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510(k) Data Aggregation
(56 days)
Massachusetts 02453
Re: K250499
Trade/Device Name: RELiZORB (100300/100301)
Regulation Number: 21 CFR 876.5985
RELiZORB (100300/100301) |
| Device Common Name | Enzyme Packed Cartridge |
| Regulation Number | 21 CFR 876.5985
k) Number | K243284 |
| Device Common Name | Enzyme Packed Cartridge |
| Regulation Number | 21 CFR 876.5985
There is no effect on the special controls applied to this product per 21 CFR 876.5985 or any of the
RELiZORB is indicated for use in pediatric (including neonates and infants) and adult patients to hydrolyze fats during enteral feeding.
RELiZORB® is a point-of-care device designed to fit in-line with currently used enteral feeding circuits. RELiZORB functions to hydrolyze (break down) fats present in formulas from triglycerides into fatty acids and monoglycerides to allow for their absorption and utilization by the body. Formulas are liquid food products that are specially formulated and designed to increase the amount of various food elements and nutrients that will maintain proper physiological function of the body. The breakdown of fats by RELiZORB is intended to mimic the function of the enzyme pancreatic lipase. RELiZORB is comprised of a cylindrical, hollow cartridge with a single inlet port and a single outlet port connection. Inside the cartridge, there are small white beads. The digestive enzyme, lipase, is covalently bound to the small white beads. The lipase-bead complex, iLipase® (immobilized lipase), is retained within the cartridge during use by filters on both ends of the cartridge. The fat in formulas is hydrolyzed when it encounters iLipase as the formula passes through the cartridge.
The provided FDA 510(k) clearance letter describes a device called RELiZORB, an enzyme packed cartridge designed to hydrolyze fats in enteral feeding formulas. The clearance is for an updated indication for use to include neonates and infants.
The document does not contain acceptance criteria in the traditional sense of specific performance metrics (e.g., accuracy, sensitivity, specificity, or fat hydrolysis rate thresholds) that the device must meet, nor does it provide a study that explicitly demonstrates the device's performance against such criteria.
Instead, the submission focuses on demonstrating substantial equivalence to a previously cleared predicate device (K243284) and expanding the indications for use based on Real-World Evidence (RWE) and functional performance testing with infant formulas.
Here's an breakdown of the information provided, categorized according to your request, with a clear statement where information is not present in the document.
Analysis of Acceptance Criteria and Device Performance Study for RELiZORB (K250499)
The 510(k) clearance for RELiZORB (K250499) primarily addresses an expansion of its Indications for Use to include neonates and infants, building upon its previous clearance (K243284). The submission aims to demonstrate that this expanded use introduces no new questions of safety or effectiveness and maintains substantial equivalence to the predicate device.
Crucially, the provided document does not detail specific quantitative acceptance criteria (e.g., specific thresholds for fat hydrolysis rates) that RELiZORB had to meet for this clearance, nor does it present a formal clinical study with performance outcomes against such criteria. The evidence presented is largely qualitative and focused on the safety and functional compatibility of the device with infant formulas and its historical safety profile in a real-world setting.
1. Table of Acceptance Criteria and Reported Device Performance
As stated above, the document does not provide a table of acceptance criteria with corresponding device performance metrics in the manner of a typical analytical or clinical performance study for a diagnostic or AI device. The "performance" discussed is related to "functional performance... compatible with commercially available infant formulas" and a review of post-market surveillance data for safety. No quantitative outcomes (e.g., specific fat hydrolysis percentages) are reported as acceptance criteria or performance metrics in this document.
2. Sample Size Used for the Test Set and Data Provenance
- Test Set (Real-World Data):
- Sample Size: "multiple data outputs in Medical Records for patients initiating RELiZORB use between ages
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(90 days)
200 Waltham, Massachusetts 02453
Re: K243284
Trade/Device Name: RELiZORB Regulation Number: 21 CFR 876.5985
Packed Cartridge |
| Regulation Number | 21 CFR 876.5985
Device Common Name | Enzyme Packed Cartridge |
| Regulation Number | 21 CFR 876.5985
There is no effect on the special controls applied to this product per 21 CFR 876.5985 or any of the
RELiZORB is indicated for use in pediatric (ages 1 year and above) and adults patients to hydrolyze fats in enteral formula.
RELiZORB® is a point-of-care device designed to fit in-line with currently used enteral feeding circuits. RELiZORB functions to hydrolyze (break down) fats present in enteral formulas from triglycerides into fatty acids and monoglycerides to allow for their absorption and utilization by the body. This breakdown of fats by RELiZORB is intended to mimic the function of the enzyme pancreatic lipase. RELiZORB is comprised of a cylindrical, hollow cartridge with a single inlet port and a single outlet port connection. Inside the cartridge, there are small white acrylic beads. The digestive enzyme, lipase, is covalently bound to the small white beads. The lipase-bead complex, iLipase® (immobilized lipase), is retained within the cartridge during use by filters on both ends of the cartridge. The fat in enteral formulas is hydrolyzed when it comes in contact with iLipase as the formula passes through the cartridge.
The provided text is a 510(k) summary for the RELiZORB device. It details various aspects of the device, its intended use, and substantial equivalence to a predicate device. However, it does not contain a typical acceptance criteria table with reported device performance metrics in the format usually associated with diagnostic device evaluation (e.g., sensitivity, specificity, accuracy).
Instead, the submission focuses on extending the Indications for Use for the RELiZORB device to include pediatric patients aged 1 year and above, compared to the previous indication of 2 years and above. The "acceptance criteria" in this context are primarily related to demonstrating that this change in indication does not introduce new safety or effectiveness concerns, and that the device remains substantially equivalent to the predicate.
Here's an analysis of the "acceptance criteria" and the study that supports the change, based on the provided text:
1. A table of acceptance criteria and the reported device performance
The document does not present a formal table of acceptance criteria with specific performance metrics (like sensitivity, specificity, or AUC) as one might expect for a diagnostic AI/ML device. Instead, the acceptance criteria for extending the age indication are implicitly:
- Safety: The device is safe for use in pediatric patients aged 1 to
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(101 days)
200 Waltham, Massachusetts 02453
Re: K232784
Trade/Device Name: RELiZORB® Regulation Number: 21 CFR 876.5985
Device Common Name | Enzyme Packed Cartridge |
| Regulation Number | 21 CFR 876.5985
Device Common Name | Enzyme Packed Cartridge |
| Regulation Number | 21 CFR 876.5985
enteral nutrition.
Special Controls
RELiZORB is subject to special controls detailed under 21 CFR 876.5985
RELiZORB® is indicated for use with pediatric (ages 2 years and above) and adult patients to hydrolyze fats in enteral formula.
RELiZORB® is a single-use, point-of-care digestive enzyme cartridge that connects in-line with existing enteral feeding circuits. RELiZORB is designed to hydrolyze (digest) fats contained in enteral formulas from triglycerides into fatty acids and monoglycerides to allow for their absorption and utilization by the body. This hydrolysis of fats by RELiZORB is intended to mimic the function of the digestive enzyme lipase in patients. RELiZORB is comprised of a clear cylindrical, plastic cartridge with a single inlet connection port and a single outlet connection port. Inside the cartridge, there are small white beads covalently bonded to the digestive enzyme, lipase. This lipase-bead complex, iLipase™ (immobilized lipase) is retained within the cartridge during use by filters on both ends of the cartridge. The fat in enteral formulas is hydrolyzed upon contact with iLipase as the formula passes through the cartridge.
This document is a 510(k) summary for the RELiZORB® device, which is an enzyme-packed cartridge used to hydrolyze fats in enteral formula. It is a submission to the FDA seeking clearance for a modified version of an already cleared device.
The provided text focuses on demonstrating the substantial equivalence of the subject device (RELiZORB® K232784) to its predicate device (RELiZORB® K231156). It does not contain information about the acceptance criteria and study proving performance for an AI/Software as a Medical Device (SaMD).
Specifically, the document does not contain the following information typically found in acceptance criteria and study designs for AI/SaMD devices:
- A table of acceptance criteria and reported device performance (for an AI/SaMD)
- Sample sizes used for a test set (as would be used for an AI/SaMD model's performance evaluation)
- Data provenance for a test set
- Number of experts and qualifications for ground truth establishment
- Adjudication method for a test set
- MRMC comparative effectiveness study details
- Standalone (algorithm-only) performance results
- Type of ground truth used (e.g., pathology, outcomes data)
- Sample size for the training set (for an AI/ML model)
- How ground truth for the training set was established
Instead, the document details performance testing related to the physical and chemical characteristics of the RELiZORB® cartridge, which is a hardware medical device with an enzymatic function.
Here's a breakdown of the performance testing cited for this hardware device, which is different from "acceptance criteria" for an AI/SaMD:
Overview of Performance Testing for RELiZORB® (Hardware Device):
The performance testing listed is geared towards a physical device with a biological function (enzyme action). The "acceptance criteria" for this device would therefore relate to its physical integrity, chemical activity, and biocompatibility, rather than diagnostic accuracy or algorithmic performance.
1. Table of "Acceptance Criteria" (Inferred from Performance Testing) and Reported Device Performance:
The document lists categories of testing rather than specific numerical acceptance criteria or detailed results. However, we can infer some "acceptance criteria" that would be met by these tests:
Acceptance Criteria Category (Inferred) | Specific Tests Performed (from text) | Reported Device Performance (General Statement) |
---|---|---|
Biocompatibility | Biocompatibility testing (Sections 15, 19) | Device causes neither an adverse tissue response nor adverse performance. |
Device Integrity/Durability | Internal and external appearance, Pouch integrity, Physical/Mechanical Testing (Filter tensile strength, Weld tensile strength, Filter integrity/bead retention), Ship testing | Demonstrated to withstand clinical forces, maintain integrity, and retain beads. |
Enzymatic Function | Hydrolysis, Demonstration of enzymatic effect on intended macronutrient | Hydrolyzes fats in enteral formula from triglycerides into fatty acids and monoglycerides. |
Enzyme Retention | Unconjugated protein, Amount of enzyme that exits the cartridge (Section 10) | Enzyme is retained within the cartridge during use by filters; amount exiting the cartridge is characterized. |
Flow Dynamics | Flow rate and leakage testing, Validation that the device does not impede flow alarms on enteral feeding pumps (Sections 18 & 14) | Does not impede the flow of enteral formula or flow alarms on enteral feeding pumps. |
Nutritional Impact | Validation that the device does not adversely impact the nutritional composition of enteral formula (Section 18) | Does not adversely impact the nutritional composition. |
Shelf Life | Evaluation of product shelf life, Performance data to support shelf life by demonstrating package integrity and device functionality over the identified shelf life (Section 14) | Functionality and integrity maintained over identified shelf life. |
Safety in Use | Human factors testing (Section 10), Preclinical Studies in porcine model | Risks characterized; safety and efficacy assessed, including impact on fat absorption and weaning from parenteral to enteral nutrition. |
Labeling Requirements | Labeling (Section 13) | Labeling includes required summaries, instructions, warnings, and patient information. |
2. Sample size used for the test set and the data provenance:
- Test Set Sample Size: Not applicable in the context of an AI/ML test set. For physical and chemical tests, typically specific numbers of units are tested according to standard protocols (e.g., n=3, n=5, n=10 per batch), but these specific numbers are not provided in the summary.
- Data Provenance: The preclinical studies were conducted in a porcine model. The document does not specify the country of origin for the studies, nor whether they were retrospective or prospective, though preclinical animal studies are typically prospective.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable as this is not an AI/ML diagnostic device requiring human expert ground truth for interpretation of imaging or other complex data. The "ground truth" for this device's performance would be the scientific measurement of its physical properties and chemical activity (e.g., fat hydrolysis percentage).
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- Not applicable. Adjudication methods are relevant for human interpretation or consensus in diagnostic studies, not for the performance testing of a physical medical device.
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. This is not an AI-assisted diagnostic device, so an MRMC study is not relevant or performed.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- No. This is a physical device, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- For this device, the "ground truth" for its performance is established through standard laboratory testing for:
- Chemical Analysis: Measuring the hydrolysis of fats (e.g., quantifying fatty acids and monoglycerides produced).
- Physical Measurements: Tensile strength, flow rates, bead retention, appearance.
- Biological Testing: Biocompatibility tests (e.g., cytotoxicity, sensitization), and in vivo animal studies (porcine model) to assess safety and efficacy (fat absorption, impact on parenteral nutrition weaning).
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.
In summary: The provided text details the regulatory clearance process for a physical medical device (enzyme-packed cartridge), not an AI/Software as a Medical Device (SaMD). Therefore, the criteria and study types described in the prompt (which are typical for AI/SaMD) are not present in this document. The "performance data" here refers to standard engineering, chemical, and biological testing of a hardware product.
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(128 days)
02453
Re: K231156
Trade/Device Name: Enzyme Packed Cartridge - RELiZORB® Regulation Number: 21 CFR 876.5985
Cartridge |
| Regulation Number | 21 CFR 876.5985
Device Common / Regulation Name | Enzyme Packed Cartridge |
| Regulation Number | 21 CFR 876.5985
There is no effect on the special controls applied to this product per 21 CFR 876.5985 or any of the
RELiZORB® is indicated for use with pediatric (ages 2 years and above) and adult patients to hydrolyze fats in enteral formula.
RELiZORB® is a single-use, point-of-care digestive enzyme cartridge that connects in-line with existing enteral feeding circuits. RELiZORB® is designed to hydrolyze (digest) fats contained in enteral formulas from triglycerides into fatty acids and monoglycerides to allow for their absorption and utilization by the body. This hydrolysis of fats by RELiZORB® is intended to mimic the function of the digestive enzyme lipase in patients who do not excretesufficient levels of the lipase enzyme. RELiZORB® is comprised of a clear cylindrical, plastic cartridge with a single inlet connection port and a single outlet connection port. Inside the cartridge, there are small white beads that the digestive enzyme, lipase, is covalently bound to. The lipase-bead complex, iLipase™ (immobilized lipase) is retained within the cartridge during use by filters on both ends of the cartridge. The fat in enteral formulas is hydrolyzed as it comes in contact with iLipase as the formula passes through the cartridge.
The provided text describes a 510(k) premarket notification for the RELiZORB® enzyme packed cartridge. This submission is primarily focused on updating the indications for use to include pediatric patients aged 2 years and above, extending from the previous clearance for 5 years and above. The core device (RELiZORB®) itself has not changed technologically since its previous clearance (K191379).
Here's an analysis of the acceptance criteria and the study that proves the device meets those criteria, based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly present a table of quantitative acceptance criteria for device performance. Instead, it states that the technological characteristics, design, materials composition, principal of operation, and all other features of RELiZORB® have not changed since the clearance of K191379. Therefore, the device performance is assumed to be consistent with the performance demonstrated for the predicate device.
The primary "acceptance criterion" addressed in this specific submission is the safety and effectiveness of the device for a younger pediatric population (2-5 years old). The device's performance in terms of fat hydrolysis would be the same as previously established.
Regarding the expanded indication for use:
Acceptance Criterion (Implicit) | Reported Device Performance |
---|---|
Safety and effectiveness for pediatric patients aged 2-5 years | "This Real World Data supports the Real World Evidence that use in this use population is both safe and effective." (Based on a retrospective registry study evaluating multiple data outputs in Electronic Medical Records (EMRs) for patients in this age group who had been prescribed RELiZORB®). |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size for Test Set: The document states that the retrospective registry study "evaluated multiple data outputs in Electronic Medical Records (EMRs) for patients between ages 2 year and 5 years to whom RELiZORB® had been prescribed to them." However, the exact sample size (number of patients) used in this retrospective study is not specified.
- Data Provenance: The data is described as "Real World Data" from "Electronic Medical Records (EMRs)". The specific country of origin is not mentioned, but given the FDA submission, it's highly likely to be U.S. data. The study is explicitly described as retrospective.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
The document does not describe the use of experts to establish ground truth for this particular retrospective registry study. The study appears to rely on clinical outcomes and data from Electronic Medical Records, implying that the "ground truth" concerning safety and effectiveness in the 2-5 year old population was derived from the real-world clinical experience and documentation within those EMRs.
4. Adjudication Method for the Test Set
No adjudication method is described. The retrospective EMR data analysis would likely involve data extraction and analysis by the submitting company, Alcresta Therapeutics, Inc.
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 section is not applicable as the device is an enzyme packed cartridge, not an AI or imaging diagnostic device that involves human readers or an AI assistance component.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
This section is not applicable. The RELiZORB® is a physical device that performs a chemical function (fat hydrolysis), not an algorithm.
7. The Type of Ground Truth Used
The ground truth for the expanded indication of use (safety and effectiveness in 2-5 year olds) was established through Real World Evidence (RWE) derived from Real World Data (RWD), specifically "multiple data outputs in Electronic Medical Records (EMRs)" reflecting actual clinical outcomes and experiences of patients who had already used the device.
8. The Sample Size for the Training Set
There is no mention of a "training set" in the context of this submission. The device itself (enzyme cartridge) is not a machine learning model that requires a training set. The retrospective registry study is analyzing existing real-world data to support an expanded indication for use, not to train a device or algorithm.
9. How the Ground Truth for the Training Set Was Established
This section is not applicable as there is no training set for the device itself or a machine learning component.
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(195 days)
Park, Suite 100 Newton, MA 02462
K191379 Re:
Trade/Device Name: RELiZORB Regulation Number: 21 CFR 876.5985
|
| Subject device
classification | 21 CFR 876.5985
|
| Predicate device
classification | 21 CFR 876.5985
RELiZORB™ is indicated for use with pediatric (ages 5 years and above) and adult patients to hydrolyze fats in enteral formula.
RELiZORB is a single-use, point-of-care digestive enzyme cartridge that connects in-line with existing enteral feeding circuits. RELiZORB is designed to hydrolyze (digest) fats contained in enteral formulas from triglycerides into fatty acids and monoglycerides to allow for their absorption and utilization by the body. This hydrolysis of fats by RELiZORB is intended to mimic the function of the digestive enzyme lipase in patients who do not excr ete sufficient levels of the lipase enzyme. RELiZORB is comprised of a clear cylindrical, plastic cartridge with a single inlet connection port and a single outlet connection port. Inside the cartridge, there are small white beads. The digestive enzyme, lipase, is covalently bound to the small white beads. The lipasebead complex, iLipase™ (immobilized lipase), is retained within the cartridge during use by filters on both ends of the cartridge. The fat in enteral formulas is hydrolyzed as it comes in contact with iLipase as the formula passes through the cartridge.
Here's a breakdown of the acceptance criteria and study information for the RELiZORB device, based on the provided document:
1. Table of Acceptance Criteria and Reported Device Performance
The document doesn't explicitly state "acceptance criteria" with numerical targets for each performance metric for the subject device (K191379), but rather implies equivalence to a predicate device. The performance data listed are the types of tests conducted to demonstrate this equivalence. The "Reported Device Performance" for the subject device is simply that it met the equivalence requirements for these tests. The predicate device's performance would have established the original acceptance criteria.
Performance Metric | Implied Acceptance Criteria (via Predicate Equivalence) | Reported Device Performance (Subject Device) |
---|---|---|
Pouch seal/tensile/visual testing | Met predicate specifications | Demonstrated equivalence |
Primary pouch ship testing (ISTA 2A) | Met predicate specifications | Demonstrated equivalence |
Filter integrity performance | Met predicate specifications | Demonstrated equivalence |
Hydrolysis | Functionally equivalent to predicate | Demonstrated equivalence |
Flow rate | Functionally equivalent to predicate | Demonstrated equivalence |
Leak testing | Met predicate specifications | Demonstrated equivalence |
2. Sample Size Used for the Test Set and Data Provenance
The document does not specify a distinct "test set" sample size or data provenance (e.g., country of origin, retrospective/prospective) for a clinical study. The performance data focuses on non-clinical testing of the device itself (e.g., integrity, flow, hydrolysis), rather than clinical outcomes with human subjects.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
Not applicable. This device is an enzyme-packed cartridge for hydrolyzing fats in enteral formula. The "ground truth" would be objective measurements of its physical and chemical properties and its ability to break down fats, not a diagnostic interpretation by human experts.
4. Adjudication Method for the Test Set
Not applicable, as no human expert adjudication is involved in the technical performance testing described.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. The document describes non-clinical performance testing for a device that acts on enteral formula. It focuses on the device's functional equivalence to a predicate, not on human reader performance with or without AI assistance.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
Yes, in a way. The testing described is "standalone" in the sense that it evaluates the device's performance (hydrolysis, flow rate, integrity) directly, without human interaction during the measurement process. However, this is not an "algorithm-only" performance as the device is a physical product, not a software algorithm.
7. The Type of Ground Truth Used
The ground truth used is primarily based on objective physical and chemical measurements of the device's performance, such as:
- Measurement of seal strength, tensile strength, visual inspection results for pouch testing.
- Results from standardized shipping tests (ISTA 2A).
- Quantitative measurements of filter integrity.
- Biochemical assays to measure the extent of fat hydrolysis.
- Measurements of fluid flow rate through the cartridge.
- Leak detection methods.
These measurements are compared against established specifications for the predicate device to demonstrate equivalence.
8. The Sample Size for the Training Set
Not applicable. This device is a physical product, not an AI/ML algorithm that requires a "training set." The development would involve engineering and materials science, not machine learning training.
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there is no "training set" for this type of device.
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(253 days)
Park, Suite 100 Newton, MA 02462
Re: K163057 Trade/Device Name: RELiZORB Regulation Number: 21 CFR§ 876.5985
| | | |
| Subject device
classification | 21 CFR 876.5985
| | | |
| Predicate device
classification | 21 CFR 876.5985
RELiZORB™ is indicated for use in pediatric patients (ages 5 years and above) and adult patients to hydrolyze fats in enteral formula.
RELiZORB is a single-use, point-of-care digestive enzyme cartridge that connects in-line with existing enteral feeding circuits. RELiZORB is designed to hydrolyze (digest) fats contained in enteral formulas from triglycerides into fatty acids and monoglycerides to allow for their absorption and utilization by the body. This hydrolysis of fats by RELiZORB is intended to mimic the function of the digestive enzyme lipase in patients who do not excr ete sufficient levels of the lipase enzyme. RELiZORB is comprised of a clear cylindrical, plastic cartridge with a single inlet connection port and a single outlet connection port. Inside the cartridge, there are small white beads. The digestive enzyme, lipase, is covalently bound to the small white beads. The lipase-bead complex, iLipaseTM (immobilized lipase), is retained within the cartridge during use by filters on both ends of the cartridge. The fat in enteral formulas is hydrolyzed as it comes in contact with iLipase as the formula passes through the cartridge.
This document is a 510(k) summary for the RELiZORB™ device, submitted by Alcresta Therapeutics, Inc. The purpose of the submission is to expand the indications for use to include pediatric patients (ages 5 years and above) and to update the shelf life. The device, an enzyme-packed cartridge, is designed to hydrolyze fats in enteral formulas.
Here's an analysis of the requested information based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly state "acceptance criteria" in a quantitative format for the clinical study. However, it describes the outcomes and findings from the clinical study that supported the expanded indication. For shelf life, it generally states "Shelf life test results support labeled shelf life of RELiZORB," implying that the performance met internal criteria.
Acceptance Criteria (Inferred from study outcomes) | Reported Device Performance |
---|---|
Safety and Tolerability (evaluated through GI symptoms and adverse events) in pediatric and adult patients with CF | The most commonly reported GI events were abdominal pain, gas and bloating, while the most common non-gastrointestinal adverse event reported was headache. The implication is that these were acceptable given the patient population and the overall context of the study. |
Efficacy in fat absorption (measured by plasma concentrations of LCPUFAs like DHA and EPA) in pediatric and adult patients with CF | RELiZORB use resulted in a 2.8-fold change in plasma concentrations of physiologically relevant long-chain polyunsaturated fatty acids (LCPUFAs) such as DHA and EPA, as measured by plasma absorption kinetics and bioavailability profile (Area Under the Curve - AUC). |
Additionally, there was a 2.1-fold change in peak plasma concentrations (Cmax) of DHA and EPA. These results confirmed previous findings in a porcine model. | |
Shelf Life (tensile, mechanical strength, flow rate, hydrolysis, microbiological testing) | "Shelf life test results support labeled shelf life of RELiZORB." (Specific numerical acceptance criteria and performance values are not provided in this summary). |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size for Test Set (Clinical Study): 33 evaluable patients completed the study (from an initial enrollment of 35 patients; 2 withdrew before exposure).
- Data Provenance: The study was a "multicenter, randomized, double-blind, placebo-controlled crossover clinical study in adult and pediatric patients with cystic fibrosis (CF)." While the specific country of origin is not explicitly stated, "multicenter" implies multiple sites, likely within the United States given the FDA submission. The study design is prospective.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
This type of information is not applicable to this device and study. The RELiZORB device is an enzyme-packed cartridge; its "ground truth" for performance is based on biochemical hydrolysis of fats and physiological absorption, not subjective expert interpretation of images or other data that require inter-rater agreement. The "ground truth" for efficacy was established through objective biochemical markers (LCPUFAs in plasma).
4. Adjudication Method for the Test Set
This is not applicable as the outcome measures (LCPUFA concentrations, adverse events) are objective and do not require adjudication by experts in the way clinical images or diagnoses might.
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. The RELiZORB is a medical device (enzyme-packed cartridge), not an AI-powered diagnostic or assistive technology for human readers.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
This is not applicable. The RELiZORB is a physical device, not an algorithm. Its performance is inherent to its enzymatic activity.
7. The Type of Ground Truth Used
For the clinical study, the ground truth for device efficacy was established using outcome data:
- Plasma absorption kinetics and bioavailability profile (Area Under the Concentration Time Curve - AUC) of physiologically relevant long-chain polyunsaturated fatty acids (LCPUFAs) like DHA and EPA.
- Peak plasma concentrations (Cmax) of DHA and EPA.
- Gastrointestinal (GI) symptoms and non-GI adverse events for safety and tolerability.
8. The Sample Size for the Training Set
This is not applicable to the RELiZORB device. The device is not learning or being trained in a computational sense. Its design and enzymatic function are pre-defined.
9. How the Ground Truth for the Training Set Was Established
This is not applicable for the same reasons as #8.
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(58 days)
Suite 102 Newton, MA 02462
Re: K161247
Trade/Device Name: RELiZORB™ Regulation Number: 21 CFR §876.5985
|
| Subject device
classification | 21 CFR 876.5985
|
| Predicate device
classification | 21 CFR 876.5985
RELiZORB™ is indicated for use in adults to hydrolyze fats in enteral formula
The RELiZORB device is a point-of-care accessory designed to fit in line with currently used enteral feeding circuits. RELiZORB is designed to hydrolyze (break down) fats present in enteral formulas from triglycerides into fatty acids and monoglycerides to allow for their absorption and utilization by the body. This breakdown of fats by the RELiZORB is intended to mimic the function of the enzyme lipase in patients who do not excr ete sufficient levels of pancreatic lipase. RELiZORB is comprised of a cylindrical, hollow cartridge with a single inlet port and a single outlet port connection. Inside the cartridge, there are small white beads. The digestive enzyme, lipase, is covalently bound to the small white beads. The lipase-bead complex, iLipaseTM (immobilized lipase), is retained within the cartridge during use by filters on both ends of the cartridge. The fat in enteral formulas is hydrolyzed as it comes in contact with iLipase as the formula passes through the cartridge.
This document describes a 510(k) premarket notification for the RELiZORB™ device, an enzyme-packed cartridge designed to hydrolyze fats in enteral formula. The submission aims to demonstrate substantial equivalence to a previously cleared RELiZORB™ device (DEN150001).
Since this is a submission for an enzyme-packed cartridge and not a diagnostic AI/ML device, the detailed questions about acceptance criteria, test sets, ground truth establishment, expert adjudication, and comparative effectiveness studies as typically applied to AI/ML software are not directly applicable in the same manner. This submission focuses on the chemical and mechanical performance of the device rather than the diagnostic accuracy of an algorithm.
However, I can extract the relevant performance data and criteria mentioned in the document in the spirit of your request:
1. Table of acceptance criteria and the reported device performance:
Acceptance Criteria Category | Specific Criteria (Implicitly Met) | Reported Device Performance |
---|---|---|
Shelf Life | Product stability over time, retaining intended function. | "Shelf life testing of RELIZORB was completed and met the acceptance criteria in the protocol. The shelf life test results support the proposed edit to the labeling with respect to product stability." |
Device Performance | Device performs as intended under anticipated conditions of use. | "The RELIZORB device was previously tested to demonstrate that the device performs as intended under anticipated conditions of use, and safety, including: Tensile and mechanical strength, Flow rate, Demonstration of enzymatic effect on macronutrients, Impurities/degradants characterization, Animal testing to demonstrate hydrolysis effect, Human factors testing." (These tests were deemed sufficient for the predicate device and are implicitly accepted for the current device due to no changes in design, technology, or functionality). |
Safety | No significant changes to risk assessment due to proposed minor labeling change. | "The Risk management file was reviewed and there was no significant change to the risk assessment as a result of the proposed minor change to the labeling." |
Quality System Compliance | Compliance with medical device quality system regulations. | "Alcresta develops and manufactures RELIZORB in compliance with the Quality System regulations (21 CFR 820)." |
Biocompatibility | Biological safety of materials in contact with the body/formula. | Referenced standard: ISO 10993-1:2009/Cor 1:2010 Biological evaluation of medical devices. (Implicitly met through prior testing of predicate). |
Usability/Human Factors | Device is safe and effective for users. | Referenced standard: EN 62366:2008 Medical devices - Application of usability engineering. (Implicitly met through prior testing of predicate). |
Risk Management | Application of risk management processes. | Referenced standard: EN ISO 14971:2012 Medical devices. Application of risk management. (Implicitly met through prior testing of predicate and current review). |
Packaging/Shipping | Device integrity maintained during transport. | Referenced standard: ISTA 2A: Packaged-Products weighing 150 lb (68 kg) or Less. Basic Requirements: atmospheric conditioning, compression, fixed displacement or random vibration and shock testing. (Implicitly met through prior testing of predicate). |
Connectors/Adapters | Compatibility and safety of enteral feeding set adapters and connectors. | Referenced standard: AAMI/ANSI ID54: 1996/(R)2012: Enteral feeding set adapters and connectors. (Implicitly met through prior testing of predicate). |
Controlled Environments | Manufacturing in appropriate environments. | Referenced standard: ISO-14644: Cleanrooms and associated controlled environments. (Implicitly met through prior manufacturing of predicate). |
2. Sample size used for the test set and the data provenance:
- Test set sample size: Not explicitly stated for each specific performance test (tensile, flow rate, enzymatic effect, etc.). The document mentions "shelf life testing" was completed, but not the number of units or replicates. For prior testing of the predicate device, it indicates a range of tests were performed, but no numbers of devices tested are provided.
- Data provenance: Not explicitly stated (e.g., country of origin). The testing seems to have been conducted by or for Alcresta Therapeutics, Inc. (Newton, MA, USA). The studies appear to be prospective as they involve testing the device under various conditions.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable in the typical sense for this device. This device is not a diagnostic tool requiring expert interpretation of results for ground truth. The "ground truth" for this device would be established by objective measurements of its physical properties (tensile strength, flow rate) and chemical activity (enzymatic effect on macronutrients), likely performed by laboratory technicians or engineers following validated protocols, rather than expert interpretation of a diagnostic outcome.
4. Adjudication method for the test set:
- Not applicable. Adjudication methods like 2+1 or 3+1 are used to reconcile disagreements among human readers in diagnostic studies. For this device, performance is evaluated against objective, measurable criteria and laboratory standards.
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 an AI/ML diagnostic device and does not involve human readers interpreting cases with or without AI assistance.
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:
- For the enzymatic effect: Objective chemical measurements (e.g., measuring the breakdown of triglycerides into fatty acids and monoglycerides).
- For mechanical/physical properties: Engineering measurements against established standards (e.g., tensile strength, flow rate).
- For biocompatibility: Laboratory testing results compared to biological safety standards.
8. The sample size for the training set:
- Not applicable. This device does not use an algorithm that requires a training set.
9. How the ground truth for the training set was established:
- Not applicable. As there is no training set for an algorithm, there is no ground truth to be established for it.
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(322 days)
NEW REGULATION NUMBER: 21 CFR 876.5985
CLASSIFICATION: II
PRODUCT CODE: PLQ
BACKGROUND
DEVICE
the following:
Product Code: PLQ Device Type: Enzyme Packed Cartridge Class: II Regulation: 21 CFR 876.5985
RELIZORB™ is indicated for use in adults to hydrolyze fats in enteral formula.
The RELIZORB™ device is a point-of-care accessory designed to fit in series with currently used enteral feeding circuits. During the submission process, the device was also known as the Enteral Feeding In-Line Cartridge (EFIC). Therefore, the subject device may be referred to as EFIC in some figures within this document. RELIZORB™ is designed to hydrolyze (break down) fats present in enteral formulas from triglycerides into fatty acids and monoglycerides to allow for their absorption and utilization by the body. This breakdown of fats by the RELIZORB™ is intended to mimic the function of the enzyme lipase in patients who do not excrete sufficient levels of pancreatic lipase. The subject device is shown below in Figure 1. The RELIZORB™ is comprised of a cylindrical, hollow port and a single outlet port connection.
RELIZORB™ is packed with polymeric beads that have lipase enzyme immobilized on the surface. This lipase enzyme is Generally Regarded as Safe (GRAS). The chemical action of the lipase enzyme is shown in Figure 2, where triglyceride molecules are broken into constituent monoglycerides and fatty acids. The food contacting substance (FCS) of (b) (4) beads manufactured using the RELIZORBTM are (b) (4). The lipase enzyme is chemically bound to the FCS and is intended to remain within the cartridge.
RELIZORB™ is an intermediary between an enteral feeding source (infusion pump) and an implanted feeding tube, as shown in Figure 3. The distal end of compatible infusion pump administration sets (Figure 3A) should have a stepped connector (Christmas tree). This connector plugs into the proximal end of the RELIZORB™ device (Figure 3B). The distal end of the RELIZORB™ (Figure 3C) connects to the enteral funnel of an extension set (Figure 3D). This extension set connects to an enteral feeding tube on the patient, such as a nasogastric or gastrostomy tube.
Here's a breakdown of the acceptance criteria and the studies performed for the RELIZORB™ device:
1. Table of Acceptance Criteria and Reported Device Performance
Note: The document primarily focuses on non-clinical and animal studies. There is no information provided about human-in-the-loop performance, multi-reader multi-case studies, or traditional algorithm-only performance metrics like sensitivity, specificity, etc., as this is a medical device (enzyme-packed cartridge) performing a chemical function, not an AI/imaging device.
Biocompatibility Testing
Test | Purpose | Acceptance Criteria | Reported Device Performance |
---|---|---|---|
Cytotoxicity – MEM Elution Test | Assess biological activity of mouse fibroblast cells after exposure to extracts. | Non-cytotoxic | Non-cytotoxic |
Irritation – Intracutaneous reactivity | Determine if extracts produce an irritation reaction when injected intracutaneously. | Non-irritating | Non-irritating |
Sensitization – Guinea Pig Maximization | Determine potential for sensitization of extracts. | Non-sensitizing | Non-sensitizing |
Acute systemic toxicity | Determine potential for acute systemic toxicity of extracts by injection into mice. | Not systemically toxic | Not systemically toxic |
Genotoxicity – In Vitro Gene Mutations | Determine potential mutagenic activity of extracts by measuring reversion rates in bacteria. | Non-mutagenic | Non-mutagenic |
Genotoxicity – In Vitro Mouse Lymphoma | Determine if extracts induce forward mutations at the thymidine kinase locus. | Non-mutagenic | Non-mutagenic |
Genotoxicity – In Vivo Mouse Micronucleus | Determine potential for extracts to induce micronuclei formation in immature polychromatic erythrocytes in the bone marrow of mice. | Non-mutagenic | Non-mutagenic |
Performance Testing - Bench
Test | Purpose | Acceptance Criteria | Reported Device Performance |
---|---|---|---|
Torque strength | Determine torque necessary to separate small bore connectors from the cartridge body. | Torque at separation higher than 3 times the estimated clinical force. | RELIZORB™ met the acceptance criteria. |
Tensile strength | Determine force required to separate small bore connectors from the cartridge using a linear tensile force. | Linear tensile strength shall be greater than [b)(4) psi] (value obscured in document). | RELIZORB™ met the established acceptance criteria. |
Air leakage test | Establish that material bonds would not fail or leak when challenged with pressurized air. | Material bonds shall not leak when challenged with [b)(4) psi] compressed air. | RELIZORB™ did not leak and met the acceptance criteria. |
Filter integrity | Ensure FCS/enzyme beads are retained within the cartridge, by subjecting device to maximum pump flow rate in forward and reverse flow. | Should not allow for beads to pass the filter and leave the cartridge. | Allowed 5 particles in 3 forward flow repetitions and 1 particle in reverse flow. Only 1 particle had a diameter of [b)(4) - size obscured]. Justified as contamination and clinically acceptable due to small number and biocompatibility. |
Fat hydrolysis | Determine amount of free fatty acids (FFA) produced by enzymatic hydrolysis using a simulated enteral circuit. | Produce [b)(4) FFA] per serving. | Breaks down ≈90% of fats in most enteral formulas. (Detailed results added to labeling). |
Unconjugated lipase analysis | Evaluate potential leaching of lipase enzyme from beads. | No formal acceptance criteria. Measured lipase concentration using a [b)(4) assay]. | Observed [b)(4) %] leaching by BCA assay and [b)(4) %] by absorbance. Deemed safe due to biocompatibility and GRAS status of lipase. |
Assessment of impact to other nutrients | Ensure device does not adversely affect other nutrients (vitamins, minerals) in enteral formula under simulated use. | No formal acceptance criteria. Conducted nutritional analysis of vitamins and minerals. | No meaningful difference for any vitamins or minerals after exposure to RELIZORB™. |
Flow rate | Ensure device does not restrict the flow of formula using an enteral feeding pump. | Presence of RELIZORB™ should not affect the flow rate of formula. | No statistical differences between flow rate with or without RELIZORB™. |
Liquid leakage test | Inspect material joints for leaks during priming or flow rate testing after simulated feeding. | Should not leak under normal and worst-case conditions. | No leaking observed using two formulas and two different enteral feeding pumps. |
Pump alarm verification | Verify that the flow error alarm works both before and after RELIZORB™ by kinking the tubing during flow rate testing. | Shall not cause pump alarm failure. | Verified that the flow alarm sounds if tubing becomes occluded before or after RELIZORB™. |
Shelf Life Testing (6 months)
Test | Purpose/Acceptance Criteria (identical to bench tests) | Reported Device Performance |
---|---|---|
Fat hydrolysis | Demonstrate equivalent fat hydrolysis after aging. | No meaningful difference between baseline and aged product |
Tensile strength | Not compromised after aging. | Not compromised |
Filter integrity | Not compromised after aging. | Not compromised |
Flow rate | Not compromised after aging. | Not compromised |
Package integrity | Demonstrate package integrity (visual inspection, peel strength, bubble leak test). | Clean barrier not compromised after simulated shipping. |
Animal Studies (Effectiveness - primarily based on increased fat absorption)
Study | Acceptance Criteria | Reported Device Performance |
---|---|---|
Chronic Porcine Study 1 | Enhanced absorption of LCPUFAs, reflected by reduced total and PUFA fecal fats, and increase in %CFA (Coefficient of Fat Absorption), and increased AA and DHA in plasma/tissues. No adverse clinical effects. | Increased LCPUFA absorption, reduced total stool fat, fecal AA, and DHA. 20-30% improvement in %CFA (e.g., CV lipase 86.6±4.3% vs. control 67±5.8%, p=0.002; RO lipase 87.1±3.5% vs. control 67±5.8%, p=0.003). No adverse clinical effects or pathologic macroscopic findings. |
Chronic Porcine Study 2 | Safety and effectiveness of continuous feeding (RO lipase enzyme in beads) over 6 weeks. Reduced fecal fats, improved AA/DHA levels, normalized blood lipid profile, improved consumption of LCPUFA, and improved Vitamins A and E absorption. No safety signals on histopathology. | 38% and 53% reduction in omega-3 and omega-6 fecal LCPUFA. 66% and 50% respective reduction in fecal AA and DHA. Normalized blood lipid profile, improved LCPUFA consumption, and improved Vitamins A and E absorption. No safety signals related to treatment in blinded GLP histopathology (observed issues related to EPI status, not treatment). |
12 Day Efficacy Study | Increased fat absorption, measured as %CFA, and reduced stool weight. No adverse events. Validation of simulated use of RELIZORB™. | Statistically significant decrease in stool weight (p=0.014). Statistically significant increase in %CFA (approx. 60% for PepAF+EFIC vs. 42% for PepAF, p=0.036). No adverse events. |
24 Hour Pharmacodynamics | Statistically significant improvement in fat absorption in the treatment arm (prototype device) as evidenced by increased plasma omega-3 fat (DHA and EPA) concentrations. | Statistically significant (p |
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