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510(k) Data Aggregation
(186 days)
Z-Medica, LLC's QuikClot® Interventional Dressing (K090620)
QuikClot® Radial® is applied topically as an adjunct to manual compression and is indicated for the local management and control of surface bleeding from vascular access sites, percutaneous catheters or tubes utilizing introducer sheaths up to 7 Fr. in (a) patients on druq/induced anti-coagulation treatment and (b) patients not on druq/induced anti-coaqulation treatment.
The QuikClot® Radial® consists of a rolled hemostatic dressing to be used in conjunction with Tegaderm™, Coban™, or equivalent adhesive bandage (not supplied). The roll is a soft, white, sterile, hydrophilic, kaolin-impregnated gauze. Kaolin is a hemostatic agent that functions to stop bleeding in anti-coagulated patients, and is used in the same form and amount as in the predicate device. The kaolin is bound to the gauze in the same manner as in the predicate device. The QuikClot® Radial® is configured in 0.75" diameter x 1.5" length. The device is packaged for aseptic removal in a peelable foil pouch. The dressing is a single-use device that has suface contact with breached or compromised skin for a limited duration (≤24 hours).
The provided text describes the 510(k) premarket notification for the QuikClot® Radial® device, which is a hemostatic dressing. However, it does not contain specific acceptance criteria or a detailed study report that would typically lay out acceptance criteria and then demonstrate performance against them. Instead, it focuses on demonstrating substantial equivalence to a predicate device.
Here's a breakdown of the information provided, specifically addressing your numbered points, and highlighting what is not present in the document:
1. A table of acceptance criteria and the reported device performance
This information is not present in the provided document in the form of a table of specific acceptance criteria. The document states that the device achieved "successful hemostasis without occurrence of re-bleeding or radial artery occlusion" and that the "mean time to achieve successful hemostasis was significantly shorter" in one study. These are performance observations, but not defined acceptance criteria against which the device was measured for regulatory clearance in this specific document.
2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Test Set Sample Sizes:
- Study 1: 30 patients
- Study 2: 20 patients
- Data Provenance: The studies were described as "confirmatory clinical studies performed by the company." The provenance (country of origin) is not explicitly stated. They were prospective studies as patients were "randomized into cohorts."
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 information is not present in the document. The studies assessed clinical outcomes directly, observed by the study personnel, rather than relying on a separate ground truth established by experts.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This information is not present in the document. Clinical studies typically have protocols for assessing outcomes, but the specific adjudication method for the test set is not detailed here.
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
This is not applicable as the device is a hemostatic dressing, not an AI-powered diagnostic tool. Therefore, no MRMC study or AI-related effectiveness analysis was performed or is relevant.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This is not applicable as the device is a hemostatic dressing. The device is used by humans but it does not have a "standalone" algorithmic performance in the way an AI diagnostic tool would. Its performance is intrinsic to its physical and chemical properties and how it interacts with the patient's physiology.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
The "ground truth" for the clinical studies appears to be the directly observed clinical outcomes data related to hemostasis, re-bleeding, and radial artery occlusion. In Study 1, it also included the "mean time to achieve successful hemostasis."
8. The sample size for the training set
This is not applicable as the device is a physical hemostatic dressing, not an AI or machine learning algorithm that requires a training set.
9. How the ground truth for the training set was established
This is not applicable as the device is a physical hemostatic dressing, not an AI or machine learning algorithm.
Summary of Device Performance (from the document, without explicit acceptance criteria):
- Study 1 (30 patients):
- Achieved successful hemostasis without re-bleeding or radial artery occlusion in all patients treated with QuikClot® Radial®.
- Mean time to achieve successful hemostasis was significantly shorter for QuikClot® Radial® compared to the standard of care (TR Band).
- No major complications reported.
- Study 2 (20 patients):
- Achieved successful hemostasis without re-bleeding or radial artery occlusion in all patients treated with QuikClot® Radial®.
- No major complications reported.
In essence, the document confirms the device's safety and efficacy based on two small clinical studies and its substantial equivalence to an existing predicate device with a history of clinical data. It emphasizes that differences between the subject and predicate devices do not raise new safety or effectiveness concerns.
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(370 days)
QuikClot Interventional-A Hemostatic Bandage is applied topically as an adjunct to manual compression and is indicated for the local management and control of surface bleeding from vascular access sites, percutaneous catheters or tubes utilizing introducer sheaths up to 7 Fr. in patients on drug/induced anti-coagulation treatment.
The QuikClot Interventional-A Hemostatic Bandage that is the subject of this submission is described in detail in K090620 in that it is made of a soft, white, kaolin-impregnated gauze. QuikClot® Interventional-A Hemostatic Bandage may be provided in a kit form that consists of a hemostatic pad and an adhesive bandage. The adhesive bandage is a 3M Tegaderm® bandage (K973036) or equivalent. The hemostatic pad is a hemostatic dressing made of soft, white, kaolin impregnated gauze, configured in a 1 ½" long by l 1/2"wide by 1/2" thick multi-layer pad.
Here's an analysis of the acceptance criteria and supporting studies for the QuikClot Interventional-A Hemostatic Bandage, based on the provided document:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly state formal "acceptance criteria" in a quantitative format typical for regulatory submissions (e.g., "sensitivity must be > X%", "specificity must be > Y%"). Instead, it presents performance metrics from pre-clinical animal studies and clinical studies. The implicit acceptance criterion is that the device demonstrates efficacy in controlling bleeding in anticoagulated patients, comparable to or superior to control methods, with an acceptable safety profile.
| Metric/Study Objective | Implicit Acceptance Criteria (Inferred) | Reported Device Performance |
|---|---|---|
| Pre-Clinical Swine Model | ||
| Efficacy in Coumadin-treated pigs | Effective control of bleeding | 94.5% successful control of bleeding (vs 24% for control gauze) |
| Efficacy in Plavix-treated pigs | Effective control of bleeding | 91.2% successful control of bleeding (vs 29.7% for control gauze) |
| Safety in animal model | Safe use in anticoagulated model | No animal deaths due to bleeding. Wounds not fully controlled required additional manual compression. |
| Trabattoni D, et al. (2010) - Single Arm Pilot Study | ||
| Complete bleeding cessation at 5 min | High rate of cessation | Mean cumulative hemostasis time 4.9 ± 1.05 min (diagnostic: 4.2 ± 0.9 min, interventional: 5.3 ± 0.95 min) |
| Safe ambulation at 4 hours | All patients achieve safe ambulation | All patients achieved ambulation at 4 hours |
| Serious Adverse Events | Low incidence of adverse events | One patient required extra compression and developed a small hematoma (< 5cm) |
| Trabattoni D, et al. (2011) - Randomized Controlled Trial | ||
| Hemostasis time vs. manual compression | Shorter hemostasis time | QuikClot: 5.4 ± 1.5 min vs. Manual Compression: 25 ± 15 min (p<0.001) |
| Hemostasis failure rate | No hemostasis failure | No hemostasis failure in either group |
| Major bleeding / Hematoma > 5cm | Low incidence of events | Major Bleeding: 1 pt (QuikClot) vs. 1 pt (control); Hematoma > 5cm: 1 pt (QuikClot) vs. 2 pts (control) |
| Politi L, et al. (2011) - Randomized Clinical Trial (Radial) | ||
| Radial Artery Occlusion (RAO) | Low to no RAO | Group 1 (QuikClot): 0% RAO; Group 2 (control short time): 5% RAO; Group 3 (control 2 hours): 10% RAO (p = 0.05) |
| Active bleeding after compression removal | Lower incidence than control | Group 1 (QuikClot): 10 patients (20%); Group 2 (control short time): 18 patients (90%); Group 3 (control 2 hours): 1 patient (2%) (p < 0.001) |
| Post-Market Data | ||
| Success rate in controlling bleeding | High success rate | 96% success rate |
| Reported complications | Low incidence of complications | 1% reported complications |
| User satisfaction | High satisfaction | 93% improved outcome, 95% saved time, 97.4% would use again |
2. Sample Sizes and Data Provenance
-
Pre-clinical Study (Swine Model):
- Sample Size: 10 pigs (5 treated with Plavix, 5 with Coumadin). 187 intra-abdominal vascular injuries were tested across these animals.
- Data Provenance: United States (US), prospective animal model study.
-
Trabattoni D, et al. (2010):
- Sample Size: 40 human subjects.
- Data Provenance: Outside US (OUS), prospective single-arm pilot trial.
-
Trabattoni D, et al. (2011):
- Sample Size: 200 human subjects (100 in QuikClot group, 100 in manual compression control group).
- Data Provenance: Outside US (OUS), prospective randomized controlled trial.
-
Politi L, et al. (2011):
- Sample Size: 120 human subjects (Group 1 (QuikClot) n=50; Group 2 (control short time) n=20; Group 3 (control 2 hours) n=50). The study stopped enrolling Group 2 subjects due to unethically high bleeding rates.
- Data Provenance: Outside US (OUS), randomized clinical trial.
-
Post-Market Data:
- Sample Size: 138 Product Evaluation Forms. (Number of patients not explicitly stated, but implies at least 138 instances of use).
- Data Provenance: United States (US), real-world usage reports (retrospective collection of feedback forms).
3. Number of Experts and Qualifications for Ground Truth
- Animal Study: "One investigator" from a US site. Specific qualifications (e.g., veterinarian, surgeon) are not detailed. The ground truth (success/failure of bleeding cessation) was based on direct observation.
- Clinical Studies (Trabattoni and Politi): These were peer-reviewed clinical publications. The "ground truth" for outcomes like bleeding cessation, hemostasis time, ambulation, and adverse events would have been established by the study investigators (physicians/clinicians) based on direct observation, medical records, and established clinical protocols.
- Trabattoni (2010): Three investigators from one OUS site.
- Trabattoni (2011): Six investigators from one OUS site.
- Politi (2011): Ten investigators from one OUS site.
- Specific qualifications of these investigators (e.g., interventional cardiologist, years of experience) are not provided in this document, but being published implies they were qualified medical professionals.
- Post-Market Data: The "ground truth" for success/failure and complications was based on reports from "several health care institutions in the US." These would be the observations and assessments of the healthcare professionals using the device. Specific qualifications or number of individual experts are not given for this aggregated data.
4. Adjudication Method for the Test Set
The provided summary does not detail explicit adjudication methods for events or outcomes in the clinical studies (e.g., an independent clinical events committee). For the animal study, the single investigator would have determined success/failure. For the human studies, the study endpoints and assessment protocols would have guided the determination of outcomes by the investigators. It does not mention complex multi-reader/adjudicator processes.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No, an MRMC comparative effectiveness study was not explicitly mentioned. The clinical studies (Trabattoni (2011) and Politi (2011)) were randomized controlled trials comparing the device to standard care (manual compression), but they do not appear to be structured as MRMC studies that typically evaluate reader performance on cases with and without AI assistance. The studies here compare device performance (QuikClot) against a traditional method (manual compression) from the perspective of patient outcomes.
6. Standalone (Algorithm Only) Performance Study
No, a standalone (algorithm only without human-in-the-loop performance) study was not done. The QuikClot Interventional-A Hemostatic Bandage is a physical medical device (hemostatic dressing), not an algorithm or AI. Its performance is intrinsically linked to its application by a human healthcare professional as an adjunct to manual compression. The studies assess the device's effectiveness when used by humans.
7. Type of Ground Truth Used
- Pre-clinical Animal Study: Direct observation of bleeding cessation in a live animal model (surgical wounds).
- Clinical Studies (Trabattoni and Politi): Clinical observations, measurements (hemostasis time, ambulation time), and documented adverse events by medical investigators. This aligns with clinical outcomes data and expert assessment.
- Post-Market Data: Real-world clinical outcomes and observations reported by healthcare professionals through product evaluation forms.
8. Sample Size for the Training Set
The provided document describes the QuikClot Interventional-A Hemostatic Bandage as a modified version of a previously cleared device (K090620), with the primary change being an expanded indication for use in anticoagulated patients. The device itself is a physical product (kaolin-impregnated gauze), not a machine learning model. Therefore, the concept of a "training set" for an algorithm doesn't apply directly.
The device's development and prior clearance (K090620 and K072474) would have involved earlier testing and validation. The studies described in this K120782 submission serve as the test set to demonstrate the safety and effectiveness of the device for the new indication (use in anticoagulated patients).
If we interpret "training set" loosely as the accumulated evidence that informs the device's design and previous clearances:
- The device's core technology (kaolin hemostatic properties) is based on fundamental scientific principles and earlier research not detailed here.
- The original QuikClot Hemostatic Dressings (K072474) and QuikClot Interventional Hemostatic Bandage (K090620) underwent their own performance testing, which would form a "training set" of evidence for the device's general efficacy before this specific extended indication.
Relevant "Training" (Prior Evidence) mentioned:
The specific sample sizes for these prior clearances are not provided in the K120782 document.
9. How the Ground Truth for the Training Set Was Established
As explained above, since this is a physical medical device and not an AI algorithm, the concept of establishing ground truth for a "training set" in the machine learning sense doesn't apply. Instead, the prior evidence supporting the initial clearance of the QuikClot Interventional Hemostatic Bandage (K090620) and its predecessors (K072474) would have involved:
- Non-clinical (Bench and Animal) Testing: Biocompatibility tests (cytotoxicity, irritation, sensitization, systemic toxicity, genotoxicity, repeat exposure systemic toxicity), likely following ISO standards. These would have established the safety profile and basic hemostatic function.
- Clinical Data: The original submissions would have included clinical data to demonstrate the device's effectiveness for its initial indications. This would involve clinical observations, measurements, and adverse event reporting, similar to how ground truth was established for the "test set" studies presented in K120782.
The K120782 document focuses on adding a new indication to an already cleared and proven device. The studies presented within K120782 specifically address the safety and efficacy of the device (with its existing technology and design) when used in the new patient population (anticoagulated patients).
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