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510(k) Data Aggregation
(147 days)
Indicated for the management of various types of dermatoses, including atopic dermatitis and allergic contact dermatitis
NEOCERA Advanced Cream is a fragrance-free, water-soluble dressing formulated for the management of various types of dermatoses, including atopic dermatitis and allergic contact dermatitis. NEOCERA Cream is intended for topical application. This product is to be sold by prescription only.
The provided text describes a 510(k) premarket notification for a medical device called NEOCERA Advanced Barrier Cream. It focuses on establishing substantial equivalence to a predicate device, Neosalus cream. Therefore, the "acceptance criteria" and "device performance" are primarily demonstrated through comparison to the predicate device and specific non-clinical and clinical tests. It is essential to note that this document does not describe a study comparing the device against specific, quantitative performance acceptance criteria in the way one might expect for a diagnostic or therapeutic device with measurable outcomes. Instead, it demonstrates safety and biocompatibility to support substantial equivalence.
Here's an analysis of the provided information:
1. A table of acceptance criteria and the reported device performance
Since this is a substantial equivalence submission for a topical cream, the "acceptance criteria" are implied by the performance of the predicate device and the regulatory requirements for similar products, particularly for safety and biocompatibility. The "reported device performance" refers to how NEOCERA cream met these implied criteria through specific tests.
Acceptance Criteria (Implied) | Reported Device Performance (NEOCERA Cream) |
---|---|
Safety and Biocompatibility: | |
- Non-cytotoxic | - Met requirements of ISO 10993-5 (Test for In Vitro Cytotoxicity); not cytotoxic. |
- Non-irritating (dermal) | - Primary Dermal Irritation Index of 0.67 (on a scale of 0-8), categorized as "slightly irritant" (lower end of 0.5-1.9 range). |
- Non-sensitizing (allergic contact) | - Did not elicit sensitization reactions in guinea pigs (ISO 10993-10). |
- Non-irritating/non-sensitizing in humans (dermal) | - No potential for dermal irritation or allergic contact sensitization in humans based on Repeated Insult Patch Test. |
- Antimicrobial Efficacy | - Met requirements. |
Functional Equivalence: | |
- Similar Intended Use and Indications for Use as predicate | - "Management of various types of dermatoses, including atopic dermatitis and allergic contact dermatitis." Identical to predicate. |
- Prescription Use Only | - Yes. Identical to predicate. |
- Topical Dressing | - Similar to predicate. |
- Similar Composition (with justifiable differences) | - Similar composition to predicate, with additional ingredients (Ceramide PC-104, Palmitamide MEA, Glycyrrhetinic Acid, Grape seed extract, Petrolatum, higher Dimethicone) previously used in cleared devices for enhanced application. |
- Non-Sterile | - Non-Sterile. |
Shelf Life: | |
- Adequate stability (predicate has 36 months) | - 24 months (on-going stability). This is shorter than the predicate's 36 months but presumably deemed acceptable for initial marketing, with stability testing continuing. |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Cytotoxicity Agar Diffusion: Not specified, but generally involves a standard number of cell cultures.
- Primary Dermal Irritation in Rabbits: Not specified, but rabbit irritation tests typically involve 3-6 rabbits.
- Guinea Pig Closed Patch Sensitization Test: Not specified, but standard guinea pig sensitization studies typically use 10-20 animals per group.
- Repeated Insult Patch Test in Humans: Not specified. These studies can range from 50 to over 200 subjects.
The document does not explicitly state the country of origin for the data or whether the studies were retrospective or prospective, though biocompatibility and human patch tests are typically prospective.
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 section is not applicable as the document describes biocompatibility and safety testing for a topical cream, not a diagnostic device requiring expert interpretation of images or clinical findings to establish a "ground truth." The results of the tests (e.g., cytotoxicity, irritation index) are objective measurements.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This is not applicable for the reported non-clinical and clinical (safety) tests. Adjudication methods like "2+1" or "3+1" are typically used in studies where multiple human readers interpret data (e.g., medical images) and a consensus or tie-breaking mechanism is needed to establish ground truth. The tests performed are objective, laboratory-based, or involve direct observation (like irritation scores) by trained personnel according to standardized protocols.
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. An MRMC study is designed for evaluating diagnostic devices, particularly those involving human interpretation, and comparing performance with and without AI assistance. This document pertains to a topical cream, not an AI-enabled diagnostic device.
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 topical cream, not an algorithm or AI system.
7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)
Given the nature of the device and tests, the "ground truth" is defined by:
- For Biocompatibility (cytotoxicity, irritation, sensitization): Standardized ISO (International Organization for Standardization) protocols and GLP (Good Laboratory Practice) standards are used to generate objective quantitative and qualitative results (e.g., cytotoxicity score, irritation index, presence/absence of sensitization).
- For Human Repeated Insult Patch Test: Direct observation and scoring of skin reactions by trained clinicians or dermatologists against a predefined scale, following Good Clinical Practice (GCP) principles as indicated by adherence to the Declaration of Helsinki, ICH E6, and 21 CFR Parts 50 and 56.
8. The sample size for the training set
This is not applicable. This document describes the testing of a cream, not an algorithm that requires a training set. The term "training set" is relevant for machine learning models.
9. How the ground truth for the training set was established
This is not applicable as there is no training set for this device.
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