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510(k) Data Aggregation
(90 days)
Trade/Device Name: Resilience Fully Covered Esophageal Stent System
Regulation Number: 21 CFR 878.3610
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Trade/Device Name: Resilience Fully Covered Esophageal Stent System
Regulation Number: 21 CFR 878.3610
Name | Esophageal prosthesis |
| Classification Name | Prosthesis, Esophageal |
| Regulation Number | 878.3610
The Resilience Fully Covered Esophageal Stent System is intended for maintaining esophageal luminal patency in patients with esophageal strictures caused by intrinsic and/or extrinsic malignant tumors and for occlusion of esophageal fistulae.
The MERIT ENDOTEK® Resilience™ Fully Covered Esophageal Stent System is a through-the-scope system comprised of two components: the radiopaque self-expanding nitinol stent and the delivery system. The stent is completely covered with a biocompatible silicone membrane. Stent expansion results from the physical properties of the metal and the proprietary geometry. The stent is designed with unique geometrical features at the distal and proximal ends to anchor the stent and resist migration. The proximal and distal ends of the stent are threaded with suture intended for use in repositioning and removal of the stent.
The stents come in nine (9) sizes, comprising all combinations of three lengths (5cm, 6cm, and 7cm) and three midbody diameters (14mm, 17mm, and 20mm). The midbody lengths are 1cm, 2cm, and 3cm with the flared ends comprising the remaining length. The ends of the stents are larger in diameter than the midbody.
There is one 10.5Fr delivery system used to deploy all 9 stents.
The provided FDA 510(k) clearance letter and summary for the Resilience Fully Covered Esophageal Stent System describes non-clinical testing to demonstrate substantial equivalence to a predicate device. However, it does not include information about clinical studies involving human readers or AI algorithms. The clearance is based on the device itself (the stent system), not an AI algorithm performing diagnosis or analysis.
Therefore, many of the requested points, especially those pertaining to AI performance, human reader studies, and ground truth establishment for AI, cannot be answered from the provided text.
Here's an analysis based on the information provided, focusing on the device's non-clinical testing:
Acceptance Criteria and Reported Device Performance (Non-Clinical)
The study described is a series of non-clinical, in-vitro tests on the mechanical and material properties of the Resilience Fully Covered Esophageal Stent System and its delivery system.
Acceptance Criteria Category | Reported Device Performance |
---|---|
Stent Verification Testing | |
Dimensions & Condition (post-deployment & removal) | Passed predetermined specifications |
Suture purse-stringing ability | Passed predetermined specifications |
Stent spring-back after purse-stringing | Passed predetermined specifications |
Repositioning with forceps | Passed predetermined specifications |
Suture withstands forceps | Passed predetermined specifications |
Removal force | Passed predetermined specifications |
Flare retention force | Passed predetermined specifications |
Radial pressure forces (compression/expansion) | Passed predetermined specifications |
Tensile strength | Passed predetermined specifications |
Food flow | Passed predetermined specifications |
Post-Fatigue Stent Testing | |
Condition (post-fatigue) | Passed predetermined specifications |
Removal force (post-fatigue) | Passed predetermined specifications |
Flare retention force (post-fatigue) | Passed predetermined specifications |
Radial pressure forces (compression/expansion, post-fatigue) | Passed predetermined specifications |
Tensile strength (post-fatigue) | Passed predetermined specifications |
Delivery System Testing | |
Guidewire compatibility | Passed predetermined specifications |
Catheter working length | Passed predetermined specifications |
Catheter outer diameters | Passed predetermined specifications |
Safety functionality | Passed predetermined specifications |
Stent deployment force | Passed predetermined specifications |
Stent repositioning after partial deployment | Passed predetermined specifications |
Stent expansion after deployment | Passed predetermined specifications |
Deployment accuracy | Passed predetermined specifications |
Delivery system condition (post-deployment & removal) | Passed predetermined specifications |
Tip-to-guidewire lumen bond strength | Passed predetermined specifications |
Outer sheath-to-connector bond strength | Passed predetermined specifications |
Egress plug-to-guidewire lumen bond strength | Passed predetermined specifications |
Material/Environmental Testing | |
Corrosion testing | Met all predetermined corrosion performance requirements |
MRI compatibility | MR conditional in accordance with FDA's guidance |
Biocompatibility testing | Met requirements of FDA Final Guidance ISO 10993-1 |
Overall Design Validation | All design validation requirements were met |
Information Not Found in the Provided Text:
Since this is a clearance for a medical device (esophageal stent) and not an AI/software device, the following points related to AI studies are not applicable or not present in the provided document.
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Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective):
- This device clearance is based on non-clinical, in-vitro testing. It does not utilize "test sets" in the context of clinical data for AI analysis. The "test sets" here refer to batches of manufactured stents and delivery systems for mechanical and material property evaluation. Specific sample sizes for each non-clinical test are not detailed in this summary, but the summary states "all of the above testing passed the predetermined specifications" and "All design validation requirements were met."
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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 as this is not an AI/software clearance based on expert-labeled clinical data. Ground truth for non-clinical device testing is typically based on engineering specifications and direct physical measurements/observations.
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Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Not applicable.
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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-assisted device.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- For the non-clinical testing, the "ground truth" or "reference standard" would be the pre-defined engineering specifications and performance criteria derived from established medical device standards and the predicate device's performance benchmarks. For biocompatibility, the ground truth is compliance with ISO 10993-1.
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The sample size for the training set:
- Not applicable, as this is not an AI/software device. There is no "training set" in the context of machine learning.
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How the ground truth for the training set was established:
- Not applicable.
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Trade/Device Name: Niti-S Duodenal Comfort Stent Niti-S Colonic Comfort Stent Regulation Number: 21 CFR 878.3610
Duodenal stent; colonic stent |
| Regulation Number: | 21 CFR 878.3610
|
| Regulation
Number | 21 CFR 878.3610
| 21 CFR 878.3610
Niti-S Duodenal Comfort Stent is indicated for the palliative treatment of pyloric or duodenal obstructions caused by malignant neoplasms.
Niti-S Colonic Comfort Stent is indicated for the palliative treatment of colorectal strictures produced by malignant neoplasms and to relieve large bowel obstruction prior to colectomy in patients with malignant strictures.
The Niti-S Duodenal Comfort Stent and Niti-S Colonic Comfort Stent consist of an implantable metallic stent and an introducer system.
The stent is made of nitinol wire and is designed as a flexible, fine mesh tubular prosthesis with several radiopaque markers. The Niti-S Duodenal Comfort Stent has a diameter of 22 mm, while the Niti-S Colonic Comfort Stent is available in diameters of 22 mm and 24 mm. Both stent types are available in lengths of 60 mm, 80 mm, 100 mm, and 120 mm.
The stent delivery system accommodates a 0.035 in (0.89 mm) guidewire. It is advanced over the guidewire and passed through an endoscope into the duodenum or colon. Fluoroscopy is recommended to ensure accurate device placement.
This document is a 510(k) Premarket Notification from the U.S. Food & Drug Administration (FDA) for medical devices. It primarily focuses on the substantial equivalence determination for the Niti-S Duodenal Comfort Stent and Niti-S Colonic Comfort Stent.
Crucially, this document does not describe studies involving AI or software-based medical devices with performance metrics like sensitivity, specificity, or AUC. It is for a physical medical device (stent and delivery system) and the performance testing mentioned are mechanical and material integrity tests.
Therefore, I cannot provide the information requested regarding acceptance criteria and studies proving the device meets those criteria in the context of an AI/software device. The questions about sample size for test sets, data provenance, expert ground truth, adjudication methods, MRMC studies, standalone performance, and training set details are all irrelevant to the content of this document.
The "Performance Testing" section (page 7) lists the following non-clinical tests:
- Packaging strength and dye penetration
- Sterility verification
- Deployment accuracy test
- Deployment force test
- Dimensional test
- Tensile strength test (SDS)
- Trackability and visualization test
- Repositioning force test
These are standard engineering and material science tests for physical medical devices to ensure they function as intended and are safe. The document states that the results "demonstrate that the Niti-S Duodenal Comfort Stent and Niti-S Colonic Comfort Stent are as safe and effective as the predicate device and supports a determination of substantial equivalence."
In summary, the provided document does not contain the information requested about AI device performance studies.
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(137 days)
Name: Ultraflex Esophageal NG Stent System; WallFlex Esophageal Stent System Regulation Number: 21 CFR 878.3610
| |
| Regulation Number | 878.3610
The Ultraflex Esophageal NG Stent is intended for maintaining esophageal luminal patency in esophageal strictures caused by intrinsic and/or extrinsic malignant tumors only. The Ultraflex Esophageal NG Covered Stent System is also indicated for occlusion of concurrent esophageal fistula.
The WallFlex Esophageal Partially Covered and Fully Covered Stent System is intended for maintaining esophageal luminal patency in esophageal strictures caused by intrinsic malignant tumors, and occlusion of concurrent esophageal fistulas.
The Ultraflex Esophageal NG Stent System allows placement of a self-expanding metallic stent within the esophagus. The systems consist of a flexible delivery system preloaded with an expandable with or without a cover. The WallFlex Esophageal Stent System consists of a self-expanding esophageal metal stent and a delivery system.
The provided text is an FDA 510(k) clearance letter and a 510(k) summary for Boston Scientific's Ultraflex Esophageal NG Stent System and WallFlex Esophageal Stent System. This document explicitly states that the proposed devices are identical to their legally marketed predicate devices in design, material, chemical composition, fundamental technology, principle of operation, sterilization, packaging, shelf-life, and manufacturing process.
Therefore, the submission does not describe a study involving acceptance criteria and device performance based on a test set, expert ground truth, or AI assistance. The clearance is based on the substantial equivalence of the new devices to existing, already cleared devices.
Here's why the requested information cannot be extracted from this document:
- No new performance data is presented. The core argument for clearance is "identity" to predicates, not "improved performance" or meeting specific performance thresholds through new testing against a defined ground truth.
- The document states, "The testing performed on the proposed Ultraflex Esophageal Stent System and WallFlex Esophageal Stent System demonstrates the devices are substantially equivalent." This testing would likely be engineering or bench performance tests (e.g., stent radial force, deployment accuracy, material compatibility) to demonstrate the identity and safety of the new devices, not clinical performance against a diagnostic task or a clinical outcome. These tests are not detailed in the provided summary.
- The context is a 510(k) premarket notification for a Class II device. For such devices, especially those claiming identity to predicates with established performance, a comparative effectiveness study involving human readers with and without AI assistance is generally not required or performed.
- AI/Machine Learning is not mentioned. The document describes physical medical devices (stents), not AI-powered diagnostic or therapeutic tools.
In summary, the provided text does not contain the information requested regarding acceptance criteria, study design (test set, ground truth, experts, adjudication, MRMC, standalone), or training set details because the basis for clearance is substantial equivalence (identity) to existing devices, not a new performance claim for an AI/ML-driven device or a device requiring new clinical performance validation in the way described in your prompt.
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(122 days)
Massachusetts 01752
Re: K233837
Trade/Device Name: Agile Esophageal Stent System Regulation Number: 21 CFR 878.3610
| | 878.3610
The Agile Esophageal Stent System is intended for maintaining esophageal luminal patency in esophageal strictures caused by intrinsic and/or extrinsic malignant tumors, and occlusion of concurrent esophageal fistulas.
The Agile Esophageal Stent System consists of a self-expanding esophageal metal stent and a delivery system. The Agile Esophageal Stent is available partially or fully covered with silicone covering and in three diameter sizes: 14mm, 18mm and 23mm. The 14mm and 18mm diameter stents are pre-loaded on a 10.5Fr delivery system and the 23mm diameter stent is pre-loaded on an 18.5Fr delivery system. The 10.5Fr delivery system has a single central lumen to accommodate a 0.035" (0.89 mm) guidewire. The 18.5Fr delivery system has a single central lumen to accommodate a 0.038" (0.97mm) guidewire.
The provided text, K233837, is an FDA 510(k) clearance letter for the Boston Scientific Agile Esophageal Stent System. This document does not contain information about acceptance criteria or a study proving the device meets those criteria in the context of an AI/ML-driven medical device.
Instead, this document is a Traditional 510(k) submission for a non-software medical device (an esophageal stent system). The text explicitly states that the proposed device is "identical to the predicate Agile Esophageal Stent System (K180144 and K211960) in intended use, indications for use, classification, principles of operation, technical characteristics, performance, and materials." This means the submission is based on substantial equivalence to a previously cleared device, not on new performance studies with specific acceptance criteria that would typically be seen for an AI/ML device.
Therefore, I cannot provide the requested information as it is not present in the given document. The document confirms:
- Device Name: Agile Esophageal Stent System
- Regulation Number: 21 CFR 878.3610 (Esophageal Prosthesis)
- Regulatory Class: Class II
- Product Code: ESW
- Predicate Devices: K180144 and K211960 (Agile Esophageal Stent System and Agile Esophageal OTW Stent System, respectively)
- Basis for Clearance: Substantial equivalence to previously cleared predicate devices, an "identical" comparison in design, material, chemical composition, fundamental technology, principle of operation, sterilization, packaging, shelf-life, and manufacturing process.
The document discusses "Non-Clinical and/or Clinical Tests Summary & Conclusions," but it does so in the context of confirming the substantial equivalence to the predicate, implying that the tests performed (if any beyond confirming identical characteristics) were to demonstrate this equivalence, not to meet new, specific performance acceptance criteria for a novel AI/ML algorithm.
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(28 days)
Alexandria, Virginia 22314
Re: K240522
Trade/Device Name: Esophageal TTS Stent Regulation Number: 21 CFR 878.3610 |
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Common Name: |
Regulation Number: |
Identical |
Regulation |
21 CFR 878.3610 |
The Esophageal TTS Stent is intended for use in esophageal strictures caused by intrinsic and/or extrinsic malignant tumors and occlusion of concurrent esophageal fistulas.
The Esophageal TTS Stents that are the subject of this 510(k) are identical to the devices cleared in K221482, with the exception of the modification to its introducer system. The Esophageal TTS Stents consist of an implantable metallic stent and a disposable, flexible introducer system for placement of the stent. The stent is a flexible and expandable tubular device made of Nitinol wire that is intended to be implanted to restore the structure and/or function of the esophagus. The introducer is a disposable system for delivery and deployment of the stent at the target position. Upon deployment, the stent imparts an outward radial force on the luminal surface of the esophagus to establish patency.
This document is a 510(k) premarket notification for a medical device called the "Esophageal TTS Stent." It explains that the new device is substantially equivalent to a previously cleared device (K221482) manufactured by the same company, Taewoong Medical.
The core of the document focuses on demonstrating this substantial equivalence, noting that the stent itself is identical to the predicate device, with modifications only to the introducer system (the delivery mechanism). Therefore, much of the testing performed is related to the performance and biocompatibility of this modified introducer system.
Based on the provided document, here's a breakdown of the requested information:
This document is a marketing submission for a medical device (Esophageal Stent) that does not involve AI or software. Therefore, many of the requested criteria related to AI/software performance validation, such as "acceptance criteria for an AI model," "MRMC study," "standalone algorithm performance," "ground truth establishment for training set," are not applicable to this submission.
The "acceptance criteria" and "study that proves the device meets the acceptance criteria" in this context refer to the standard non-clinical performance and biocompatibility testing for a physical medical device, not an AI or software component.
Here's a detailed response to the applicable sections of your request:
1. A table of acceptance criteria and the reported device performance
The document does not provide a formal table with specific numerical acceptance criteria and reported numerical performance for each test. Instead, it lists the types of performance tests conducted and then states a general conclusion that the device "meets its design requirements and performs as intended" and is "as safe and effective as the predicate device."
However, we can infer the types of tests and the general outcome:
Acceptance Criteria Category | Specific Test Conducted (Implied Criteria: Meet Design Req. & Perform as Intended) | Reported Device Performance |
---|---|---|
Biocompatibility | Cytotoxicity (ISO 10993-5:2009) | Pass (Supports SE) |
Sensitization (ISO 10993-10:2021) | Pass (Supports SE) | |
Intracutaneous Reactivity (ISO 10993-23:2021) | Pass (Supports SE) | |
Acute Systemic Toxicity (ISO 10993-11:2017) | Pass (Supports SE) | |
Pyrogen Test (ISO 10993-11:2017, USP ) | Pass (Supports SE) | |
Device Performance | Deployment Test | Meets design requirements |
Deployment Force Test | Meets design requirements | |
Dimensional Test | Meets design requirements | |
Tensile Strength Test | Meets design requirements |
Notes on Acceptance Criteria:
- For biocompatibility tests, the acceptance criteria would be defined by the ISO standards, e.g., "non-cytotoxic," "not a sensitizer," etc.
- For performance tests (Deployment, Deployment Force, Dimensional, Tensile Strength), the acceptance criteria would be specific to the device's engineering specifications, such as "deployment within X seconds," "deployment force less than Y Newtons," "dimensions within Z tolerance," "tensile strength greater than W," etc. These specific numerical criteria and results are not provided in this summary document. The document only states that the testing was conducted and found to demonstrate substantial equivalence.
2. Sample sized 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 the sample sizes used for the non-clinical performance tests (Deployment, Deployment Force, Dimensional, Tensile Strength).
- For biocompatibility, the sample sizes would be typical for the specific ISO test methods (e.g., a certain number of mice for acute systemic toxicity, guinea pigs for sensitization), but these are not explicitly detailed.
- Data Provenance:
- This is a submission for a medical device (stent and introducer), not data related to a clinical study or AI model.
- The testing pertains to the physical characteristics and interaction of the device components.
- The manufacturer is Taewoong Medical Co., Ltd., based in the Republic of Korea. It's highly probable the testing was conducted there or at subcontracted labs.
- The tests are prospective in nature, as they are performed on newly manufactured devices or materials to demonstrate compliance for premarket submission.
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 (stent and introducer system) and does not involve a diagnostic AI or imaging interpretation. Therefore, there is no "ground truth" derived from expert interpretation of images or clinical data in the context of an AI model.
- The "ground truth" for this device's performance is established by engineering specifications, physical measurements, and standardized biological safety tests. The "experts" involved would be engineers, material scientists, and toxicologists/biologists conducting and interpreting the non-clinical tests.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not Applicable. Adjudication methods like 2+1 or 3+1 are used in clinical studies or for establishing ground truth in machine learning contexts (e.g., for radiology readings) where there might be disagreement among human readers. Since this is a submission for a physical device based on non-clinical performance and biocompatibility testing, such adjudication methods are not relevant.
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 submission is for a physical medical device (esophageal stent) and its introducer system. It does not involve AI or software, and therefore, no MRMC study or assessment of human reader improvement with AI assistance was conducted or would be relevant.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not Applicable. This device does not have an "algorithm" component. It is a physical medical device.
7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)
- The "ground truth" for this device is based on engineering specifications and established test methodologies.
- For performance tests (Deployment, Deployment Force, Dimensional, Tensile Strength), the ground truth is defined by the pre-defined design requirements and specifications (e.g., a stent must deploy within a certain time, or a certain force is required for deployment).
- For biocompatibility tests, the ground truth is defined by the results of standardized in vitro and in vivo biological tests as per ISO 10993 series, indicating the material's safety for contact with the body.
- It is not based on expert consensus, pathology, or outcomes data in the way these terms are typically used for diagnostic or AI-related devices.
8. The sample size for the training set
- Not Applicable. This is not an AI or machine learning device. Therefore, there is no "training set." The device's design is based on engineering principles and knowledge gained from previous device iterations (the predicate device).
9. How the ground truth for the training set was established
- Not Applicable. As there is no training set (being a physical medical device, not an AI), there is no ground truth establishment for a training set.
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System; WallFlex Duodenal Soft Stent System with Anchor Lock Delivery System Regulation Number: 21 CFR 878.3610
Expandable, metallic duodenal stent Classification Name Esophageal Prosthesis Regulation Number 21 CFR 878.3610
The WallFlex Colonic Stent System with Anchor Lock Delivery System is indicated for palliative treatment of colonic strictures caused by malignant neoplasms and to relieve large bowel obstructions prior to colectomy in patients with malignant strictures.
The WallFlex Duodenal Stent System with Anchor Lock Delivery System is indicated for the palliative treatment of gastroduodenal obstructions produced by malignant neoplasms.
The WallFlex Colonic Soft Stent System with Anchor Lock Delivery System is indicated for palliative treatment of colonic strictures caused by malignant neoplasms and to relieve large bowel obstructions prior to colectomy in patients with malignant strictures.
The WallFlex Duodenal Soft System with Anchor Lock Delivery System is indicated for the palliative treatment of gastroduodenal obstructions produced by malignant neoplasms.
The WallFlex Colonic Stent System with Anchor Lock Delivery System and WallFlex Duodenal Stent System with Anchor Lock Delivery System each consist of two components: the implantable metal stent and the anchor lock delivery system.
The proposed stent is manufactured of Ntinol. The stent will be offered in two diameters, 22mm with a 30mm flare. Each diameter will be available in three lengths, 6cm, 9cm, and 12cm. The WallFlex Duodenal Stent will only be offered in the 22mm/27mm stent diameter (all lengths) preloaded on the 230cm Anchor Lock Delivery System. The WallFlex Colonic Stent will be offered in the 22mm/27mm and 25mm/30mm diameters (all lengths) preloaded on the 230cm or 135cm Anchor Lock Delivery System. The Anchor Lock delivery system consist of a coaxial tubing assembly that constrains the stent on the until the stent is released by retracting the exterior tube.
The WallFlex™ Colonic Soft Stem with Anchor Lock Delivery System and WallFlex™ Duodenal Soft Stent System with Anchor Lock Delivery System each consist of two components: the implantable metal stent and the Anchor Lock Delivery System.
The stent is manufactured from Nitinol wires braided together to form a cylinder with a flared end. The wires are looped at both stent ends and welded at the non-flared end. The WallFlex Colonic Soft Stent and the WallFlex Duodenal Soft Stent will be offered in three diameters: 22 mm with a 27 mm flare, 20 mm flare, and 18 mm with a 23 mm flare. Each diameter will be available in three lengths, 6cm, 9cm, and 12cm. The stent sizes that are shared between the WallFlex Colonic Soft Stent and the WallFlex Duodenal Soft Stent are identical in all aspects of their design; the only difference is in indication.
The stent is compressed on a flexible catheter for delivery system consists in part of coaxial tubes. The exterior tube serves to constrain the stent until retracted during deployment. There are 3 radiopaque marker bands on the diftate placement; the exterior tube marker band, the deployment limit marker band, and the post deployment marker band. The exterior tube marker band is located adjacent to the leading end the deployment limit marker band is located adjacent to the trailing end of the stent. The deployment limit marker band identifies the stent beyond which the stent cannot be reconstrained. The post deployment marker band, situated 4cm from the trailing end of the constrained stent, helps to facilitate accurate placement of the stent. The only design difference between product offerings is how the stent is loaded onto the delivery system. The colonic stent is loaded with the flare is distal to the operator, and the duodenal stent is loaded with the flare is proximal to the operator.
The Anchor Lock stent holder is located at the trailing end of the stent on the delivery system to aid in reconstrainment when repositioning the stent. The interior tube of the coaxial system contains a central lumen that accommodates a 0.035 in. / 0.89 mm guidewire. The device may be inserted through the working channel of a 9 French endoscope (minimum channel diameter 3.2mm scope). The WallFlex Colonic/Duodenal Soft Stent with Anchor Lock Delivery System will be offered in 230cm.
The provided text pertains to a 510(k) premarket notification for a medical device, specifically the WallFlex Colonic and Duodenal Stent Systems. This document is a regulatory clearance letter from the FDA, asserting that the device is substantially equivalent to legally marketed predicate devices.
Crucially, this document does not describe the acceptance criteria and study proving a device meets those criteria for an AI/ML-enabled medical device. The product under review (WallFlex Stent Systems) is a physical, implantable medical device, not an AI/ML diagnostic or therapeutic system. Therefore, the concepts of "acceptance criteria for an AI/ML device," "test set sample size," "data provenance," "number of experts," "adjudication method," "MRMC study," "standalone performance," "ground truth type," "training set size," and "ground truth establishment for training" are not applicable to the content of this FDA clearance letter.
The letter focuses on demonstrating substantial equivalence to already cleared predicate devices based on:
- Intended Use/Indications for Use: The current devices have identical indications for use as their predicates, which are for palliative treatment of malignant colonic and duodenal strictures and large bowel obstructions.
- Technological Characteristics: The devices are stated to be identical to the predicates in terms of principles of operation, technical characteristics, performance, and materials (Nitinol stents with anchor lock delivery systems).
- Non-Clinical Tests: The documentation mentions compliance with FDA guidance for MR safety (ASTM F2503e2020), which is a standard non-clinical test for implantable devices, not an AI/ML algorithm validation.
In summary, this document is a 510(k) clearance for a conventional medical device and does not contain the information requested about acceptance criteria and study data for an AI/ML-enabled medical device.
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(449 days)
North Carolina 28269
Re: K223266
Trade/Device Name: Hilzo Esophageal Stents Regulation Number: 21 CFR 878.3610
| Product Code: | ESW |
| | Regulation No: | 878.3610
Number | 878.3610
| 878.3610
The HILZO Esophageal Stents are indicated for use in esophageal strictures caused by intrinsic malignant tumors.
The HILZO Esophageal Stents are partially covered and fully covered, self-expanding tubular prosthesis designed to maintain patency of esophageal strictures. The HILZO Esophageal stents are available loaded on two styles of delivery devices, Over the Wire (OTW) and Through the Scope (TTS). The OTW delivery devices are 14Fr and the TTS is 10.5Fr to enable delivery through the working channel of an endoscope. The stents are made of Nitinol wire and are designed to prevent stent migration due to peristaltic motion and tumor in-growth. The stents are available in a variety models, diameters and lengths.
The document provided is a 510(k) Premarket Notification from the FDA for a medical device: the Hilzo Esophageal Stents. This type of submission is for demonstrating "substantial equivalence" to a legally marketed predicate device, not for establishing novel safety and effectiveness through clinical trials or performance studies involving complex metrics like those for AI/ML devices (e.g., sensitivity, specificity, clinical workflow improvement).
Therefore, the vast majority of the requested information regarding acceptance criteria, study design, ground truth establishment, expert adjudication, MRMC studies, and training set details are not applicable to this particular document. This document focuses on demonstrating that the new device is as safe and effective as a previously cleared device, primarily through bench testing comparing physical and mechanical properties, and biocompatibility.
Here's what can be extracted and what cannot:
1. A table of acceptance criteria and the reported device performance
The document provides a comparative table where "acceptance criteria" are implicitly defined by similarity to the predicate device's performance, often with an explicit acceptance range (e.g., "fell within the +/- 5% difference acceptance criteria").
Feature | Acceptance Criteria (compared to Niti-S Esophageal K080782) | Reported HILZO Esophageal Stent Performance Range / Value | Reported Niti-S Esophageal Performance Range / Value |
---|---|---|---|
Regulatory Number | Same | 878.3610 | 878.3610 |
Product Code | Same | ESW | ESW |
Indication for Use | Same | For esophageal strictures caused by intrinsic and/or extrinsic malignant tumors | For esophageal strictures caused by intrinsic and/or extrinsic malignant tumors |
Principle of Operation | Similar/Same (TTS and OTW models for HILZO, OTW for predicate) | TTS and OTW models available | OTW |
Biocompatibility | Biocompatible per ISO 10993 | Biocompatible per ISO 10993 (found to be) | Biocompatible per ISO 10993 |
Single Use | Yes | Yes | Yes |
Sterility | Eto | Eto | Eto |
Stent material | Nitinol | Nitinol | Nitinol |
Covering material | Similar (biocompatibility and mechanical testing support equivalence) | Silicone/PTFE | Silicone |
Stent diameter (mm) | Similar (compression & expansion testing support differences) | 18-20 mm | 16-20 mm |
Stent total length (mm) | Similar (compression & expansion testing support differences; context of other cleared stents) | 60-150 mm | 60-120 mm |
Stent head | Similar flaring stent head design | Silicone covered and uncovered flaring stent head design with/without removal string (lasso) | Silicon covered and uncovered flaring stent head design with/without removal string (lasso) |
Delivery Diameter | Similar (deployment testing and tensile strength demonstrate performance) | OTW - 14 Fr, 16 Fr; TTS - 10.5 Fr | OTW - 16 Fr and 20 Fr |
MR Status | MR Conditional | MR Conditional | MR Conditional |
Expansion Force | All results fell within ±5% difference | Range: 0.442-0.537 kgf (Avg.) | Range: 0.439-0.543 kgf (Avg.) |
Compression Force | All results fell within ±5% difference | Range: 3.073-3.925 kgf (Avg.) | Range: 3.093-3.914 kgf (Avg.) |
2. Sample size used for the test set and the data provenance
The document mentions "extensive biocompatibility data" and various "Non-Clinical Performance Testing" types (shelf-life, expansion force, compression force, etc.). However, it does not specify sample sizes for these tests. The data provenance would be that of the manufacturer's internal testing. It's retrospective in the sense that the tests were completed before the submission. No country of origin for specific test data is provided, but the manufacturer is Thoracent, Inc. in Huntington, NY, USA.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This is not applicable. For this type of device (a physical medical implant), "ground truth" is established through engineering and biological performance standards, not expert medical opinion on a data set. The device is evaluated on its physical and mechanical properties and biocompatibility.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. There is no expert adjudication process for bench testing results in the way there would be for image interpretation in an AI/ML study.
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 a physical medical device (stent), not an AI/ML diagnostic or assistive software. MRMC studies are used for evaluating the impact of AI on human reader performance for diagnostic tasks.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This is a physical medical device, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
For this device, "ground truth" is established through:
- Engineering specifications and standards: For mechanical properties like expansion and compression force, dimensions, tensile strength, kink resistance.
- Biocompatibility standards (e.S. ISO 10993): For biological safety, ensuring the materials are not toxic or harmful to the body.
- Sterilization validation: Ensuring the device can be terminally sterilized.
- MR safety standards: To determine if the device is safe for patients undergoing MRI.
8. The sample size for the training set
Not applicable. This is a physical medical device, not an AI/ML model 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/ML model exists for this device.
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(264 days)
Trade/Device Name: Niti-S Duodenal Comfort Stent Niti-S Colonic Comfort Stent Regulation Number: 21 CFR 878.3610
Duodenal Comfort Stent;
Niti-S Colonic Comfort Stent
Duodenal stent; colonic stent
21 CFR 878.3610
The Niti-S Duodenal Comfort Stent is indicated for the palliative treatment of pyloric or duodenal obstructions caused by malignant neoplasms.
The Niti-S Colonic Comfort Stent is indicative treatment of colorectal strictures produced by malignant neoplasms and to relieve large bowel obstruction prior to colectomy in patients with malignant strictures.
The Niti-S Duodenal Comfort Stent and Niti-S Colonic Comfort Stent consist of the implantable metallic stent and introducer system.
The stent is made of nitinol wire. It is a flexible, fine mesh tubular prosthesis that has several radiopaque markers. The Niti-S Duodenal Comfort Stent has a diameter of 22 mm while the Niti-S Colonic Comfort Stent has diameters of 22 and 24 mm. They both have lengths of 60, 80, 100, and 120 mm.
The introducer system accepts a 0.035 in (0.89 mm) guidewire. The introducer system is passed over the guidewire and through an endoscope into the duodenum or colon. Use of fluoroscopy is recommended to ensure correct placement of the device.
This document is a 510(k) summary for the Niti-S Duodenal Comfort Stent and Niti-S Colonic Comfort Stent. It primarily focuses on demonstrating substantial equivalence to predicate devices through a comparison of technological characteristics and performance data from bench testing. It does not describe a study involving human subjects or AI.
Here's an analysis of what is present and what is missing based on your request:
1. Table of acceptance criteria and the reported device performance:
The document mentions that "The results of the bench testing show that the subject devices meet their specifications" for various tests. However, it does not provide a specific table outlining the acceptance criteria and the numerical results for each test. Instead, it lists the types of bench tests conducted:
Acceptance Criteria (Implied) | Reported Device Performance |
---|---|
Meet specifications for: | - Deployment Accuracy |
- Deployment Force | - Expansion Force |
- Compression Force | - Dimensional |
- Tensile Strength | - Shipping |
- Shelf-life | - Corrosion |
- MR Compatibility | - Axial Force |
- Trackability and Visualization | - Repositioning Force |
- Radiopacity | All listed tests met specifications and demonstrate substantial equivalence. |
Sterility | In accordance with ISO 11135:2014 & AAMI/ANSI/ISO 11607-1:2019, AAMI/ANSI/ISO 11607-2:2019 |
Biocompatibility | Acceptable biocompatibility profile (evaluated for cytotoxicity, sensitization, irritation/intracutaneous reactivity, acute systemic toxicity, material-mediated pyrogenicity, subacute/subchronic toxicity, chronic toxicity, and implantation effects) |
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 for Test Set: Not specified. The document only refers to "bench testing."
- Data Provenance: Not specified. Bench testing is typically performed in a lab setting, so country of origin isn't directly relevant in the same way as clinical data. This is not a study on patient data.
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 document describes bench testing of a medical device (stent and introducer system), not an AI algorithm or a diagnostic tool requiring expert ground truth in a clinical context.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
Not applicable. As this is bench testing, there is no expert adjudication of image interpretations or clinical diagnoses.
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 a 510(k) submission for a physical medical device (stent), not an AI-powered diagnostic or assistive tool. Therefore, no MRMC study or AI-related effectiveness analysis was conducted or reported here.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
No. This is for a physical medical device, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc):
Not applicable. For bench testing, the "ground truth" would be the engineering specifications and performance standards that the device is designed to meet. The document states the tests "meet their specifications."
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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(30 days)
Alexandria, VA 22314
Re: K221482
Trade/Device Name: Esophageal TTS Stent Regulation Number: 21 CFR 878.3610 |
---|
Device Common Name: |
Classification Name |
878.3610 |
878.3610 |
The Esophageal TTS Stent is intended for use in esophageal strictures caused by intrinsic and/or extrinsic malignant tumors and occlusion of concurrent esophageal fistulas.
The Esophageal TTS Stents consists of an implantable metallic stent and a disposable, flexible introducer system for placement of the stent is a flexible and expandable tubular device made of Nitinol wire that is intended to be implanted to restore the structure and/or function of the esophagus. The introducer is a disposable system for delivery and deployment of the stent at the target position. Upon deployment, the stent imparts an outward radial force on the luminal surface of the esophagus to establish patency.
The provided document is a 510(k) premarket notification for the Taewoong Medical Co., Ltd. Esophageal TTS Stent. It states that the device is "substantially equivalent" to previously cleared predicate devices (K211706, K123205, K113551) with the "exception of a modification to the Indications for Use statement."
As such, this document does not contain acceptance criteria for this specific submission with new performance data to prove the device meets these criteria. Instead, it relies on the previous clearances and argues that the change in indication does not affect safety and efficacy, therefore no additional performance data is required for this 510(k).
Therefore, I cannot provide the requested information regarding acceptance criteria and performance study details from this document. The document explicitly states:
- No additional biocompatibility information is required.
- Not applicable for Electrical safety and electromagnetic compatibility (EMC) as it contains no electrical components.
- Not applicable for Software Verification and Validation Testing as it contains no software.
- No additional performance data is required for Bench Testing because no design modifications were made.
- Not applicable for Animal Testing.
- Not applicable for Clinical Data.
The 510(k) submission relies on the substantial equivalence principle, asserting that since the new device is identical in design and materials to previously cleared devices, and the change in indication does not introduce new risks, the prior performance data of the predicate devices is sufficient.
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(151 days)
01752
Re: K211960
Trade/Device Name: Agile Esophageal OTW Stent System Regulation Number: 21 CFR 878.3610
Device Class and Panel: | Class II |
| Classification Regulation: | 21 CFR 878.3610
Device Class and Panel: | Class II |
| Classification Regulation: | 21 CFR 878.3610
Class II |
| Classification Regulation: | 21 CFR 878.3610
The Agile Esophageal Partially Covered OTW Stent System is intended for maintaining esophageal luminal patency in esophageal strictures caused by intrinsic malignant tumors, and occlusion of concurrent esophageal fistulas.
The Agile Esophageal Partially Covered and Fully Covered OTW Stent System is intended for maintaining esophageal luminal patency in esophageal strictures caused by intrinsic and/or extrinsic malignant tumors, and occlusion of concurrent esophageal fistulas.
The Agile Esophageal 23mm Partially Covered and Fully Covered Over the Wire (OTW) Stent System is comprised of a metallic implantable stent pre-loaded inside of a flexible delivery system. The stent is made from braided Nitinol wires which form a self-expanding. radiopaque (RO) cylindrical mesh. The stent has flares at each end to aid in minimizing migration after the stent is placed in the esophagus. The flares are a wider diameter than the stent body. The wire ends are looped at the end of the stent. The proximal and distal stent ends each have a continuous suture threaded around their circumferences. The suture is intended to aid in removal or repositioning during the initial stent placement procedure, to be used in the event of incorrect placement. The stent is available in either partially covered or fully covered configurations. The stent is covered with a silicone polymer to restrict turnor in-growth through the wire mesh and to occlude concurrent esophageal fistulas. The proposed stent is nearly identical in design to its predicate Agile Esophageal Stent System (K180144). The main difference between the proposed and the predicate stent is the type of delivery system used with the stent. The proposed Agile Esophageal OTW Stent is intended to be used with an over-the-wire delivery svstem. whereas the predicate Agile Esophageal Stent used a through-the-scope delivery system.
The over-the-wire delivery system is a co-axial tube design. The exterior tube is used to constrain the stent before deployment and to reconstrain the stent after partial deployment. The exterior tube has clear distal section so that the constrained stent is visible. A yellow transition zone on the inner tube of the delivery system is visible between the stent and the blue outer sheath. The system has RO and visual markers to aid in accurate stent placement.
The provided text describes a submission to the FDA for the Agile Esophageal OTW Stent System, establishing substantial equivalence to previously cleared predicate devices. The submission focuses on bench testing and biocompatibility to demonstrate this equivalence, rather than a clinical study evaluating the device's diagnostic performance with human readers and AI.
Therefore, many of the requested criteria related to clinical performance, expert ground truth, and AI assistance cannot be extracted from this document.
Here's what can be extracted based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The document lists performance attributes for the device, and the acceptance criteria are implicitly that the device "PASS" these tests, demonstrating substantial equivalence to the predicate devices.
Component | Acceptance Criteria (Product Specification) | Reported Device Performance |
---|---|---|
Delivery System | Visual Transition Zone Length | PASS |
Delivery System | Reconstrainment Band to Distal Inner Bond | PASS |
Delivery System and Stent | Delivery System Withdrawal / Removal | PASS |
Delivery System and Stent | Deployment Force | PASS |
Delivery System and Stent | Reconstrainment Force | PASS |
Stent | Stent Hoop Expansion Force | PASS |
Stent | Stent Hoop Compression Force | PASS |
Stent | Stent Flexibility | PASS |
Stent | Stent Fatigue Resistance | PASS |
Stent | Cover Fatigue Resistance | PASS |
Additionally, for biocompatibility:
Test Category | Acceptance Criteria | Reported Device Performance |
---|---|---|
Biocompatibility | According to ISO 10993-1; All acceptance criteria met for Cytotoxicity, Irritation, Sensitization Testing (stent component subset, delivery system complete set) | All acceptance criteria were met. |
2. Sample size used for the test set and the data provenance
The study conducted was a bench testing for mechanical performance and biocompatibility testing. The document does not specify a "test set" in the context of patient data or image data. Therefore, details like country of origin or retrospective/prospective nature are not applicable. The sample size for each specific bench test is not provided in this summary, only the outcome.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable. This device is a medical implant (stent) and its submission is based on engineering performance data and biocompatibility, not on diagnostic performance where human experts establish ground truth.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable, as no human expert adjudication on a test set (e.g., medical images) was performed.
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 MRMC study was done, and the device is not an AI-assisted diagnostic tool.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable, as this is a physical medical device, not a software algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
For the bench testing, the "ground truth" or reference for acceptance was the product specifications of both the proposed device and its nearly identical predicate devices. For biocompatibility, the ground truth was compliance with ISO 10993-1.
8. The sample size for the training set
Not applicable, as this is a physical medical device, not a machine learning model. There is no training set in this context.
9. How the ground truth for the training set was established
Not applicable, as there is no training set.
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