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510(k) Data Aggregation

    K Number
    K182259
    Manufacturer
    Date Cleared
    2019-02-07

    (170 days)

    Product Code
    Regulation Number
    878.3300
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K073391, K133011

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

    Gentrix® Surgical Matrix (3-layer) is intended for implantation to reinforce soft tissue where weakness exists in patients requiring urological, gastroenterological, or plastic & reconstructive surgery. Reinforcement of soft tissue within urological, gastroenterological, and plastic & reconstructive surgery includes, but is not limited to, the following open or laparoscopic procedures: hernia and body wall repair, colon and rectal prolapse repair, and esophageal repair. The Gentrix® Surgical Matrix (3-layer) minimizes tissue attachment to the device in case of direct contact with viscera.

    Gentrix® Surgical Matrix and Gentrix® Surgical Matrix Hiatal (6-layer and 8-Layer) are intended for implantation to reinforce soft tissue where weakness exists in patients requiring gastroenterological or plastic & reconstructive surgery. Reinforcement of soft tissue within gastroenterological and plastic & reconstructive surgery includes, but is not limited to, the following open or laparoscopic procedures: hernia (e.g.: hiatal/diaphragmatic) and body wall repair, colon and rectal prolapse repair, tissue repair, and esophageal repair. The Gentrix® Surgical Matrix and Gentrix® Surgical Matrix Hiatal (6-layer and 8-Layer) minimizes tissue attachment to the device in case of direct contact with viscera.

    Device Description

    Gentrix Surgical Matrix and Gentrix® Surgical Matrix Hiatal device configurations are composed of porcine-derived extracellular matrix scaffically known as urinary bladder matrix ("UBM"). The implantable biomaterial is a resorbable extracellular matrix scaffold that provides mechanical reinforcement of soft tissue and will incorporate (remodel) into the body through cellular infiltration, capillary growth, and integration by the surrounding host tissue (as demonstrated in porcine models of ventral and hiatal hernia), while minimizing tissue attachment to the device in case of direct contact with viscera (as demonstrated in a preclinical rabbit cecal abrasion model). The devices are supplied in multiple layered sheet configurations in sizes up to 10 cm x 15 cm, and are available in rectangular and u-shape variations. All device configurations are packaged in double peel-open sterile barrier system. The devices are terminally sterilized using electron beam irradiation. The devices are intended for one time use.

    AI/ML Overview

    The document describes the Gentrix Surgical Matrix and Gentrix Surgical Matrix Hiatal devices. The acceptance criteria and the study that proves the device meets the acceptance criteria are primarily focused on demonstrating substantial equivalence to a predicate device and supporting the expanded indications for use.

    Here's an analysis of the provided information based on your requested points:

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

    The document does not explicitly state "acceptance criteria" in a quantitative, pre-defined manner typical for AI/ML device performance. Instead, it describes studies conducted to support the substantial equivalence and safety/effectiveness of the device for its intended use, particularly for new indications like laparoscopic use and specific hiatal/diaphragmatic hernia repair, and minimizing tissue attachment.

    The closest to acceptance criteria and performance can be inferred from the animal studies on tissue attachment:

    Acceptance Criteria (Inferred from goals)Reported Device Performance
    Minimize tissue attachment compared to collagen mesh control in case of direct contact with viscera.Day 14:
    Gentrix Surgical Matrix (3, 6, 8-Layer): 0% animals with attachments, 0 average attachment severity score, 0 total attachments, 0 cm average estimated attachment diameter, 0% device covered with attachments.
    Collagen Mesh Control: 17% animals with attachments, 0.2 average attachment severity score, 1 total attachment, 1.0 cm average estimated attachment diameter, 0.83% device covered with attachments.
    Day 90:
    Gentrix Surgical Matrix (3-Layer): 17% animals with attachments, 0.3 average attachment severity score, 1 total attachment, 1 cm average estimated attachment diameter, 4.17% device covered with attachments.
    Gentrix Surgical Matrix (6-Layer): 33% animals with attachments, 0.7 average attachment severity score, 3 total attachments, 0.5 cm average estimated attachment diameter, 0.83% device covered with attachments.
    Gentrix Surgical Matrix (8-Layer): 0% animals with attachments, 0 average attachment severity score, 0 total attachments, 0 cm average estimated attachment diameter, 0% device covered with attachments.
    Collagen Mesh Control: 67% animals with attachments, 1.0 average attachment severity score, 5 total attachments, 1.6 cm average estimated attachment diameter, 14.16% device covered with attachments.
    Acceptable tissue responses with no instances of herniation or esophageal erosion or trauma in hiatal hernia repair model.Porcine Hiatal Hernia Model (U-Shape design): Demonstrated acceptable tissue responses, no herniation, no esophageal erosion or trauma.
    No impact on product performance from pre-fabricated u-shape design.Porcine Hiatal Hernia Model (U-Shape design): Concluded that the pre-fabricated u-shape did not impact product performance.
    Remodeling through cellular infiltration, capillary growth, and integration by surrounding host tissue.Histological analysis (porcine and rabbit models): Demonstrated that subject devices undergo remodeling through cellular infiltration, capillary growth, and integration.
    Safety and performance for enclosed indications (including hiatal hernia repair based on clinical literature).Clinical Literature Review: Six retrospective publications supported the safety and performance for hiatal hernia repair. Outcomes varied by study (e.g., radiographic recurrence rates from 22% down to 0%, post-operative complication rates). The conclusion was that the clinical data provides support for the indications.
    Substantial equivalence to predicate device (Gentrix™ Surgical Matrix 2-Layer, 3-Layer, 6-Layer, 8-Layer (K162554)) in terms of intended use, technological characteristics, and safety/effectiveness for new labeled uses. This is the overarching "acceptance criterion" for a 510(k).The studies (pre-clinical animal studies, clinical data from literature) were designed to demonstrate that the subject devices have the same intended use as the predicate and equivalent technological characteristics, supporting the safety and effectiveness for new labeled uses (like hiatal hernia repair). The FDA's clearance letter confirms this substantial equivalence was met.

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

    • Pre-clinical (Animal) Studies Data (Test Set):

      • Porcine Hiatal Hernia Model (U-shape design): 10 pigs. Prospective. Provenance not specified but typically conducted in controlled laboratory settings.
      • Porcine Hiatal Hernia Repair Model (laparoscopic and hiatal/diaphragmatic hernia indications): Number of animals not explicitly stated, but it conducted over a 60-day study duration. Prospective. Provenance not specified.
      • New Zealand White Rabbit Cecal Abrasion Model (tissue attachment): 6 animals per group (Control, GSM 3-Layer, GSM 6-Layer, GSM 8-Layer, Collagen Mesh Control) for Day 14 and Day 90. Total of 30 animals for each time point evaluation (assuming distinct animals for each time point or repeat measurements on same). Prospective. Provenance not specified.
    • Clinical Data (Test Set - from literature review):

      • Retrospective Study 1 (Zografakis et al.): 62 patients. Retrospective. Provenance implied by the authors' affiliation if provided (not in this excerpt), likely US or Europe.
      • Retrospective Study 2 (Howell et al.): 121 patients (56 UBM group, 65 non-UBM group). Retrospective. Provenance implied by the authors' affiliation if provided.
      • Retrospective Study 3 (Sasse et al.): 15 patients. Retrospective. Provenance implied by the authors' affiliation if provided.
      • Retrospective Study 4 (Reznichenko): 1 single patient. Retrospective. Provenance implied by the authors' affiliation if provided.
      • Retrospective Study 5 (Reznichenko): 11 patients (4 reinforced with GSM). Retrospective. Rural community hospital setting, likely US.
      • Retrospective Study 6 (Wang, C.Q. et al.): 37 patients (22 reinforced with GSM, 15 non-reinforced). Retrospective. Poster presentation at a society meeting, likely US.

    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)

    • Pre-clinical Studies:

      • Porcine Hiatal Hernia Model: An independent clinical pathologist evaluated tissue morphology/health, considered "not clinically significant" the mild narrowing. Specific number of pathologists and their qualifications not stated, but "independent" implies objectivity.
      • Rabbit Cecal Abrasion Model & Porcine Hiatal Hernia Repair Model: The evaluation of attachments, herniation, erosion, trauma, and histological analysis would have been performed by trained personnel (e.g., veterinarians, pathologists). Specific numbers and qualifications are not detailed.
    • Clinical Data (from literature):

      • The "ground truth" here is the clinical outcomes reported by the original study authors (surgeons, researchers).
      • Study 1: Single surgeon performing LHR.
      • Study 2: 3 surgeons performing PHH repair.
      • Study 3: Single surgeon performing LHR.
      • Study 4: Single retrospective case.
      • Study 5: Single surgeon performing LHR.
      • Study 6: Same surgeon performing PHH repair.
      • Qualifications of these surgeons are not provided in this summary, but they are implicitly qualified clinicians performing surgical procedures and assessing outcomes.

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

    • Pre-clinical Studies: The document does not describe a formal multi-expert adjudication method (like 2+1 or 3+1). Decisions appear to be made by individual evaluators (e.g., "independent clinical pathologist").
    • Clinical Data (from literature): Since these are summaries of published clinical studies, specific adjudication methods for their outcomes (e.g., recurrence, complications) were part of the original study designs. The summaries provided here do not detail such methods. Decisions on complications and recurrences were likely made by the treating physicians or study investigators.

    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

    There is no mention of an AI/ML device in this document. Therefore, no MRMC comparative effectiveness study involving AI assistance for human readers was conducted or reported. This application is for a surgical mesh device, not an AI diagnostic tool.

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

    Applicable to AI/ML devices only. As stated above, this is not an AI/ML device, so no standalone algorithm performance was assessed.

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

    • Pre-clinical (Animal) Studies:
      • Pathology: Macroscopic and microscopic histological analysis of tissues to assess remodeling, inflammation, and integration.
      • Direct Observation/Measurement: Assessment of herniation, esophageal erosion/trauma, and quantitative measurements of tissue attachments (percentage coverage, diameter, severity score), based on expert observation.
    • Clinical Data (from literature):
      • Clinical Outcomes Data: Patient symptoms (shortness of breath, nausea, dysphagia, reflux), intraoperative/postoperative complications, reoperations, radiographic recurrence rates (contrast upper gastrointestinal series), endoscopic evaluations, BMI, HRQL scores, hospital length of stay, 30-day readmissions. These are derived from clinical practice and reported by the treating physicians/researchers.

    8. The sample size for the training set

    This is not an AI/ML device, so there is no concept of a "training set" in the context of machine learning model development. The document describes pre-clinical (animal) studies and a review of existing clinical data to support the safety and effectiveness of the device.

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

    Not applicable, as this is not an AI/ML device and there is no training set mentioned.

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