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510(k) Data Aggregation

    K Number
    K092829
    Device Name
    INSERTEASE
    Date Cleared
    2009-12-02

    (78 days)

    Product Code
    Regulation Number
    876.4730
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K092829

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

    InsertEase™ is to be used as a device for the insertion of prescription and over the counter suppositories into the rectum

    Device Description

    The rectal suppository applicator, to be called, InsertEase™, is a plastic, non sterile, single use device for the insertion of prescription and over the counter suppositories into the rectum. The design of InsertEase™ is substantially equivalent to a vaginal applicator used for inserting vaginal suppositories, creams and tampons. One piece, the plunger, will be movably coupled within a second piece, the barrel. The barrel has an open end to receive and hold a suppository, which is then inserted into the anus. The plunger is then pushed into the barrel and places the suppository within the rectum. InsertEase™ functions in the same way and manner that vaginal applicators insert vaginal suppositories and tampons.

    AI/ML Overview

    The provided text describes a 510(k) submission for a rectal suppository applicator called "InsertEase™". The core of the submission revolves around demonstrating substantial equivalence to already legally marketed predicate devices, primarily vaginal applicators.

    Here's an analysis of the acceptance criteria and the study as described in the document, keeping in mind that the primary "study" is a comparison to predicate devices rather than a traditional clinical trial:

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

    Since this is a 510(k) submission based on substantial equivalence, the "acceptance criteria" are not quantitative performance metrics like sensitivity or specificity. Instead, the acceptance criteria are met if the device demonstrates equivalent:

    Acceptance Criteria CategoryPredicate Device (Vaginal Applicator)InsertEase™ (Rectal Suppository Applicator)Outcome / Performance
    Intended UseInsertion of medication into the vagina.Insertion of suppositories into the rectum.Equivalent Function: The document argues that the only difference is the anatomical orifice, and the function of inserting a suppository is the same.
    DesignTwo-piece, plunger within a barrel, open end to hold suppository.Two-piece, plunger within a barrel, open end to hold suppository.Equivalent Design: Described as "substantially equivalent" design.
    MaterialsPlastic (medical grade)Plastic (medical grade)Equivalent Materials: Both are plastic applicators to be extruded using medical grade plastic.
    SterilityNon-sterile (implied for common applicators)Non-sterileEquivalent Status: Both are non-sterile.
    Single UseSingle use (implied for common applicators)Single useEquivalent Status: Both are single use.
    Function/MovementInserts vaginal suppositories/tampons by pushing plunger.Inserts rectal suppositories by pushing plunger.Equivalent Function: "functions in the same way and manner".
    Manufacturing FacilityFDA approved manufacturing facilityFDA approved manufacturing facilityEquivalent Compliance: Will be manufactured in an FDA approved facility.
    Safety and EffectivenessDemonstrated by predicate devices.Not questioned when used as labeled, based on predicate equivalence.Equivalent Assumed: Safety and effectiveness are not in question due to the similarity in function to established predicate devices.
    ClassificationClass I (Rectal Applicator, Vaginal Applicator)Class IEquivalent Classification: Both are Class I devices.

    2. Sample sized used for the test set and the data provenance

    • Sample Size for Test Set: Not applicable in the context of a 510(k) based on substantial equivalence to a physical device. There wasn't a "test set" of performance data generated, but rather a comparison of technical characteristics and intended use.
    • Data Provenance: The "data" primarily comes from the established regulatory classifications and descriptions of existing predicate devices marketed in the United States (implied by FDA regulation). This is retrospective in the sense that it relies on the known characteristics and regulatory history of pre-existing devices.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    Not applicable. Ground truth, in the sense of expert review of performance, was not established for InsertEase™ using a test set. The "ground truth" for the substantial equivalence claim relies on the established regulatory framework and common understanding of how such applicators function, and their safety/effectiveness as previously determined by the FDA for similar devices.

    4. Adjudication method for the test set

    Not applicable, as there was no test set or expert adjudication process described for performance evaluation.

    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 medical device for physical application, not an AI-powered diagnostic or assistive technology for human readers. Therefore, no MRMC study was conducted or relevant to this submission.

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

    Not applicable. This is a physical device, not an algorithm.

    7. The type of ground truth used

    The "ground truth" for this submission is based on:

    • Predicate Device Characteristics: The established design, materials, intended use, and functional principles of legally marketed vaginal applicators (Product Code: 884.4520(7)) and other relevant devices like Enema Kits (876.5210) and Rectal Dilators (876.5450), and the precedent set by the FDA regarding the Rectal Speculum vs. Vaginal Speculum.
    • Regulatory Precedent: The FDA's prior determination of substantial equivalence for devices with similar function but different anatomical sites (e.g., vaginal vs. rectal speculums).

    8. The sample size for the training set

    Not applicable. This is a physical medical 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 this type of device submission.

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