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510(k) Data Aggregation

    K Number
    K250438
    Date Cleared
    2025-04-11

    (56 days)

    Product Code
    Regulation Number
    884.3575
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K231786, K132313

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

    The CooperSurgical Milex pessaries are intended to provide support to pelvic organs when inserted in the vagina.

    The following Indications for Use are associated with each of the following pessary styles:

    Milex® Shaatz Folding Pessaries:
    Shaatz pessary is indicated for temporary, nonsurgical management of pelvic organ prolapse in Stage I and Stage II prolapse, complicated by a mild cystocele.

    Milex® Gellhorn Pessaries:
    Gellhorn pessary is indicated for temporary, nonsurgical management of pelvic organ prolapse in Stage III prolapse or procidentia.

    Milex® Ring Folding Pessaries:
    Milex Ring Pessary is indicated for use as removable structures placed in the vagina to treat uterine prolapse, including cystocele and rectocele, as well as stress urinary incontinence in women.

    Device Description

    Milex® Pessaries are intended for adult women as Obstetrical and Gynecological medical devices. Milex® Pessaries are distributed in a non-sterile condition made from silicone. The Milex Pessaries are available in a variety of styles, each having a range of sizes that is inserted into the vagina to function as a supportive structure of the uterus, bladder and rectum. All pessaries are produced in a like fashion, utilizing injection molding of liquid silicone rubber. The Milex Pessaries are manufactured in pink for single patient use.

    This submission includes the following designs of Milex Pessaries: Shaatz Pessary, Gellhorn Pessary (Short and Long Stem), and Ring Folding Pessaries (Ring without support, Ring with support, Ring with knob without support, Ring with knob with support).

    AI/ML Overview

    Based on the provided FDA 510(k) Clearance Letter and 510(k) Summary for CooperSurgical Milex® Pessaries, it's clear that this submission is for a medical device (vaginal pessaries) and NOT an AI/software device.

    Therefore, many of the questions related to acceptance criteria, MRMC studies, standalone algorithm performance, ground truth establishment, and training/test sets for AI models do not apply to this specific clearance.

    The "acceptance criteria" for this physical device are primarily based on demonstrating substantial equivalence to a predicate device through:

    • Identical/Similar Indications for Use: Showing that the new device is intended for the same medical purposes as the predicate.
    • Similar Technological Characteristics: Demonstrating that the materials, design, and fundamental principle of operation are comparable or that any differences do not raise new questions of safety or effectiveness.
    • Performance Data (Bench Testing/Biocompatibility): Providing evidence that the device performs as intended and is safe for its intended use, typically through non-clinical testing.

    Here's how to address the questions given the nature of the device:

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

    For a physical device like a pessary, "acceptance criteria" are typically defined by demonstrating substantial equivalence to a predicate device and meeting established performance and safety standards through non-clinical testing. The "reported device performance" refers to the results of these tests and the comparison to the predicate.

    Acceptance Criteria (Demonstrated Substantial Equivalence via)Reported Device Performance (Summary of Evidence)
    Identical Intended UseThe CooperSurgical Milex pessaries are intended to provide support to pelvic organs when inserted in the vagina, which is identical to the predicate device (Mentor Evacare Vaginal Pessaries, K993308) and supported by reference devices.
    Similar Fundamental Scientific Technology / Principles of OperationBoth the subject device and predicate device are removable structures placed in the vagina to support pelvic organs, manufactured from liquid silicone, and available in multiple shapes and sizes.
    Equivalent or Identical Indications for UseFor specific pessary styles (Shaatz, Gellhorn, Ring Folding), the indications align with or expand upon those of the predicate device, with reference devices supporting that these broader indications do not represent new intended uses.
    BiocompatibilityCytotoxicity: Non-cytotoxic (ISO 10993-5:2009)
    Sensitization: Non-sensitizer (ISO 10993-10:2021)
    Irritation or Intracutaneous Reactivity: Non-Irritant (ISO 10993-23:2021)
    Subacute/Subchronic Toxicity: Non-Subacute/Subchronic Toxic (ISO 10993-11:2017, and 10993-6:2016)
    Material Mediated Pyrogenicity: Non-Material Mediated Pyrogenic (ISO 10993-11:2017)
    Acute System Toxicity: Non-Acute Systemic Toxic (ISO 10993-11:2017)
    Genotoxicity: Non-Mutagenic/Non-Genotoxic (ISO 10993-3:2014, 10993-33:2015, 10993-11:2017)
    Implantation: Device induced no local response (ISO 10993-6:2016)
    Chronic Toxicity: Device induced no systemic toxicity (ISO 10993-6:2016, and 10993-11:2017)
    Engineering Rationale for additional sizesWhile the document states "Engineering Rationale for additional sizes of Milex Pessaries" was submitted, specific data or "acceptance criteria" are not detailed in this summary. It's stated that the slightly larger sizes "do not raise different questions of safety or effectiveness."
    Shelf Life of DeviceEvidence was submitted, but specific acceptance criteria or results are not detailed in this summary.
    Cleaning and Use LifeEvidence was submitted, but specific acceptance criteria or results are not detailed in this summary.
    Materials (Differences do not raise new questions of safety/effectiveness)The device is made of liquid silicone and colorant, similar to the predicate. Differences in specific formulations are stated not to raise new questions of safety or effectiveness.
    Dimensions and Sizing (Differences do not raise new questions of safety/effectiveness)The size ranges for various pessary styles are slightly larger than the predicate but are deemed not to raise different questions of safety or effectiveness.

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

    • Sample Size: The document does not specify a "sample size" for a clinical test set in the way one would for an AI model or a clinical trial. The performance data is based on biocompatibility testing of the device material, which involves laboratory tests with specific biological samples (e.g., cell cultures, animal models for implantation/toxicity studies) rather than patient data.
    • Data Provenance: Not applicable in the context of clinical patient data for this type of device. The data provenance would refer to the testing laboratories and their adherence to ISO standards for biocompatibility. The summary states "testing performed by CooperSurgical" and references international ISO standards.

    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)

    • Not applicable. This device is a physical medical device, not an AI or imaging diagnostic tool that relies on expert interpretation for ground truth.

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

    • Not applicable. As above, this is for a physical device, not an AI model requiring human adjudication of results.

    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 for a physical device, not an AI-assisted diagnostic tool.

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

    • Not applicable. This is not an algorithm or software.

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

    • Ground truth for this device is established through adherence to international consensus standards for medical device biocompatibility (ISO 10993 series) and engineering performance standards for physical characteristics like dimensions, durability, and material properties. It's not based on clinical "outcomes data" or "expert consensus" in the diagnostic sense, but rather on meeting pre-defined safety and performance benchmarks.

    8. The sample size for the training set

    • Not applicable. This is not an AI/ML device that requires a training set.

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

    • Not applicable. This is not an AI/ML device.
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    K Number
    K190277
    Date Cleared
    2019-07-08

    (150 days)

    Product Code
    Regulation Number
    884.3575
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K132313

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

    The ProVate Vaginal Support is indicated for the temporary, nonsurgical management of Pelvic Organ Prolapse in females.

    Device Description

    The ProVate Vaginal Support is a vaginal ring pessary intended for the conservative nonsurgical, temporary management of Pelvic Organ Prolapse (POP) in females. The ProVate is a disposable, single use device intended to use for up to seven (7) days. The ProVate device is intended for prescription home use following a size fitting process performed by a health care professional. The device is supplied in its compact mode, within a disposable Applicator intended for the insertion of the device is expanded into its circular ring shape using the Applicator Plunger when inserting the device into the vagina. At the end of its use (up to 7 days), the patient pulls the Removal String which collapses the device into its compact configuration, facilitating easy removal. The device is then thrown away, and a new device can be inserted by the patient as needed. The ProVate includes additional components to facilitate insertion and removal of the device. The ProVate device is constructed to allow insertion into the vagina by the patient while the device is in a compact mode contained within a single use applicator. The ProVate device is expanded to its circular shape using the applicator when inserted into the vagina. Once inserted, the circular shape of the ProVate is comparable to that of the predicate device and the ring provides support to the prolapsed organs. To remove the device, the ProVate includes a removal string. Pulling on the string collapses the device to its compact state allowing for easier and more comfortable removal.

    AI/ML Overview

    The ConTIPI Medical Ltd. ProVate Vaginal Support is a vaginal pessary intended for the temporary, nonsurgical management of Pelvic Organ Prolapse (POP) in females. The device's safety and effectiveness were evaluated through a series of bench tests and two clinical studies.

    1. Acceptance Criteria and Reported Device Performance

    The provided document does not explicitly present a table of "acceptance criteria" against which specific device performance metrics are directly reported in a comparative format. However, the document outlines various tests conducted and their successful outcomes, indicating that the device met the performance and safety requirements. The performance data section provides indirect evidence of fulfilling acceptance criteria.

    Test CategorySpecific Test / CriterionReported Device Performance
    Bench TestingInsertion ForceMet key performance specifications
    Removal ForceMet key performance specifications
    Directional compressionMet key performance specifications
    Repeatable directional compressionMet key performance specifications
    Extreme compressionMet key performance specifications
    Load on central AxisMet key performance specifications
    String Detachment ForceMet key performance specifications
    Removal String IntegrityMet key performance specifications
    Shelf LifeShelf life of the productSupported two (2) years shelf life
    BiocompatibilityCytotoxicity Study (ISO 10993-5)Non-cytotoxic
    Guinea Pig Maximization Sensitization Test (ISO 10993-10)Non-sensitizer
    Vaginal Irritation Study in Rabbits (ISO 10993-10)Non-irritant
    Muscle Implantation Study in Rabbits (ISO 10993-6)Macroscopic: Difference not significant; Microscopic: Non-irritant
    Genotoxicity: Bacterial Reverse Mutation Study (ISO 10993-3)Non-mutagenic
    Genotoxicity: Mouse Lymphoma Assay (ISO 10993-3)Non-mutagenic
    Toxicological Risk assessment (ISO 10993-18)Acceptable risk of daily dose-exposure to compounds from device use
    Microflora ImpactEvaluation of TSST-1 RiskLaboratory testing to evaluate impact on Staphylococcus aureus growth and TSST-1 production was performed (results not explicitly stated as metric, but implies acceptable risk)
    Clinical Study 1Primary endpoint: Changes in vaginal microflora (non-inferiority to control)Met successfully, showing non-inferiority of ProVate Device
    Clinical Study 2Improvement in prolapse from baseline (at least one stage)Demonstrated improvement from baseline of at least one stage in prolapse while in use
    Improvement in prolapse symptomsDemonstrated improvement in prolapse symptoms
    Safety: Adverse events rateDid not result in adverse events at a higher rate than predicate pessary devices; all device-related adverse events were mild and transient

    2. Sample Sizes and Data Provenance

    The document describes two clinical studies:

    • Prospective Safety Clinical Study:
      • Sample Size: Not explicitly stated but described as "statistically powered."
      • Data Provenance: Multicenter, randomized, cross-over study. The country of origin is not explicitly stated, but the manufacturer is based in Israel and the submission is to the U.S. FDA, suggesting potential international or U.S.-based study sites. The study design is prospective.
    • Prospective Clinical Study to Evaluate Safety and Effectiveness:
      • Sample Size: Not explicitly stated but described as "statistically powered."
      • Data Provenance: One arm, multi-clinic prospective study. Country of origin not explicitly stated.

    3. Number of Experts and Qualifications (for Ground Truth)

    The document does not detail the number of experts or their specific qualifications for establishing ground truth within the clinical studies. For the clinical studies, vaginal examinations were conducted by physicians, who would serve as experts in assessing prolapse stages and adverse events. Specific qualifications (e.g., years of experience, specialization) are not provided.

    • In the "Prospective Clinical Study to Evaluate Safety and Effectiveness," a "fitting process performed by a physician" is mentioned, indicating the involvement of medical professionals in determining appropriate device sizing and assessment.
    • "Vaginal examinations and microbial evaluations were performed at the beginning and at the end of each usage phase" in the safety study, again implying medical expert assessment.

    4. Adjudication Method

    The document does not specify an adjudication method for the test set data (e.g., 2+1, 3+1 for resolving discrepancies). It is implied that clinical assessments were made by individual clinicians or study investigators.

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

    No Multi-Reader Multi-Case (MRMC) comparative effectiveness study is mentioned. The clinical studies focused on the performance of the device itself, either in comparison to a control device (for microflora) or against a baseline (for prolapse improvement), rather than on the impact of AI assistance on human readers.

    6. Standalone Performance Study (Algorithm Only)

    This device is a physical medical device (vaginal pessary), not a software or AI algorithm. Therefore, a standalone (algorithm only) performance study is not applicable and was not conducted.

    7. Type of Ground Truth Used

    The ground truth for the clinical studies was based on:

    • Clinical Assessments: Vaginal examinations performed by physicians to assess prolapse stage (e.g., improvement by at least one stage, starting from stage 2 or 3 to stage 0 or 1).
    • Microbial Evaluations: Laboratory analysis of vaginal microflora.
    • Adverse Event Reporting: Clinical evaluation and reporting of adverse events.

    This constitutes a combination of expert clinical assessment and laboratory data.

    8. Sample Size for the Training Set

    This question is not applicable. The ProVate Vaginal Support is a physical medical device, not an AI or machine learning model that requires a training set. The "training" in this context refers to the development and iterative testing of the device, which is informed by engineering principles, bench testing, and clinical feedback, rather than a data training set for an algorithm.

    9. How Ground Truth for the Training Set was Established

    This question is not applicable for the same reason as point 8. The device development process involves engineering specifications and preclinical/clinical data gathering, not the establishment of ground truth for an algorithmic training set.

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