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510(k) Data Aggregation
(99 days)
Collagen Nerve Wrap is indicated for the management of peripheral nerve injuries in which there has been no substantial loss of nerve tissue and where gap closure can be achieved by flexion of the extremity.
Collagen Nerve Wrap is a resorbable collagen matrix that provides a non-constricting encasement for injured peripheral nerves for protection of the neural environment. Collagen Nerve Wrap is designed to be an interface between the newe and the surrounding tissue. When hydrated, Collagen Nerve Wrap is an easy to handle, soft, pliable, nonfriable, porous collagen conduit. The wall of the conduit has a longitudinal slit that allows Collagen Nerve Wrap to be spread open for easy placement over the injured nerve. The resilience of the Collagen Nerve Wrap allows the product to recover and maintain closure once the device is placed around the nerve. Collagen Nerve Wrap is provided sterile, non-pyrogenic, for single use only, in a variety of sizes, and in double peel packages.
This document is a 510(k) summary for a medical device called "Collagen Nerve Wrap." The purpose of a 510(k) submission is to demonstrate that the new device is substantially equivalent to a legally marketed predicate device, rather than proving its effectiveness through a typical clinical trial with acceptance criteria and comparative studies as one might find for a novel drug or a high-risk device.
Therefore, the information you're requesting regarding acceptance criteria, specific study details (sample size for test set/training set, ground truth establishment, expert involvement, MRMC studies, standalone performance), and effect sizes of AI assistance is not typically found in a 510(k) submission for a device like this, as it's not a diagnostic AI device or a device requiring extensive clinical performance measures against predefined metrics.
Instead, the submission focuses on demonstrating substantial equivalence to existing predicate devices based on technical characteristics, materials, and safety/biocompatibility testing.
Here's an analysis based on the provided text, addressing your points where applicable and explaining why others are not included:
1. A table of acceptance criteria and the reported device performance
This type of table is not applicable here. The submission does not define specific performance acceptance criteria (e.g., sensitivity, specificity, accuracy) that would be typically seen for diagnostic devices or AI algorithms. Instead, the "effectiveness" is assessed by demonstrating that its characteristics meet design requirements and comparing it to predicate devices.
Acceptance Criteria (Not explicitly stated as performance metrics) | Reported Device Performance (Summary) |
---|---|
Safe (Biocompatibility) | Passed all selected FDA Blue Book Memorandum G95-1 and ISO 10993-1 testing for biological evaluation of medical devices. |
Effective (Meets design requirements for a nerve protector) | Characteristics of the Collagen Nerve Wrap meet design requirements for an effective nerve protector. |
Substantially Equivalent to Predicates | Demonstrated through animal study, in vitro product characterization, in vitro and in vivo biocompatibility studies. |
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 Size: Not applicable/provided in the context of typical clinical performance testing as would be requested for an AI diagnostic device. The "test set" here would refer to the animal study and various in vitro and in vivo biocompatibility tests. No specific sample sizes for these individual tests are provided, nor are details on data provenance (e.g., country) or study design (retrospective/prospective) for these tests within this summary.
- Data Provenance: Not specified for the animal study or biocompatibility tests.
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 resorbable collagen matrix for nerve protection, not a diagnostic tool requiring expert interpretation or "ground truth" establishment in the way an imaging AI algorithm would.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. As above, no adjudication method for establishing ground truth is mentioned or relevant for this type of device submission.
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
No. A MRMC study is relevant for diagnostic imaging devices, especially those incorporating AI. This device is a surgically implanted collagen wrap; therefore, an MRMC study is not relevant or reported.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This is not an algorithm or AI device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
Not explicitly defined as "ground truth" in this context. For a device like this, "ground truth" would be inferred from the successful completion of biocompatibility tests and the in vivo animal study demonstrating appropriate physiological responses and nerve protection that are comparable to predicate devices. This isn't a diagnostic scenario where a "truth" needs to be established through expert consensus or pathology.
8. The sample size for the training set
Not applicable. This device does not involve a "training set" as it is not an AI/machine learning model.
9. How the ground truth for the training set was established
Not applicable. This device does not involve a "training set" or a ground truth established in the context of machine learning.
Summary of the Study that Proves the Device Meets the Acceptance Criteria:
The "study" demonstrating the Collagen Nerve Wrap's safety and effectiveness (and thus, its substantial equivalence) consisted of:
- Biocompatibility Testing: The device underwent and passed all selected FDA Blue Book Memorandum G95-1 and ISO 10993-1 testing. These are standard tests designed to assess the biological response to medical devices in contact with the body.
- Animal Study: The submission mentions "The results of an animal study" as contributing to the conclusion of safety and substantial equivalence to its predicates. No specific details about the animal model, study design, or outcomes are provided in this summary.
- In Vitro Product Characterization Studies: These studies would have evaluated the physical and chemical properties of the Collagen Nerve Wrap to ensure it meets its design specifications (e.g., hydration properties, porosity, resilience, degradation profile).
- Comparison to Predicate Devices: The core of the 510(k) submission is the comparison to legally marketed predicate devices (Collagen Nerve Cuff, NeuraWrap™ Nerve Protector, FASTUBE™ Nerve Regeneration Device). The Applicant states that Collagen Nerve Wrap and its predicates have the same technological characteristics, including intended use, design, materials, material characterization, form, and sizes. This forms the basis for the claim of "substantial equivalence."
Conclusion:
The Collagen Nerve Wrap received 510(k) clearance based on demonstrating substantial equivalence to existing predicate devices through an animal study, in vitro product characterization, and in vitro and in vivo biocompatibility testing, rather than through a clinical trial with predefined performance acceptance criteria typical for diagnostic or AI-driven medical devices.
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