Device Name
    WOUNDSTAT
    Manufacturer
    Date Cleared
    2008-06-19

    (55 days)

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

    K070010, K061079, K070211, K071578, K013390

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

    WoundStat™ wound dressing for OTC is indicated for temporary external use to control bleeding from minor cuts and abrasions of the skin.

    Device Description

    WoundStat™ is a clay-based, granufar hemostatic agent that is poured on a moderate to severe wound and held in place until it adheres to the wound and hemostasis is achieved. The device is packaged in a foil package and is provided sterile.

    AI/ML Overview

    This document is a 510(k) premarket notification for WoundStat™, a wound dressing intended for over-the-counter (OTC) use to control bleeding from minor cuts and abrasions. It's an administrative update to a previous 510(k) K071936 which originally cleared WoundStat™ for prescription (Rx) use.

    Here's an analysis of the acceptance criteria and supporting study information:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document does not explicitly define specific performance acceptance criteria (e.g., stopping bleeding within X seconds for Y% of cases) for the OTC version of WoundStat™. Instead, the core of the submission relies on demonstrating substantial equivalence to its own previously cleared Rx version and other legally marketed OTC hemostatic agents.

    The reported device performance, therefore, is primarily that:

    • Mechanism of action is unchanged from the Rx version.
    • It is demonstrated to be as safe and effective as the WoundStat™ for Rx use (K071936).
    • It is similar to other legally marketed OTC wound management devices in terms of intended use and effectiveness for temporary external use to control bleeding from minor cuts and abrasions.
    Acceptance Criteria (Explicitly Stated in Document)Reported Device Performance
    Safety & Effectiveness (as compared to Rx version)Deemed "as safe and effective" as WoundStat™ for Rx use (K071963).
    Meeting OTC labeling requirementsLabeling revised "in conformance with 21 CFR 801 Subpart C" and "modeled after legally marketed OTC wound management devices".
    Similar mechanism of actionMechanism of action is "unchanged" from the Rx version.

    2. Sample Sizes Used for the Test Set and Data Provenance:

    The document does not describe a new clinical study or test set specifically for this OTC 510(k) submission. Instead, it leverages the previous clearance of WoundStat™ for Rx use (K071936). The basis for "as safe and effective" likely stems from data or analyses provided in the K071936 submission. Without access to K071936, the specifics of its test set sample size and data provenance cannot be determined from this document.

    3. Number of Experts Used to Establish Ground Truth and Qualifications:

    This document does not mention the use of experts to establish a ground truth for a new test set for the OTC clearance. The assessment is based on comparison to existing cleared devices and the previous Rx clearance. Any expert involvement would have been part of the K071936 submission or the development of the predicate devices.

    4. Adjudication Method:

    Not applicable, as no new specific test set or clinical study requiring adjudication is described in this document for the OTC clearance.

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

    Not applicable. This document is for a medical device (wound dressing), not an AI/imaging diagnostic tool. Therefore, an MRMC study comparing human readers with and without AI assistance is not relevant.

    6. Standalone (Algorithm Only) Performance Study:

    Not applicable. This is a physical wound dressing, not an algorithm or software. Its performance is inherent to its physical and chemical properties when applied.

    7. Type of Ground Truth Used:

    For this OTC submission, the "ground truth" implicitly relies on:

    • Previous FDA clearance of its own Rx version (K071936): This implies that the Rx version was found safe and effective based on its own ground truth (e.g., animal studies, clinical data on hemostasis).
    • Established safety and effectiveness of predicate OTC devices: The comparison to other legally marketed OTC hemostatic agents (QuikClot Sport™, CELOX, BleedArrest™, BloodStop) suggests that the "ground truth" for these devices' performance in controlling minor bleeding is generally accepted by the FDA for OTC applications.

    8. Sample Size for the Training Set:

    Not applicable. This is a physical device, not a machine learning model, so there is no "training set."

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

    Not applicable, as there is no training set for a physical device.


    Summary of Device Meeting Acceptance Criteria:

    The device, WoundStat™ for OTC use, meets the "acceptance criteria" by demonstrating substantial equivalence to its own previously cleared prescription version (K071936) and other legally marketed OTC hemostatic agents. The study proving this essentially refers back to the data and rationale provided in the K071936 submission, along with a revised labeling conforming to OTC regulations (21 CFR 801 Subpart C). The core logic is that if the Rx version was safe and effective for its broader indications, and the mechanism of action remains the same, then the OTC version with more limited indications (minor cuts and abrasions) and appropriate labeling is also safe and effective. No new clinical trials or performance studies are described in this specific 510(k) update for the OTC clearance.

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