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510(k) Data Aggregation
(52 days)
PanoGauze™ Non-Woven Hydrogel Dressing, like the CarraGauze™ Carrasyn™ Gel Wound Dressing Saturated Pad, is intended to provide a moist packing/healing environment which helps to prevent wound desiccation.
absorbent pads saturated with water based hydrogels packaged in sterile single-use poly/Mylar-laminate pouches.
Here's an analysis of the provided text based on your request:
Based on the provided document (K964620 Summary Basis of Substantial Equivalence for PanoGauze™ Non-Woven Hydrogel Dressing), it's important to clarify that this document describes a medical device (a hydrogel wound dressing), not a diagnostic AI/ML algorithm. Therefore, many of the questions regarding "AI," "ground truth," "experts," and "training sets" are not applicable.
The "acceptance criteria" in this context refer to the demonstrations of substantial equivalence to a predicate device and the safety characteristics of the device.
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria Category | Specific Criteria | Reported Device Performance (PanoGauze™) |
---|---|---|
Substantial Equivalence to Predicate | Design, composition, and function equivalent to CarraGauze™ Carrasyn™ Gel Wound Dressing Saturated Pad (K915001). | Stated to be substantially equivalent. Intended to provide a moist packing/healing environment and prevent wound desiccation, similar to the predicate. |
Safety - Systemic Toxicity | Meet USP requirements for systemic toxicity. | Met USP requirements. |
Safety - Cytotoxicity | Meet USP requirements for cytotoxicity. | Meets USP requirements. |
Safety - Primary Skin Irritation | Not considered a primary irritant to the skin per FHSA Regulations, 16 CFR 1500. | No irritation observed. |
Safety - Delayed Dermal Contact Sensitization | No evidence of causing delayed dermal contact sensitization. | Showed no evidence. |
Function - Moist Environment | Maintain a moist environment in the wound bed. | "maintains a moist environment in the wound bed" (stated in summary). |
Function - Microbial Contamination | Not introduce microbial contamination. | "does not introduce microbial contamination" (stated in summary). |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: The document does not specify a numerical sample size for the safety studies. It states "several studies were conducted by an independent testing laboratory." For toxicology and irritation tests, it typically involves a small number of animal subjects or cell cultures, but no specific numbers are given here.
- Data Provenance: The studies were conducted by an "independent testing laboratory." The country of origin is not specified but implicitly assumed to be within regulatory standards relevant to the US FDA (given the 510(k) submission). The studies are inherently "prospective" in the sense that they were conducted specifically to evaluate the PanoGauze™ device.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
- Not Applicable. This is a physical device, not an AI/ML diagnostic system requiring expert interpretation of outputs. "Ground truth" for safety studies is established by standardized laboratory assays and observation, not expert consensus.
4. Adjudication Method for the Test Set
- Not Applicable. As this is not an AI/ML diagnostic system, there is no need for adjudication of interpretations. The results of the laboratory tests are typically objective and quantitative (e.g., cell viability percentages, irritation scores).
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 not a diagnostic AI device.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) Was Done
- Not Applicable. This is not an AI algorithm.
7. The Type of Ground Truth Used
- For the safety studies, the "ground truth" was established based on standardized laboratory assay results against established biochemical, cellular, and physiological endpoints (e.g., USP requirements for toxicity, FHSA guidelines for irritation).
8. The Sample Size for the Training Set
- Not Applicable. This is not an AI/ML algorithm that requires a "training set."
9. How the Ground Truth for the Training Set Was Established
- Not Applicable. As above, no training set for an AI algorithm.
Summary of Device and Acceptance:
The PanoGauze™ Non-Woven Hydrogel Dressing gained acceptance (substantial equivalence) by demonstrating that it shares the same intended use, fundamental technological characteristics (hydrogel-saturated pad for moist wound healing), and safety profile (meeting USP and FHSA standards for toxicity, cytotoxicity, irritation, and sensitization) as its predicate device, the CarraGauze™ Carrasyn™ Gel Wound Dressing Saturated Pad. The "study" proving this involved a series of independent laboratory safety tests that yielded negative results for adverse effects, thereby establishing the device's safety and supporting its substantial equivalence claim.
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(94 days)
Carrasyn wound dressings are either smooth, nonoily clear hydrogels or freeze-dried preparations of the same. They are supplied in either a liquid or dry state and are designed to be used in conjunction with an appropriate cover dressing and are intended for the management of wounds.
Carrasyn wound dressings are either smooth, nonoily clear hydrogels or freeze-dried preparations of the same. They are supplied in either a liquid or dry state and are designed to be used in conjunction with an appropriate cover dressing and are intended for the management of wounds.
Here's an analysis of the provided text regarding the acceptance criteria and supporting studies for the CARRINGTO device (Carrasyn® Hydrogel Wound Dressing):
It's important to note that the provided text is a 510(k) Premarket Notification summary from 1998. This type of submission focuses on demonstrating substantial equivalence to a predicate device, rather than proving de novo safety and effectiveness through extensive clinical trials as would be required for a PMA (Premarket Approval) or for novel high-risk devices today. Therefore, the "studies" described are more akin to pilot or observational studies rather than rigorous, controlled clinical trials.
Acceptance Criteria and Reported Device Performance
The provided text does not explicitly state quantifiable acceptance criteria (e.g., "device must achieve 80% sensitivity for X condition" or "wound healing rate must be Y%"). Instead, it describes general findings regarding acceptability and effectiveness.
Acceptance Criteria (Inferred) | Reported Device Performance |
---|---|
Biocompatibility: Minimal irritation (dermal/ocular) | "Carrasyn® wound dressings are not primary dermal irritants or primary eye irritants." (Based on Primary Dermal Irritation testing and Primary Eye Irritation testing) |
Clinical Acceptability (Patient/Clinician): Well-received | "These studies evaluated the acceptability of Carrasyn® Hydrogel Wound Dressing to both the patients and clinicians..." (Implicitly, the conclusion of "safe and effective" suggests good acceptability.) |
Effect on Wound/Skin Appearance: Positive impact | "...to wound and skin appearance..." (Implicitly, the conclusion of "safe and effective" suggests a positive impact.) |
Effect on Wound Healing Environment: Favorable conditions | "...and to the wound healing environment." (Implicitly, the conclusion of "safe and effective" suggests a favorable impact.) |
Overall Safety and Effectiveness for Intended Use: | "These studies concluded that Carrasyn® wound dressings are safe and effective for their intended use." (This is the overarching conclusion, encompassing the above points for radiation dermatitis and diabetic ulcers.) |
Study Details
Given the context of a 1998 510(k) for a wound dressing, the "studies" mentioned are quite limited compared to modern standards for AI/medical device performance evaluation.
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Sample size used for the test set and the data provenance:
- Test Set Sample Size: 4 patients with radiation dermatitis and 30 patients with diabetic ulcers. (Total: 34 patients).
- Data Provenance: The text does not specify the country of origin. It describes "clinical experience to date" and "these studies," implying they were conducted by or for Carrington Laboratories. It refers to these as "two studies." Given the context, these are prospective observational studies or case series, not randomized controlled trials.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- The text does not specify the number of experts or their qualifications for establishing ground truth in clinical outcomes. It implies a clinical assessment was made, likely by the treating clinicians ("clinicians" are mentioned in evaluating acceptability).
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Adjudication method for the test set:
- Not specified. The text does not describe any formal adjudication process for clinical outcomes.
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If a multi-reader multi-case (MRMC) comparative effectiveness study was done:
- No. This type of study is entirely irrelevant for a hydrogel wound dressing undergoing a 510(k) submission in 1998. MRMC studies are typically for diagnostic imaging interpretation devices involving multiple readers.
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If a standalone (i.e. algorithm only without human-in-the loop performance) was done:
- No. This is a physical wound dressing, not an AI algorithm.
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The type of ground truth used:
- Clinical observation and assessment: For the clinical studies, the "ground truth" was based on clinical assessment of wound healing, skin appearance, wound environment, and patient/clinician acceptability over time by treating medical personnel. For the biocompatibility studies, the ground truth was based on the results of standardized animal model tests (e.g., observing for irritation).
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The sample size for the training set:
- Not applicable. This device is a physical hydrogel wound dressing, not an AI model requiring a training set. The "clinical experience" described is a small pilot/observational evaluation rather than a dataset to train an algorithm.
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How the ground truth for the training set was established:
- Not applicable. See point 7.
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(69 days)
Carrasyn™ wound dressings are either smooth, nonoily clear hydrogels or freeze-dried preparations of the same. They are supplied in either a liquid or dry state and are intended for the management of wounds.
Carrasyn™ wound dressings are either smooth, nonoily clear hydrogels or freeze-dried preparations of the same. They are supplied in either a liquid or dry state and are intended for the management of wounds.
The provided document describes the safety and effectiveness of Carrington's Carrasyn® wound dressings. It primarily focuses on demonstrating biocompatibility and some clinical observations. However, it does not include detailed acceptance criteria or a study designed to rigorously prove that the device meets specific performance metrics in the way that would typically be expected for a diagnostic or AI-based device's acceptance criteria.
The information provided is more akin to a 510(k) premarket notification summary for a medical device, which generally focuses on demonstrating substantial equivalence to a predicate device and outlining safety and efficacy through biocompatibility and some clinical experience.
Given this, I will interpret "acceptance criteria" as the overall goal of demonstrating safety and effectiveness as outlined in the summary, and "reported device performance" as the outcomes of the studies described.
Here's an analysis based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria (Interpreted) | Reported Device Performance |
---|---|
Safety: Device is not a primary dermal or eye irritant. | Biocompatibility Studies: |
- Primary Dermal Irritation testing: Demonstrated not to be a primary dermal irritant.
- Primary Eye Irritation testing: Demonstrated not to be a primary eye irritant. |
| Safety: Device does not cause adverse events. | Clinical Experience (Radiation Dermatitis & Diabetic Ulcers): No mention of adverse events.
Clinical Trial (Aphthous Ulcers - Carrington Patch™): - Randomized, double-blind study: No adverse events reported.
- Open-label study: No adverse events reported. |
| Effectiveness: Improves wound healing/manages wounds as intended. | Clinical Experience (Radiation Dermatitis & Diabetic Ulcers): Evaluated "acceptability... to clinicians, to wound and skin appearance, and to the wound healing environment." Concluded to be "safe and effective for their intended use." |
| Effectiveness: Reduces discomfort (specifically for aphthous ulcers). | Clinical Trial (Aphthous Ulcers - Carrington Patch™): - Randomized, double-blind study: Found to "reduce discomfort."
- Open-label study: Found to "significantly reduce discomfort within 2 minutes." |
2. Sample Size Used for the Test Set and Data Provenance
Due to the nature of the device (wound dressing, not AI/diagnostic), the concept of a "test set" in the context of an AI model doesn't directly apply. The document describes clinical studies that serve as evidence of safety and effectiveness.
- Clinical Experience (Radiation Dermatitis & Diabetic Ulcers):
- Sample Size: 4 patients with radiation dermatitis, 30 patients with diabetic ulcers.
- Data Provenance: Not specified, but generally implies a prospective clinical observation.
- The Carrington™ Patch - Randomized, Double-Blind Study (Aphthous Ulcers):
- Sample Size: 60 healthy volunteer patients (30 in treatment group, 30 in control group).
- Data Provenance: Not specified, but implies a prospective clinical trial.
- The Carrington™ Patch - Open-Label Study (Aphthous Ulcers):
- Sample Size: 30 healthy volunteer patients.
- Data Provenance: Not specified, but implies a prospective clinical trial.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of Experts
- Biocompatibility Studies: These were laboratory tests conforming to GLP regulations using animal models. The "ground truth" (i.e., irritation levels) would be established by trained technicians/toxicologists following standard protocols. Specific numbers or qualifications are not provided but are inherent in GLP compliance.
- Clinical Experience (Radiation Dermatitis & Diabetic Ulcers): "Clinicians" were involved in evaluating acceptability and wound healing. The number and specific qualifications (e.g., dermatologists, wound care specialists) are not specified.
- Clinical Trials (Aphthous Ulcers): Patients themselves provided input on discomfort via diaries and adverse event reports. Clinicians would have conducted assessments but their number and specific qualifications are not detailed.
4. Adjudication Method for the Test Set
- Biocompatibility Studies: Not applicable in the sense of expert adjudication. Results were objectively measured based on irritation scores.
- Clinical Experience (Radiation Dermatitis & Diabetic Ulcers): Adjudication method not described. It appears to be clinician observation without a formal multi-reader adjudication process.
- Clinical Trials (Aphthous Ulcers): Patient diaries and adverse event reports were primary data sources. Clinicians would have overseen the study, but a specific adjudication method for their observations is not detailed. The randomized double-blind nature of one study partially addresses bias for the discomfort assessment.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done
No, an MRMC comparative effectiveness study was not done. The document does not describe human readers interpreting images or data with and without AI assistance. This device is a wound dressing, not an AI diagnostic tool.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done
Not applicable. The device is a physical wound dressing, not an algorithm.
7. The Type of Ground Truth Used
- Biocompatibility Studies: Objective measurements of dermal and ocular irritation in animal models.
- Clinical Experience (Radiation Dermatitis & Diabetic Ulcers): Clinician observations and assessments of wound/skin appearance and healing environment. Patient acceptability. This is a form of expert clinical assessment.
- Clinical Trials (Aphthous Ulcers):
- Discomfort: Patient-reported outcome (via diary), which is a subjective but direct measure of a patient's experience.
- Adverse Events: Patient-reported and clinically observed events.
8. The Sample Size for the Training Set
Not applicable. As this is not an AI/ML device, there is no "training set" in the conventional sense. The "training" for the device's formulation likely involved laboratory research and development, but not data-driven machine learning.
9. How the Ground Truth for the Training Set was Established
Not applicable, as there is no training set for an AI/ML model for this device. The development process for the dressing would have involved standard chemical and material science techniques, preclinical testing, and potentially iterative formulation based on performance in those settings.
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