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510(k) Data Aggregation
(30 days)
Massachusetts 02492
Re: K251156
Trade/Device Name: NPseal
Regulation Number: 21 CFR 878.4683
Therapy Non-Powered Suction Apparatus
Classification: Class II
Product Code: OKO (21 CFR 878.4683
| Guard Medical |
| Product Code | Same as predicate | OKO |
| Regulation No. | Same as predicate | 878.4683
The NPseal is indicated for patients who would benefit from wound management via application of negative pressure, particularly as the device may promote wound healing through the removal of small amounts of exudates from closed surgical incisions.
The NPseal Negative Pressure Advanced System is a single-use device that includes an integrated, mechanical pump system. The NPseal maintains Negative Pressure Wound Therapy (NPWT) in the -75 mmHg to -125 mmHg nominal range. Each NPseal dressing is intended to be used up to 7 days. The total therapy time across multiple NPseal dressing changes is up to 14 days. NPseal therapy must be discontinued after 14 days. NPSeal dressing wear time may be less than indicated if clinical practice or other factors such as time to wound closure and rate of exudate, result in earlier removal or need for dressing change.
- The NPseal 5 is intended for surgically closed incisions up to 5 cm × 0.5 cm.
- The NPseal 10 is intended for surgically closed incisions up to 10 cm x 0.5 cm.
- The NPseal 15 is intended for surgically closed incisions up to 15 cm x 0.5 cm.
- The NPseal 20 is intended for surgically closed incisions up to 20 cm x 0.5 cm.
- The NPseal 25 is intended for surgically closed incisions up to 25 cm x 0.5 cm.
The provided 510(k) clearance letter and summary describe a modification to an existing medical device, the NPseal. The core of this submission is to extend the allowed "Total Therapy Time" from 7 days to 14 days, while the "Single Dressing Wear Time" remains 7 days.
Crucially, the document states that no functional, performance, or clinical testing was conducted for this specific submission (K251156) to support the extended therapy time. Instead, it relies on the safety and effectiveness established for the predicate device (K250708) and asserts that the labeling update itself does not raise new safety or effectiveness concerns.
Therefore, many of the requested details regarding acceptance criteria, study design, and performance metrics are not available within this document for the K251156 submission. The document explicitly states: "No functional or performance testing was completed based on the change" and "No clinical testing was applicable to this submission."
However, we can infer some information based on the nature of a 510(k) submission for a device like this and the reliance on a predicate. The original clearance (K250708) for the predicate device would have involved such testing.
Based on the provided text, here's what can be extracted and what cannot:
1. A table of acceptance criteria and the reported device performance
Not Applicable (N/A) for this specific K251156 submission.
The document explicitly states: "No functional or performance testing was completed based on the change." The acceptance criteria and performance data would have been part of the predicate device's (K250708) submission. Since no new testing was performed for K251156, no new performance data or specific acceptance criteria for the change are reported.
2. Sample size used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective)
N/A for this specific K251156 submission.
No new test set was used, as no new functional, performance, or clinical testing was conducted. The reliance is on prior V&V data from the predicate device.
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)
N/A for this specific K251156 submission.
No new test set was evaluated with expert ground truth, as no new studies were conducted.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set
N/A for this specific K251156 submission.
No new test set was adjudicated.
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
N/A. This device (Negative Pressure Wound Therapy Non-Powered Suction Apparatus) is not an AI/imaging device that would typically involve human readers or MRMC studies.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
N/A. This device does not incorporate an algorithm in the typical sense (e.g., for automated diagnosis or image analysis). It is a mechanical device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
N/A for this specific K251156 submission.
No new ground truth was established for the purpose of this submission, as no new studies were conducted. For the predicate device, ground truth for performance would likely have been established through physical and mechanical testing (e.g., pressure measurements, exudate absorption capacity, material biocompatibility) rather than clinical "ground truth" as seen in diagnostic device studies.
8. The sample size for the training set
N/A. This device does not involve machine learning or a "training set."
9. How the ground truth for the training set was established
N/A. This device does not involve machine learning or a "training set."
Summary of Device and Rationale for Clearance without New Testing:
The K251156 submission is a Special 510(k) based on the "The Special 510(k) Program" guidance. This program is for modifications to a manufacturer's own legally marketed device where the change does not pose new questions of safety or effectiveness.
- Device Name: NPseal
- Device Type: Non-Powered Suction Apparatus Device Intended For Negative Pressure Wound Therapy (NPWT)
- Modification: Extension of the "Total Therapy Time" from 7 days to 14 days. Crucially, the "Single Dressing Wear Time" remains 7 days. This implies that therapy over 14 days would involve at least one dressing change.
- Rationale for No New Testing: The FDA's clearance suggests that changing the total therapy duration from 7 to 14 days, while keeping the single dressing wear time at 7 days, was considered a minor labeling change that does not introduce new risks or alter the fundamental performance of the device that was already proven safe and effective for up to 7 days, presumably including multiple dressing changes within that 7-day period. The assumption is that if a patient can safely use the device for two 7-day periods (with a dressing change) in sequence, then extending the total therapy time to 14 days doesn't inherently change the device's mechanism of action or safety profile. The previous verification and validation data from the predicate (K250708) were deemed sufficient to support this extended timeframe.
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(29 days)
Needham, Massachusetts 02492
Re: K250708
Trade/Device Name: NPseal
Regulation Number: 21 CFR 878.4683
Therapy Non-Powered Suction Apparatus
Classification: Class II
Product Code: OKO (21 CFR 878.4683
| Guard Medical |
| Product Code | Same as predicate | OKO |
| Regulation No. | Same as predicate | 878.4683
The NPseal is indicated for patients who would benefit from wound management via application of negative pressure, particularly as the device may promote wound healing through the removal of small amounts of exudates from closed surgical incisions.
The NPseal Negative Pressure Advanced System is a single-use device that includes an integrated, mechanical pump system. The NPseal maintains Negative Pressure Wound Therapy (NPWT) in the -75 mmHg to -125 mmHg nominal range.
The NPseal is intended for 7 days of use. Therapy duration of the system may be less than indicated if clinical practice or other factors such as time to wound closure and rate of exudate, result in earlier removal or need for system change.
- The NPseal 5 is intended for surgically closed incisions up to 5 cm × 0.5 cm.
- The NPseal 10 is intended for surgically closed incisions up to 10 cm x 0.5 cm.
- The NPseal 15 is intended for surgically closed incisions up to 15 cm x 0.5 cm.
- The NPseal 20 is intended for surgically closed incisions up to 20 cm x 0.5 cm.
- The NPseal 25 is intended for surgically closed incisions up to 25 cm x 0.5 cm.
The provided text is a 510(k) clearance letter for a medical device called NPseal. It is crucial to understand that this document describes a Special 510(k) submission, which is used for minor changes to an already cleared device. In this case, the changes were:
- Adding an MR safety statement to labeling.
- Minor labeling updates regarding wear time and latex content.
- Adding an alternate source for a material (hydrophilic polyurethane foam).
The core of a Special 510(k) is to demonstrate that the minor modifications do not raise new questions of safety or effectiveness and that the modified device remains substantially equivalent to the cleared predicate device. This is different from a de novo submission or a traditional 510(k) for a novel device or significant change, which would typically involve more extensive clinical performance studies.
Therefore, the "studies" mentioned in this document are primarily non-clinical performance testing to ensure the alternative material performs equivalently, and no clinical trials or human-in-the-loop studies (like MRMC studies) were conducted or needed for this specific Special 510(k) submission. The FDA's acceptance is based on the equivalency demonstrated through bench testing and material assessments, not on clinical performance criteria like diagnostic accuracy.
Analysis of the Provided Information against the Request:
Based on the nature of a Special 510(k) for these specific changes, many of the requested elements (especially those related to clinical performance, ground truth establishment, expert adjudication, and MRMC studies) are not applicable to this document. The "device performance" here refers to physical and material performance, not diagnostic accuracy or human-in-the-loop clinical benefit.
Here's an attempt to answer your questions based only on the provided text, highlighting what is applicable and what isn't:
Acceptance Criteria and Device Performance for NPseal (K250708)
The acceptance criteria for this Special 510(k) submission primarily revolved around demonstrating that the modifications (specifically, the alternative foam source) maintained the same performance and safety profile as the predicate device (K241522). This is centered on non-clinical performance specifications.
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria Category | Specific Criteria (Implicitly from the changes) | Reported Device Performance (from K250708) |
---|---|---|
Material Performance | Equivalent physical and functional performance of the alternative hydrophilic polyurethane foam pad to the original source. | "Testing has shown that the alternative sourced material meets the same performance specifications as the predicate device." |
Biocompatibility | Compliance with ISO 10993-1 for the alternative material. | "Biocompatibility: Same as predicate (Complies with ISO 10993-1)" (re-executed for alternative source) |
Shelf-Life | Maintenance of device integrity and performance over its labeled shelf-life with the new material. | "Shelf-life testing was re-executed." (Implied successful, as clearance was granted) |
Negative Pressure Range | Maintain -75 to -125 mmHg (± 17.5 mmHg) | "Same as predicate" |
Exudate Management | Maintain management via absorption into foam and evaporation through film. | "Same as predicate" |
Sterility | Maintain sterility (Gamma irradiation). | "Same as predicate" (Implied validated for new material/source if affected) |
MR Safety | Demonstrating MR Safe status for the device. | "MR Status: MR Safe" (Previously "Not evaluated") |
Labeling Accuracy | Accurate reflection of device capabilities and instructions. | Labeling updates made (MR safety, wear time, latex statement). |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size for Test Set: Not explicitly stated in terms of number of units or patients for performance testing. As this is a Special 510(k) focused on material equivalency, "test sets" would refer to units used in bench testing.
- Data Provenance: Not specified. Performance and shelf-life testing would typically be conducted in a laboratory setting, likely at the manufacturer's or a contract lab's facility. It's non-clinical data, not patient data. This was not a clinical study.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
- Not Applicable. No ground truth in the sense of clinical diagnoses or expert consensus was established for a "test set" from patient data, as this was not a clinical study assessing diagnostic performance or clinical outcomes. The "ground truth" here is the technical specification of the predicate device, against which the modified device's bench test results were compared.
4. Adjudication Method for the Test Set
- Not Applicable. There was no expert adjudication process as this was non-clinical performance testing, not a clinical study requiring human interpretation of medical images or data.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was Done
-
No. An MRMC study was not done. This type of study is relevant for AI/imaging devices to show how AI assists human readers. The NPseal is a physical wound therapy device, and this particular submission involved material and labeling changes, not development or modification of an AI component or a diagnostic aid.
-
Effect Size: Not applicable, as no MRMC study was performed.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not Applicable. The NPseal is a physical medical device, not a diagnostic algorithm. Therefore, "standalone performance" of an algorithm is not relevant. The closest analogous concept would be the device's physical performance (e.g., maintaining negative pressure), which was assessed via bench testing to be equivalent.
7. The Type of Ground Truth Used
- Technical Specifications / Predicate Device Performance Data: The "ground truth" for affirming substantial equivalence in this context was the established, documented performance specifications and safety profile of the legally marketed predicate NPseal device (K241522). The new material and changes had to meet or exceed these existing, validated specifications through non-clinical testing.
8. The Sample Size for the Training Set
- Not Applicable. There was no "training set" in the context of machine learning or AI, as this submission did not involve an AI/algorithm.
9. How the Ground Truth for the Training Set was Established
- Not Applicable. (See #8)
In summary, this document highlights a Special 510(k) for minor changes to an already cleared physical medical device. The "study" proving acceptance was primarily non-clinical bench testing to demonstrate that the revised device, particularly with an alternate material source, met the same performance specifications as its predicate. Clinical trials, human reader studies, or AI algorithm training/testing were not part of this specific submission.
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(78 days)
, Massachusetts 02492
Re: K241522
Trade/Device Name: NPseal (20 and 25) Regulation Number: 21 CFR 878.4683
II |
| Product Code: | OKO (21 CFR 878.4683
Same as predicate | 878.4683
The NPseal is indicated for patients who would benefit from wound management via application of negative pressure, particularly as the device may promote wound healing through the removal of small amounts of exudates from closed surgical incisions.
The NPseal Negative Pressure Advanced System is a single-use device that includes an integrated, mechanical pump system. The NPseal maintains Negative Pressure Wound Therapy (NPWT) in the -75 mmHg to -125 mmHg nominal range. The NPseal is intended for 7 days of use. Therapy duration of the system may be less than indicated if clinical practice or other factors such as time to wound closure and rate of exudate, result in earlier removal or need for system change. The NPseal 20 is intended for surgically closed incisions up to 20 cm x 0.5 cm. The NPseal 25 is intended for surgically closed incisions up to 25 cm x 0.5 cm.
The provided text is a U.S. FDA 510(k) summary for the NPseal device. It states that the device is a Non-Powered Suction Apparatus Device Intended For Negative Pressure Wound Therapy. The document describes modifications to an already cleared device, specifically the introduction of longer versions (NPseal 20 and NPseal 25).
Crucially, the document does not describe the specific acceptance criteria or a study that proves the device meets those acceptance criteria in the context of typical AI/ML medical device performance studies (e.g., sensitivity, specificity, AUC). This is because the device, Guard Medical's NPseal, is a negative pressure wound therapy device, not an AI/ML diagnostic or prognostic device. The 510(k) submission is for a physical medical device with design modifications (longer versions), not a software or AI algorithm.
Therefore, many of the requested information points (like AI performance metrics, sample size for test/training sets, expert consensus for ground truth, MRMC studies) are not applicable to this type of device and submission.
However, I can extract information related to the performance testing that was conducted for this device modification, which served as the "proof" that the modified device is substantially equivalent to its predicate.
Here's the reinterpretation of your request based on the provided document:
Device: Guard Medical NPseal (Negate Pressure Wound Therapy Device)
Nature of the Submission: Special 510(k) for device modification – introducing longer versions (NPseal 20 and NPseal 25) of an already cleared negative pressure wound therapy (NPWT) device.
Acceptance Criteria and Reported Device Performance (Non-AI/ML Context)
Since this is a physical medical device and not an AI/ML product, the "acceptance criteria" and "performance" relate to its physical and functional characteristics remaining equivalent or safe despite the size change.
The document refers to "Verification and validation data" supporting substantial equivalence. Based on the "Summary of Functional and Performance Testing," the acceptance criteria would be that the modified devices maintain the crucial functionalities of the predicate device.
Table of Performance Testing and Implied Acceptance Criteria:
Performance Test (Analogous to "Acceptance Criteria Review Area") | Reported Device Performance (Implicitly Met) |
---|---|
Pressure and Exudate Handling Over Time | Functions in the specified negative pressure range (-75 to -125 mmHg nominal) and effectively handles exudates over its intended 7-day use, similar to the predicate. |
Pull Testing | The device's adhesion or structural integrity under tension remains adequate for its intended use. |
Benchtop Usability Testing | The device can be used safely and effectively by its intended users in a lab/simulated environment. |
Packaging Validation | The packaging effectively protects the device, maintains sterility, and ensures device integrity until use. |
Sterility | Remains sterile via Gamma irradiation, as per predicate. |
Biocompatibility | Complies with ISO 10993-1, as per predicate, indicating materials are safe for patient contact. |
Study that Proves the Device Meets the Acceptance Criteria:
The studies conducted were benchtop performance and functional tests, not clinical trials in the sense of large patient cohorts, as this was a Special 510(k) for a modification (size increase).
2. Sample Size and Data Provenance:
- Sample Size: Not explicitly stated as a numerical sample size of "patients" or "images" as it's a physical device. For benchtop testing, typically multiple units of the device would be tested to ensure consistency and reliability. The document states testing was performed "exclusively on the NPseal 25 as it represents the most challenging device size," implying tests were sufficient to address the change.
- Data Provenance: Not applicable in terms of country of origin for clinical data or retrospective/prospective collection, as no clinical testing was performed for this submission (as stated in Section 9: "No clinical testing was applicable to this submission."). The data originates from internal engineering and quality validation testing by Guard Medical, Inc.
3. Number of Experts and Qualifications for Ground Truth:
- Not applicable. This information is relevant for AI/ML diagnostic devices where human experts establish ground truth for image or data interpretation. For a physical device like NPseal, "ground truth" is typically defined by engineering specifications, material properties, and established medical standards for wound care devices, validated through physical and functional testing.
4. Adjudication Method for Test Set:
- Not applicable. No human interpretation or adjudication of test results in the context of diagnostic agreement was required here. Performance was assessed against engineering specifications and functional requirements.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:
- No. This type of study is for evaluating human reader performance with and without AI assistance for diagnostic tasks. It is not relevant to a negative pressure wound therapy device.
6. Standalone (Algorithm Only) Performance:
- Not applicable. The NPseal is a physical medical device, not an algorithm.
7. Type of Ground Truth Used:
- The "ground truth" for this device modification was based on engineering specifications, functional requirements, and performance data from the predicate device. The aim was to demonstrate that the increased sizes (NPseal 20 and NPseal 25) perform equivalently to the predicate devices (NPseal 5, 10, and 15) in terms of established parameters like negative pressure maintenance, exudate handling, and material integrity.
8. Sample Size for the Training Set:
- Not applicable. There is no "training set" as this is not an AI/ML device. The "training" in a broad sense would be the cumulative design and manufacturing experience for the predicate device.
9. How Ground Truth for Training Set was Established:
- Not applicable. See point 8.
In summary: The provided document is a 510(k) notice for a physical medical device modification, not an AI/ML software device. Therefore, the detailed questions pertaining to AI/ML study methodologies (e.g., AI performance metrics, expert labeling, MRMC studies) are not relevant to this specific FDA submission. The "proof" of meeting acceptance criteria for this device involved benchtop functional and performance testing to demonstrate substantial equivalence to an already cleared predicate device, despite the change in size.
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(30 days)
Massachusetts 02492
Re: K240244
Trade/Device Name: NPseal (Small, Medium, Large) Regulation Number: 21 CFR 878.4683
II |
| Product Code: | OKO (21 CFR 878.4683
| Same as predicate | 878.4683
The NPseal is indicated for patients who would benefit from wound management via application of negative pressure, particularly as the device may promote wound healing through the removal of small amounts of exudates from closed surgical incisions.
The NPseal Negative Pressure Advanced System is a single-use device that includes an integrated, mechanical pump system. The NPseal maintains Negative Pressure Wound Therapy (NPWT) in the -75 mmHg to -125 mmHg nominal range. The NPseal is intended for 7 days of use. Therapy duration of the system may be less than indicated if clinical practice or other factors such as time to wound closure and rate of exudate, result in earlier removal or need for system change. The NPseal Small is intended to remove small amounts of exudate from surgically closed incisions up to 5 cm × 0.5 cm. The NPseal Medium is intended to remove small amounts of exudate from surgically closed incisions up to 10 cm x 0.5 cm. The NPseal Large is intended to remove small amounts of exudate from surgically closed incisions up to 15 cm x 0.5 cm.
The provided text is a 510(k) summary for a medical device called NPseal. This document does not contain information about acceptance criteria for device performance in the context of diagnostic or prognostic accuracy, nor does it describe a study that uses a test set, expert ground truth, or addresses human reader performance with or without AI.
The document describes a submission for a modification to an existing device (NPseal K212971) to allow for 7 days of wear time instead of 6, and some manufacturing-related design changes. The document explicitly states: "No clinical testing was applicable to this submission."
Therefore, I cannot provide the requested information about acceptance criteria, device performance, sample sizes for test/training sets, data provenance, expert qualifications, adjudication methods, MRMC studies, standalone performance, or ground truth establishment for a study demonstrating device performance against acceptance criteria for a diagnostic/prognostic device.
The study described in this document is a non-clinical bench testing and verification/validation study to support the modified device's safety and effectiveness compared to its predicate.
Here's what information can be extracted or inferred from the provided text, related to the nature of this submission:
- Type of Study: Bench testing, verification, and validation of physical device modifications and extended wear time.
- Purpose of Study: To demonstrate substantial equivalence of the modified NPseal to the predicate device, particularly regarding the extended wear time and manufacturing changes.
- Tests Performed (Functional and Performance Testing):
- Pressure and Exudate Handling Over Time
- Benchtop Usability Testing
- Pull Testing
- Shipping Validation
- Ground Truth: For the "Pressure and Exudate Handling Over Time" test, the "ground truth" would be defined by pre-determined engineering specifications for negative pressure range (-75 to -125 mmHg nominal range) and exudate handling capabilities, both over the extended 7-day period. For "Pull Testing," it would be mechanical strength requirements. For "Usability" and "Shipping," it would be performance against established protocols and acceptance limits for functionality and integrity after use/transport.
- No Clinical Testing: The document explicitly states, "No clinical testing was applicable to this submission." This means there's no clinical trial data to evaluate device performance in patients, nor any data related to diagnostic accuracy, sensitivity, specificity, or human reader performance.
- Sample Size: The document does not specify sample sizes for the bench tests.
- Experts: Not applicable in the context of diagnostic/prognostic device evaluation. Engineering and quality control personnel would have designed, executed, and reviewed these bench tests.
In summary, the provided FDA 510(k) document is for a non-diagnostic device modification and does not contain the type of study data (clinical, AI performance, expert review, etc.) that your request targets.
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(146 days)
166 Needham, Massachusetts 02492
Re: K212971
Trade/Device Name: NPseal Regulation Number: 21 CFR 878.4683
II |
| Product Code: | OKO (21 CFR 878.4683
| Same as predicate | 878.4683
The NPseal is indicated for patients who would management via application of a negative pressure, particularly as the device may promote wound healing through the removal of small amounts of exudates from closed surgical incisions.
The NPseal Neqative Pressure Advanced System is a single-use device that includes an integrated, mechanical pump system. The NPseal maintains Negative Pressure Wound Therapy (NPWT) in the -75 mmHg to -125 mmHg nominal range.
The NPseal is intended for 6 days of use. Therapy duration of the system may be less than indicated if clinical practice or other factors such as time to wound closure and rate of exudate, result in earlier removal or need for system change. The NPseal can be replaced only one time for a total maximum wear time of 6 days.
The NPseal Small is intended for surgically closed incisions up to 5cm x 0.5 cm
The NPseal Medium is intended for surgically closed incisions up to 10 cm x 0.5 cm.
The NPseal Large is intended for surgically closed incisions up to 15 cm x 0.5 cm.
The provided text is a 510(k) Summary for the NPseal device, specifically for the Medium and Large versions. It outlines the device description, indications for use, comparison to a predicate device, and functional/performance testing.
Here's the breakdown of the acceptance criteria and study information:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria Category | Specific Acceptance Criteria | Reported Device Performance (NPseal Large) |
---|---|---|
Pressure and Exudate Handling | Maintain negative pressure within the specified range (-75 mmHg to -125 mmHg). | Demonstrated that negative pressure could be maintained within the specified range. |
Capable of absorbing simulated exudate. | Demonstrated that the device was capable of absorbing simulated exudate. | |
Volume of simulated exudate absorbed covers less than 50% of the foam pad. | Demonstrated that the volume of simulated exudate absorbed covered less than 50% of the foam pad. | |
Benchtop Usability Testing | Usability requirements for pump actuation met. | Demonstrated that usability requirements including pump actuation met acceptance criteria. |
Usability requirements for device removal from packaging met. | Demonstrated that usability requirements including device removal from packaging met acceptance criteria. | |
Usability requirements for device application met. | Demonstrated that usability requirements including device application met acceptance criteria. | |
Usability requirements for ability to generate negative pressure met. | Demonstrated that usability requirements including ability to generate negative pressure met acceptance criteria. | |
Packaging Validation | Sterile packaging seal maintained after environmental conditioning. | Demonstrated that sterile packaging seal was maintained after undergoing environmental conditioning. |
Sterile packaging seal maintained after simulated distribution. | Demonstrated that sterile packaging seal was maintained after undergoing simulated distribution. | |
Biocompatibility | Compliance with ISO 10993-1. | The predicate device (NPseal Small) complies with ISO 10993-1, and the subject devices use the same materials, implying continued compliance. |
Negative Pressure Range Maintenance | Maintain negative pressure within -75 mmHg to -125 mmHg (± 17.5 mmHg). | The "Pressure and Exudate Handling Over Time" test demonstrated negative pressure could be maintained, aligning with this criterion. |
Maximum Therapy Time | 6 days. | The device is intended for 6 days of use. (This is a design specification, confirmed by comparison to predicate). |
Maximum Number of Dressing Changes | 1 dressing change. | The device can be replaced only one time. (This is a design specification, confirmed by comparison to predicate). |
Wear Time per Dressing | Up to 6 days. | Up to 6 days. (This is a design specification, confirmed by comparison to predicate). |
Sterility | Sterile - Gamma irradiation. | Sterile - Gamma irradiation. (This is a design specification, confirmed by comparison to predicate). |
2. Sample Size Used for the Test Set and Data Provenance
The document does not explicitly state the specific sample sizes (e.g., number of devices/units) for each of the performance tests. It mentions that testing was performed "exclusively on the NPseal Large as it represents the worst-case device size," indicating that the tests were conducted using physical samples of the NPseal Large.
- Sample Size: Not explicitly stated for each test (e.g., how many NPseal Large devices were tested for pressure, usability, or packaging).
- Data Provenance: The studies described appear to be prospective benchtop and in-house laboratory testing conducted by Guard Medical (or their designated testing facilities) as part of their design control and 510(k) submission process. There is no indication of external or retrospective data from patients. The country of origin of this testing data is not specified, but the applicant and consultant are based in the USA.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications
There is no mention of experts being used to establish ground truth for the test set. The tests described (Pressure and Exudate Handling, Benchtop Usability, Packaging Validation) are objective functional and performance tests with predefined acceptance criteria that do not typically require expert consensus for ground truth establishment. For usability, a group of users might be involved, but they would be testers, not "experts" establishing ground truth in the sense of a diagnostic interpretation.
4. Adjudication Method for the Test Set
Since the described studies are objective functional and performance tests (e.g., measuring pressure, observing exudate absorption, confirming sterilization seal integrity), an "adjudication method" as typically understood in studies involving subjective interpretations (like medical imaging) is not applicable and therefore not mentioned. The results are based on direct measurements and observations against pre-defined engineering and performance specifications.
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 explicitly states: "No clinical testing was applicable to this submission." The submission focuses on demonstrating substantial equivalence through bench testing, comparing the larger NPseal sizes to the already cleared smaller NPseal predicate.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done
This question is not applicable to this device. The NPseal is a physical medical device (a non-powered negative pressure wound therapy device), not a software algorithm or AI-driven system. Therefore, the concept of "standalone performance" for an algorithm is irrelevant. The focus is on the device's mechanical and material performance.
7. The Type of Ground Truth Used
The "ground truth" for the performance claims are based on pre-defined engineering specifications, regulatory standards (e.g., ISO 10993-1), and the performance characteristics of the predicate device.
- For pressure maintenance, the ground truth is the specified pressure range (-75 to -125 mmHg).
- For exudate handling, the ground truth includes criteria like "capable of absorbing simulated exudate" and "less than 50% foam pad coverage."
- For usability, the ground truth is the successful completion of specific tasks (pump actuation, removal from packaging, application, generation of negative pressure).
- For packaging, the ground truth is maintaining seal integrity.
- For biocompatibility, the ground truth is compliance with ISO 10993-1.
These are objective, measurable standards rather than subjective expert consensus, pathology, or outcomes data typically used for diagnostic or treatment effectiveness claims.
8. The Sample Size for the Training Set
This question is not applicable. The NPseal is a physical medical device, not a machine learning model. Therefore, there is no "training set" in the context of AI or algorithms. The design and development process for a physical device involves engineering principles, material science, and iterative testing, not data-driven training of a model.
9. How the Ground Truth for the Training Set was Established
This question is not applicable for the same reason as point 8. There is no training set for a physical device.
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(452 days)
: npSIMS Negative Pressure Surgical Incision Management System™ (npSIMS)™ Regulation Number: 21 CFR 878.4683
|
| Classification | Regulation Number: 21 CFR 878.4683
Regulation | Regulation Number: 21 CFR 878.4683
| Regulation Number: 21 CFR 878.4683
The Negative Pressure Surgical Incision Management System (npSIMS)™ is indicated for patients who may benefit from wound management via application of negative pressure, as the device may promote wound healing through the removal of excess exudate, infectious material and tissue debris. The npSIMS is indicated for removal of small amounts of exudate from closed surgical incisions.
The npSIMS Negative Pressure Surgical Incision Management System™ by Aatru Medical, LLC is a single-use medical device consisting of a non-sterile vacuum chamber and sterile dressing and tubing kit. The npSIMS is intended for use with closed incisions with low exudate up to 10ml, or over a period of up to 7 days. The disposable vacuum chamber initially generates a peak negative pressure of -100±5mmHg at the wound surface, and maintains a continuous, linear rate of pressure decline to -60mmHg over 7 days (nominally, 80mmHg ± 20mmHg). Wound exudate is managed by the absorptive dressing technology. The tubing can be cut to length based upon patient needs. Making use of a fully pre-assembled wound contact dressing, the npSIMS operates silently without the use of an external electromechanical pump nor collection canister, enabling discrete patient portability. The duration of treatment is dependent upon the recommendation of the treating physician. After use, all components of the npSIMS are disposed of as clinical waste in accordance with local protocols and regulations.
The provided text is a 510(k) summary for the npSIMS Negative Pressure Surgical Incision Management System. It primarily focuses on demonstrating substantial equivalence to a predicate device through technological characteristic comparisons and non-clinical performance testing against recognized consensus standards.
Based on the provided text, here's a breakdown of the requested information:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly present a discrete "acceptance criteria" table with corresponding "reported device performance" values for a clinical study comparing an AI device against a specific benchmark. Instead, it refers to non-clinical tests that ensure the device meets product performance specifications and complies with FDA Recognized Consensus Standards.
Acceptance Criteria Category (from text) | Reported Device Performance / Assessment (from text) |
---|---|
Non-Clinical Performance Tests | "In vitro performance tests of the npSIMS Negative Pressure Surgical Incision Management System™ were carried out to evaluate its ability to meet product performance specifications, including delivery of negative pressure, wound exudate fluid management, and system performance. The test results met all acceptance criteria and ensure the design and construction are suitable for its intended use and as recommended by the Non-powered Suction Apparatus Device Intended for Negative Pressure Wound Therapy (NPWT) - Class II Special Controls Guidance for Industry and FDA Staff." |
Delivery of Negative Pressure | "The disposable vacuum chamber initially generates a peak negative pressure of -100±5mmHg at the wound surface, and maintains a continuous, linear rate of pressure decline to -60mmHg over 7 days (nominally, 80mmHg ± 20mmHg)." |
Wound Exudate Fluid Management | "Use with low exudate wounds up to 10ml." (This is a specification of the device, implying an acceptance criterion for its exudate management capability). |
System Performance | (General statement that the tests met acceptance criteria for system performance). |
Biocompatibility | Compliance with ANSI AAMI ISO 10993-1:2018, ISO 10993-5:2009/R2014, ANSI AAMI ISO 10993-10:2010/R2014, ISO 10993-6 Third edition 2016-12-01, ANSI AAMI ISO 10993-11:2017. |
Sterility | Compliance with ISO 11135:2014 + A1:2018. |
Packaging | Compliance with ASTM D4169-16: 2016. |
Usability | Compliance with BS EN 62366-1: 2015 + A1:2020 / ANSI AAMI IEC 62366-1:2015 + AMD1:2020 / IEC 62366-1 Ed. 1.1: 2020-06. |
Important Note: The provided text is for a non-powered medical device (npSIMS Negative Pressure Surgical Incision Management System), not an AI or software as a medical device (SaMD). Therefore, many of the subsequent questions related to AI device evaluation (sample sizes for test/training sets, experts for ground truth, adjudication methods, MRMC studies) are not applicable to this document. The study described is primarily a set of non-clinical functional and safety performance tests.
2. Sample size used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective)
- Not applicable. The document describes non-clinical in vitro performance tests and compliance with recognized standards, not a clinical study with human subjects or a test set of data in the context of AI.
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. Ground truth in the context of expert consensus is relevant for diagnostic AI/imaging devices. This document describes the performance of a physical medical device. The "ground truth" here would be the physical and chemical properties of the device and its operational parameters, assessed against engineering specifications and regulatory standards.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set
- Not applicable. Adjudication methods like 2+1 are used for resolving discrepancies among human readers in interpreting data for ground truth establishment, which is not described for this device's evaluation.
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 device is not an AI or software assistance tool for human readers. It's a wound care system.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done
- Not applicable. This is a physical non-powered medical device, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
- For the non-clinical performance tests, the "ground truth" is defined by engineering specifications, established physical and chemical principles, and the requirements of the referenced FDA Recognized Consensus Standards (e.g., ISO, ASTM standards). For biocompatibility, this involves laboratory tests with established protocols. For negative pressure delivery, it's about meeting specified pressure ranges.
8. The sample size for the training set
- Not applicable. This document describes the evaluation of a physical medical device, not an AI model that requires a training set.
9. How the ground truth for the training set was established
- Not applicable. As described above, there is no AI training set for this device.
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(28 days)
166 Needham, Massachusetts 02492
Re: K211130
Trade/Device Name: NPseal Regulation Number: 21 CFR 878.4683
II |
| Product Code: | OKO (21 CFR 878.4683
| Same as predicate | 878.4683
The NPseal is indicated for patients who would benefit from wound management via application of negative pressure, particularly as the device may promote wound healing through the removal of small amounts of exudates from closed surgical incisions.
The NPseal Negative Pressure Advanced System is a single-use device that includes an integrated, mechanical pump system. The NPseal maintains Negative Pressure Wound Therapy (NPWT) in the -75 mmHg to -125 mmHg nominal range. The NPseal is intended for 6 days of use. Therapy duration of the system may be less than indicated if clinical practice or other factors such as wound size, rate or volume of exudate, or orientation of the dressing result in earlier removal or need for system change. The NPseal can be replaced only one time for a total maximum wear time of 6 days. The NPseal is intended for surgically closed incisions up to 5 cm x 0.5 cm.
This document describes a Special 510(k) submission for the NPseal device, focusing on a labeling modification to extend the wear time from 3 days to 6 days. Due to this being a Special 510(k) and the nature of the device (non-powered suction apparatus for negative pressure wound therapy), the study performed is primarily performance and functional testing rather than a complex clinical or AI-based study.
Here's the breakdown of the acceptance criteria and the study, addressing your specific points:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria (What was tested) | Device Performance (Result) |
---|---|
Pressure and Exudate Handling Over Time | The document states that this testing was performed to assess the impact of extending the wear time from 3 to 6 days. While specific numerical results (e.g., precise pressure maintenance values, exudate absorption rates) are not provided in this summary, the conclusion drawn from this testing is that the modified NPseal is "as safe as the predicate device" and that the labeling changes "do not raise any different questions of safety or effectiveness." This implies that the device successfully maintained its intended pressure range (-75 mmHg to -125 mmHg nominal range, ± 17.5 mmHg) and adequately handled exudate over the extended 6-day period, meeting the implicit functional acceptance criteria of the predicate device. |
Shelf-Life Testing | Shelf-life was extended from 6 to 24 months. The testing used "identical test methods and acceptance criteria to the predicate device." While specific test methods (e.g., accelerated aging, real-time aging data) and acceptance criteria (e.g., maximum allowable change in material properties, sustained negative pressure over time after aging) are not detailed here, the successful extension of the shelf-life to 24 months indicates that the device met these criteria, maintaining its integrity and functionality over the extended storage period. |
Biocompatibility | "Complies with ISO 10993-1." This signifies that the materials used in the device are considered biocompatible and suitable for direct or indirect patient contact for the intended duration of use (up to 6 days), as per international standards. |
Sterility | "Sterile - Gamma irradiation." This indicates the device achieved and maintained sterility as validated by appropriate methods (e.g., bioburden testing, sterility assurance level (SAL) validation) following gamma irradiation, in line with regulatory requirements. |
Negative Pressure Range | The device maintains Negative Pressure Wound Therapy (NPWT) in the "-75 mmHg to -125 mmHg nominal range (± 17.5 mmHg)." This is a key functional requirement, and the comparative table states this is "Same as predicate," implying the modified device continues to meet this defined pressure range. |
Management of Exudates (Mechanism) | "Managed by the dressing itself - via combination of absorption into the foam pad and evaporation through the breathable upper film." This describes the mechanism, which is indicated as "Same as predicate," suggesting the effectiveness of this mechanism was sustained with the extended wear time. |
2. Sample Size Used for the Test Set and the Data Provenance
The document does not explicitly state the sample sizes (e.g., number of devices or test units) used for the pressure and exudate handling over time, or for the shelf-life testing. These would typically be determined based on statistical justification for engineering bench testing, but are not disclosed in this summary.
The data provenance is from bench testing (laboratory-based performance and functional testing). The country of origin for the data is implicitly the United States, given Guard Medical Inc.'s location in Miami, FL, and the FDA submission. The testing would be considered prospective in the sense that it was conducted specifically to support this 510(k) submission for the modified device.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts
This type of submission (Special 510(k) for a non-AI/imaging device with a labeling change based on performance testing) does not involve medical experts establishing ground truth in the way an AI diagnostic tool would. The "ground truth" here is based on engineering specifications, validated test methods, and performance against established benchmarks (i.e., the predicate device's performance over its shorter wear time). The experts involved would be engineers, materials scientists, and quality/regulatory personnel who designed and executed the tests and interpreted the results against defined acceptance criteria. Their qualifications would be in their respective technical fields.
4. Adjudication Method for the Test Set
No adjudication method as typically understood in human-reader studies (e.g., 2+1, 3+1 consensus) was performed. The data generated is from objective, quantitative bench testing, assessed against predefined engineering specifications and performance targets from the predicate device.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was Done
No, an MRMC comparative effectiveness study was not performed. This type of study is relevant for AI-powered diagnostic devices where the performance of human readers with and without AI assistance is compared. The NPseal is a physical medical device, and the changes relate to its wear time and shelf-life, not its diagnostic capability or a human-in-the-loop diagnostic process.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was Done
No, this question is not applicable. The NPseal is a physical device, not an algorithm. Its "standalone" performance refers to its ability to maintain negative pressure and manage exudate, which was evaluated through the "Pressure and Exudate Handling Over Time" and "Shelf-Life Testing" mentioned.
7. The Type of Ground Truth Used
The "ground truth" for this submission is based on:
- Engineering Specifications and Performance Benchmarks: The device must maintain specific negative pressure ranges and manage exudate effectively over the specified wear time.
- Predicate Device Performance: The modified device's performance must be substantially equivalent to, or better than, the predicate device's performance regarding safety and effectiveness, even with the extended wear time.
- International Standards: Compliance with standards like ISO 10993-1 for biocompatibility is also a form of established "ground truth" for material safety.
It is not based on expert consensus, pathology, or outcomes data in the context of diagnostic accuracy, as this is not a diagnostic device.
8. The Sample Size for the Training Set
This question is not applicable. The NPseal is a physical medical device, not an AI model that requires a training set.
9. How the Ground Truth for the Training Set Was Established
This question is not applicable as there is no training set for this device.
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(110 days)
#166 Needham, Massachusetts 02492
Re: K200305
Trade/Device Name: NPseal Regulation Number: 21 CFR 878.4683
Classification Name: Non-Powered suction apparatus device intended for negative pressure wound therapy. (21 CFR 878.4683
|
| Regulation
Number | 878.4683
| 878.4683
The NPseal is indicated for patients who would benefit from wound management via application of negative pressure, particularly as the device may promote wound healing through the removal of small amounts of exudates from closed surgical incisions.
The NPseal Negative Pressure Advanced System is a single-use device that includes an integrated, mechanical pump system. The NPseal maintains Negative Pressure Wound Therapy (NPWT) in the -75 mmHq to -125 mmHq nominal range. The NPseal is intended for 3 days of use. Therapy duration of the system may be less than indicated if clinical practice or other factors such as wound size, rate or volume of exudate, or orientation of the dressing results in earlier removal or need for system change. The NPseal can be replaced only one time for a total maximum wear time of 6 days. The NPseal is intended for surgically closed incisions up to 5 cm x 0.5 cm.
(1) A table of acceptance criteria and the reported device performance:
The provided text does not contain explicit acceptance criteria in a table format with corresponding reported device performance, as one might find in a detailed study report. Instead, it lists the types of performance data submitted for FDA's substantial equivalence determination.
Summary of Performance Data Submitted:
Test Category | Specific Tests Performed |
---|---|
Biocompatibility Testing | Cytotoxicity, Sensitization, Irritation or Intracutaneous Reactivity, Acute Systemic Toxicity, Material-Mediated Pyrogenicity, Subacute Systemic Toxicity, Subchronic Systemic Toxicity, Implantation |
Bench Testing | Pressure and exudate handling over time test, Curved surface pressure over time, Foam characterization test, Pump body adhesion test, Dressing peel test, Exudate handling without negative pressure test, Moisture vapor transmission rate (MVTR) test, Shelf Life test, Benchtop Usability Verification, Set Negative Pressure test |
Human Factors Testing | User validation study |
The "Conclusions" section states: "The test data support the safety of the device and the hardware verification and validation demonstrate that the NPseal shall perform as intended in the specified use conditions." This implies that the device met the internal acceptance criteria for each of these tests, although the specific numerical or qualitative targets for these criteria are not detailed in this summary.
(2) Sample size used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective):
The provided document is a 510(k) summary for a medical device (NPseal). It summarizes the performance data used to support substantial equivalence. It does not provide details on the sample sizes, data provenance (e.g., country of origin), or whether the studies were retrospective or prospective for the various tests mentioned (Biocompatibility, Bench, and Human Factors). These details would typically be found in the full study reports, which are not part of this summary document.
(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):
This information is not provided in the document. The NPseal is a physical device (non-powered suction apparatus for negative pressure wound therapy), not an AI/imaging diagnostic device that would typically rely on expert ground truth for a "test set" in the way an AI algorithm for image analysis does. The studies mentioned (biocompatibility, bench testing, human factors) involve laboratory or user-based assessments, not an expert panel reviewing diagnostic outcomes for ground truth establishment.
(4) Adjudication method (e.g., 2+1, 3+1, none) for the test set:
This information is not applicable and therefore not provided. Adjudication methods like 2+1 or 3+1 are typically used in clinical trials or studies involving expert interpretation of data (e.g., medical images) where discrepancies need to be resolved to establish ground truth. As the NPseal is a physical medical device for wound therapy and the studies mentioned are largely laboratory or performance-based, such adjudication would not be 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:
This information is not applicable and therefore not provided. An MRMC study is relevant for evaluating the performance of diagnostic imaging devices or AI algorithms where multiple human readers interpret cases. The NPseal is a non-powered suction apparatus for negative pressure wound therapy, not a diagnostic imaging device or an AI assistance tool for human readers.
(6) If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
This information is not applicable and therefore not provided. The NPseal is a physical medical device, not a standalone algorithm. The performance data provided relate to the physical and functional aspects of the device, as well as its interaction with users (human factors).
(7) The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
The concept of "ground truth" in the context of an AI or diagnostic study does not directly apply to the testing of the NPseal device as described. The testing (biocompatibility, bench testing, human factors) would have established expected performance parameters and safety profiles against predetermined engineering specifications, international standards (e.g., ISO 10993-1), and user requirements. For example:
- Biocompatibility: Ground truth would be the established safety limits and biological responses as defined by ISO standards.
- Bench Testing: Ground truth would be the engineering specifications for pressure, exudate handling, material strength, etc.
- Human Factors Testing: Ground truth would be the user performance against predefined usability objectives and safety critical tasks.
(8) The sample size for the training set:
This information is not applicable and therefore not provided. The NPseal is a physical medical device, not an AI algorithm that requires a training set. The various tests performed (biocompatibility, bench, human factors) are part of the verification and validation process for a hardware device, not model training.
(9) How the ground truth for the training set was established:
This information is not applicable and therefore not provided, as there is no "training set" for this physical medical device.
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(168 days)
Trade/Device Name: Anscare SIMO Negative Pressure Wound Therapy (NPWT) System Regulation Number: 21 CFR 878.4683
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| Regulation Number: | 21 CFR 878.4683
-------------------------------------|
| Regulation Number: | 21 CFR 878.4683
SIMO System is indicated for patients who would benefit from a suction device (negative pressure wound therapy) as it may promote wound healing via removal of excess exudate and infectious materials.
SIMO System is suitable for use in both hospital and homecare setting and is indicated for the following wound types:
- Chronic wounds
- Acute wounds
- Traumatic wounds
- Subacute and dehisced wounds
- Partial-thickness burns
- Ulcers (such as diabetic or pressure)
- Flaps and grafts
- Closed surgical incisions
Anscare SIMO Negative Pressure Wound Therapy (NPWT) System including non-sterilized SIMO Pump and sterilized SIMO Dressing. Patient is able to carry the SIMO Pump easily in the pocket or a belt holder (additional accessory). Anscare SIMO Negative Pressure Wound Therapy (NPWT) System is also called "SIMO System" in the following description.
SIMO System has 3 types of model variants including "2 SIMO Dressings and 1 SIMO Pump", "2 SIMO Dressings and 1 SIMO Pump with 1 holder" and "3 SIMO Dressings". Each type has 4 models, and each modelcontains 4 different sizes of SIMO dressing separately.
SIMO System is for single person use only. SIMO Pump could use for 30 days. The SIMO Dressing is sterilized by Ethylene Oxide and single-use.
SIMO System including non-sterilized negative pump and sterilize dressing. The negative pressure wound therapy is provided by a pump (-125±15mmHg) up to 30 days by manual and may promote wound healing via the removal of exudate. The negative pressure is provided by the SIMO Pump, and the exudates of wound bed is managed by the dressing. SIMO Dressing is applied to the wound. It should be changed in line with standard wound management guidelines, typically every 3-4 days up to 7 days. More frequent dressing changes may be required depending on the level of exudates, condition of the dressing, wound type/size, orientation of dressing, environmental considerations and/or other patient the considerations.
The provided text describes a 510(k) premarket notification for a medical device (Anscare SIMO Negative Pressure Wound Therapy (NPWT) System). This type of submission focuses on demonstrating substantial equivalence to a legally marketed predicate device, primarily through performance and safety testing. It does not present a study proving the device meets acceptance criteria in the format of a clinical trial or a machine learning model's performance evaluation against specific metrics.
Therefore, I cannot extract the information required to answer your request in the specified format, as the document details bench testing, biocompatibility, and sterilization, but not a study designed to evaluate performance against the kind of "acceptance criteria" you've outlined (e.g., accuracy, sensitivity, specificity, or human improvement with AI assistance).
The provided text details the following:
- Device: Anscare SIMO Negative Pressure Wound Therapy (NPWT) System
- Intended Use: Promotes wound healing via removal of excess exudate and infectious materials. Suitable for hospital and homecare settings for various wound types (chronic, acute, traumatic, subacute/dehisced, partial-thickness burns, ulcers, flaps/grafts, closed surgical incisions).
- Predicate Device: SNaP® Wound Care System (K151710) and Reference Device: PICO Single Use Negative Pressure Wound Therapy System (K151436).
- Testing Performed:
- Bench Testing: Tubing Tensile Strength Test, Adhesive test, Function Test after Drop Testing, Life Time for 30 Days Test (pump performance over 150 presses), Simulation Test (performance with low/moderate exudate, pressure stability, exudate management, fluid reflux rate), HFE/UE Report (Human Factors and Usability Engineering).
- Biocompatibility Testing: In Vitro Cytotoxicity, Skin Sensitization, Intracutaneous Skin irritation, Acute Intravenous Systemic Toxicity, Acute Intraperitoneal Systemic Toxicity, Pyrogen Test, Subacute/subchronic toxicity, Implantation study, Phthalate leachables study.
- Sterilization Testing: Verification of Ethylene Oxide (EO) sterilization process and residual testing per ISO standards.
This documentation serves to demonstrate that the device is as safe and effective as a legally marketed predecessor, not to provide statistical performance metrics typically seen in AI/ML device submissions or clinical trials.
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(121 days)
| 21 CFR 878.4683
Mepiseal is intended to be used on periwound skin in conjunction with a wound dressing to prevent leakage and premature loosening of the dressing. It is designed to fill uneven skin surfaces and mold around wounds in challenging anatomical locations. When used under NPWT dressings, Mepiseal serves as a sealant to help create and maintain a seal, which enables delivery of effective negative pressure wound therapy.
When used under NPWT dressings to aid in seal formation, Mepiseal is compatible with the Avance Dressing Kits that include Avance Film with Safetac Technology and Avance Transparent Film.
The subject device is a soft silicone sealant intended to be used on periwound skin in conjunction with a wound dressing and is designed to fill uneven skin surfaces and mold around wounds in challenging anatomical locations. Mepiseal serves the same function as the soft silicone layer of any wound dressing, to maintain the seal of the dressing around the wound. It is considered an accessory to the wound dressing and can be used under conventional wound dressings and under Negative Pressure Wound Therapy (NPWT) dressings.
The provided text is a 510(k) summary for the Mepiseal Soft Silicone Sealant. It describes the device, its intended use, and its comparison to predicate devices, but does not contain information about acceptance criteria or a study proving the device meets those criteria in the context of typical AI/ML device performance.
The "Performance Data" section states: "Bench testing has been performed to demonstrate that Mepiseal is capable of sealing air leaks in the Avance NPWT system and does not otherwise interfere with the system's ability to transport fluid away from the wound. Mepiseal's performance has been evaluated under both soft silicone films and acrylic films (Avance Film with Safetac Technology and Avance Transparent Film) and found to be acceptable."
This indicates functional testing of the sealing ability and compatibility with an NPWT system, not a study assessing diagnostic performance (like sensitivity, specificity, or AUC) which would be typical for an AI/ML device. Therefore, I cannot provide details for most of your requested points, as they are not applicable to the type of device described (a silicone sealant) or the type of data presented (bench testing for physical functionality).
However, I can extract the following:
1. A table of acceptance criteria and the reported device performance:
Based on the provided text, the acceptance criteria implicitly relate to the device's ability to create and maintain a seal for negative pressure wound therapy systems and not interfere with fluid transport. The "reported device performance" is a qualitative statement of meeting these criteria.
Acceptance Criteria (Implied) | Reported Device Performance |
---|---|
Capable of sealing air leaks in the Avance NPWT system. | "Mepiseal is capable of sealing air leaks in the Avance NPWT system." |
Does not interfere with the Avance NPWT system's ability to transport fluid away from the wound. | "Mepiseal... does not otherwise interfere with the system's ability to transport fluid away from the wound." |
Performance is acceptable under both soft silicone films (Avance Film with Safetac Technology) and acrylic films (Avance Transparent Film). | "Mepiseal's performance has been evaluated under both soft silicone films and acrylic films (Avance Film with Safetac Technology and Avance Transparent Film) and found to be acceptable." |
2. Sample sized used for the test set and the data provenance: Not applicable. This was bench testing, not a clinical study or AI/ML performance evaluation test set with patient data.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. Ground truth for an AI/ML system or diagnostic accuracy was not established.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable.
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 device or a diagnostic device where human reader improvement would be measured.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable. This is not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.): Not applicable. The "ground truth" here would be the physical principles of sealing and fluid transport, verified through bench test measurements.
8. The sample size for the training set: Not applicable. There is no training set for an AI/ML algorithm.
9. How the ground truth for the training set was established: Not applicable. There is no training set for an AI/ML algorithm.
In summary, the provided document describes a medical device (a silicone sealant) and its associated bench testing results for a 510(k) submission, not an AI/ML medical device. Therefore, most of the requested information regarding AI/ML performance studies (e.g., sample sizes for training/test sets, expert ground truth establishment, MRMC studies) is not present and not relevant to this specific premarket notification.
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