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510(k) Data Aggregation

    K Number
    K222972
    Manufacturer
    Date Cleared
    2023-08-25

    (332 days)

    Product Code
    Regulation Number
    892.5725
    Reference & Predicate Devices
    Predicate For
    N/A
    Why did this record match?
    510k Summary Text (Full-text Search) :

    19103

    Re: K222972

    Trade/Device Name: BioProtect Balloon Implant™ System Regulation Number: 21 CFR 892.5725
    |
    | Classification name: | Absorbable Perirectal Spacer |
    | Regulation Number: | 21 CFR 892.5725
    Both devices meet the regulatory definition for Absorbable Rectal Spacers outlined in 21 CFR 892.5725
    |
    | Classificationand ProductCode | 21 CFR 892.5725
    | 21 CFR 892.5725

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The BioProtect Balloon Implant System is intended to temporarily position the anterior rectal wall away from the prostate during radiotherapy for prostate cancer and in creating this space it is the intent of the BioProtect Balloon Implant System to reduce the radiation dose delivered to the anterior rectum.

    The BioProtect Balloon Implant System is composed of a balloon made of a biodegradable material that maintains the space for the entire course of prostate radiotherapy treatment and is completely absorbed by the patient's body over time.

    Device Description

    The BioProtect Balloon Implant™ System is composed of a single use, biodegradable, inflatable balloon implant, designed to act as a spacer between the prostate and the rectum. The BioProtect Balloon Implant System is supplied sterile. The balloon is implanted transperineally using transrectal ultrasound (TRUS) guidance and remains stable throughout the radiation treatment and gradually degrades over time.

    The BioProtect Balloon Implant System consists of single use components detailed below:

    1. Balloon biodegradable, inflatable balloon acts as a spacer between the prostate and rectal wall.
    2. Balloon Deployer delivery system, the balloon is mounted and folded on the deployer
    3. Delivery Kit - an applicator system used to position and deploy the balloon in the intended location. It includes an 18-gauge echogenic needle, blunt-tipped tissue dilator, and balloon introducer sheath.

    The BioProtect Balloon Implant System is for prescription use only.

    AI/ML Overview

    Here's an analysis of the provided text, focusing on the acceptance criteria and the study proving the device meets them:

    Device Name: BioProtect Balloon Implant™ System

    Indications for Use: The BioProtect Balloon Implant System is intended to temporarily position the anterior rectal wall away from the prostate during radiotherapy for prostate cancer and in creating this space it is the intent of the BioProtect Balloon Implant System to reduce the radiation dose delivered to the anterior rectum. The BioProtect Balloon Implant System is composed of a biodegradable material that maintains the space for the entire course of prostate radiotherapy treatment and is completely absorbed by the patient's body over time.


    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (from primary efficacy/safety endpoints)Reported Device Performance
    Efficacy Primary Endpoint: Reduction of at least 25% of the volume of the rectum receiving greater or equal to 70 Gy when compared to pre-implantation values, in 75% of the subjects assigned to the balloon group.97.9% of subjects gained rectal dose reduction >25% in rV70 post-implantation. Relative mean dose reduction of 84.8% of the rectum receiving 70Gy. Rectal radiation dose consistently reduced in all radiation levels (40Gy to 80Gy). Sign test p-values were <0.001 for all levels.
    Safety Primary Endpoint: Proportion of subjects with Grade 1 or greater rectal adverse events and implantation procedure-related adverse events with a duration of at least 2 days through the first six (6) months, demonstrating non-inferiority to the control group.Proportion of 18% in the Balloon Group vs. 23.1% in the Control Group, achieving the one-sided non-inferiority test for the Balloon Group (p < 0.001). No Serious Adverse Device Event (SADE) or Unanticipated Adverse Device Effect (UADE) occurred.
    Balloon Stability: Maintain stable distance between rectal wall and prostate throughout radiotherapy.Stable distance between rectal wall and prostate measured at last radiation treatment day (1.8 cm) compared to post-implantation (1.9 cm).
    Complete Degradation: Complete balloon degradation.Complete balloon degradation at 6 months demonstrated in 98.5% of subjects.
    Bladder Volume (Implicit, for context): Monitor bladder volume changes.Pre-implantation mean of 194.3cc (±128.51cc) and post-implantation mean of 231.5cc (±134.56cc) show a modest increase.
    Treatment Constraint Achievement (Implicit, for context): Ability to meet PTV and rectal/bladder constraints.No plan in the balloon group failed to meet all constraints. Significantly higher likelihood in achieving PTV and all rectal constraints (83.5% vs 57.7%) favoring the balloon arm, as well as all PTV and bladder constraints (70.5% vs 60.3%).

    Study Details

    The study that proves the device meets the acceptance criteria is a prospective, multi-center, randomized, double-arm, single blind, concurrently controlled clinical study (IDE G17020).

    1. Sample size used for the test set and the data provenance:

      • Sample Size: 222 subjects were enrolled and randomized.
      • Data Provenance: The study was a multi-center clinical study. The document does not specify the country of origin but refers to "IDE G17020," which is an FDA Investigational Device Exemption number, implying the study was conducted under FDA oversight, likely with sites in the US (though not explicitly stated). It was a prospective study.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

      • The document states that the primary safety endpoint was assessed by an independent Clinical Events Committee (CEC) blinded to subject assignment.
      • Qualifications of experts: Not specified in the provided text.
    3. Adjudication method for the test set:

      • The primary safety endpoint was assessed by an independent Clinical Events Committee (CEC), implying an adjudication process, but the specific method (e.g., 2+1, 3+1) is not explicitly detailed. The CEC's role suggests independent review and consensus on adverse events.
    4. If a multi-reader multi-case (MRMC) comparative effectiveness study was done:

      • No, an MRMC study was not done. This study was a clinical trial comparing the device (balloon + fiducial markers) to a control (fiducial markers only) in human patients for real-world clinical outcomes related to radiation dosage and adverse events, not an imaging-based assessment by multiple readers.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

      • Not applicable. This device is a physical implant, not an AI algorithm. The performance described is the device's effectiveness in a human patient setting, not the performance of an algorithm.
    6. The type of ground truth used:

      • Clinical Outcomes Data: This includes actual measurements of rectal radiation dose reduction, recorded adverse events (evaluated by an independent CEC), and physical measurements of balloon stability and degradation within patients.
    7. The sample size for the training set:

      • Not applicable for a physical medical device. "Training set" typically refers to data used to train machine learning algorithms. This was a clinical trial for a physical implant.
    8. How the ground truth for the training set was established:

      • Not applicable. As above, this concept applies to AI/ML development, not a physical medical device clinical trial.
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    K Number
    K220641
    Date Cleared
    2022-05-26

    (83 days)

    Product Code
    Regulation Number
    892.5725
    Reference & Predicate Devices
    Predicate For
    N/A
    Why did this record match?
    510k Summary Text (Full-text Search) :

    California 93101

    Re: K220641

    Trade/Device Name: Barrigel Injectable Gel Regulation Number: 21 CFR 892.5725
    Proposed Device 5.4

    Trade Name: Barrigel Injectable Gel Common/Usual Name: Barrigel Regulation Number: 892.5725
    SpaceOAR Hydrogel System, Model Number: SO-2101 Common/Usual Name: Hydrogel Spacer Regulation Number: 892.5725

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Barrigel is intended to temporarily position the anterior rectal wall away from the prostate during radiotherapy for prostate cancer and in creating this space, it is the intent of Barrigel to reduce the radiation dose delivered to the anterior rectum. Barrigel is composed of biodegradable material and maintains space for the entire course of prostate radiotherapy treatment and is intended to be absorbed by the patient's body over time.

    Device Description

    Barrigel Injectable Gel is a sterile, transparent, biodegradable gel of stabilized hyaluronic acid (HA) at a concentration of 20 mg/mL in phosphate buffered saline. The HA, formulated utilizing Q-Med's patented NASHA™ technology, is produced from non-animal hyaluronic acid by fermentation of Streptococcus species of bacteria. The HA gel is cross-linked with 1,4-butanediol diglycidyl ether (BDDE) under alkaline conditions, thereby creating ether bonds between the HA chains, resulting in a three-dimensional network. The gel is insoluble in water and organic solvents. Barrigel is supplied in a single-use glass syringe, containing 3 mL of product. Each syringe is terminally sterilized by moist heat in a heat-sealed pouch of PET/Tyvek® and packaged in a cardboard carton. Barrigel is intended for use by health-care professionals only and should be stored up to 25° C (77° F). Barrigel is manufactured for Palette Life Sciences by O-Med AB, a subsidiary of Galderma AB. The Barrigel needle is a sterile 18G stainless-steel needle, 20 cm in length, provided with an optional stylet and protected by a polyester sheath which is removed prior to use. The needle is sterilized by radiation and two (2) needles are provided in each heat-sealed pouch of PET/Tyvek®, packaged in a cardboard carton. The Barrigel needle is identical to the needle used during the Barrigel IDE study and is manufactured for Palette Life Sciences by R.K. Manufacturing.

    AI/ML Overview

    The provided text describes the acceptance criteria and study results for Barrigel Injectable Gel, an absorbable perirectal spacer.

    Here's a breakdown of the requested information:

    1. Table of Acceptance Criteria and Reported Device Performance:

    Acceptance CriteriaReported Device Performance
    Primary Effectiveness Endpoint: Achievement of a 25% reduction in the volume of the rectum receiving 90% of the prescription radiation dose. Minimally acceptable success rate established by the predicate device was 70%.98.6% of complete cases in the Barrigel group achieved at least a 25% reduction in the volume of the rectum receiving 90% of the prescription dose. The lower boundary of the 95% confidence interval (LCL) is 0.923, and the one-sided p-value is < 0.0001, demonstrating study success.
    Key Secondary Safety Objective: The Barrigel spacer does not increase the evidence of acute Grade 2+ GI toxicity within the first 3 months following treatment (non-inferiority to control group). Non-inferiority margin of 10%.The proportion of subjects with one or more acute Grade 2 or higher toxicities was 0.028 in the Barrigel group and 0.147 in the control group. The upper limit of the one-sided 95% CI (UCL) for the difference in proportions (Barrigel minus control) was -0.1189. As UCL < 0.10, Barrigel is non-inferior. Additionally, the two-sided Fisher's Exact p-value was < 0.05, indicating Barrigel was superior to control for this endpoint. Study success demonstrated.
    Biocompatibility: Meet acceptance criteria for various endpoints (Cytotoxicity, Sensitization, Irritation/Intracutaneous Reactivity, Acute Systemic Toxicity, Material Mediated Pyrogenicity, Subacute/Sub-chronic Toxicity, Genotoxicity, Implantation, Chronic Toxicity, Carcinogenicity).Barrigel met the acceptance criteria of all listed biocompatibility endpoint tests.
    Performance Testing (Bench): Meet acceptance criteria for physio/chemical characteristics (HA Content, Gel Content, Extractable Carbohydrates, Swelling Factor, pH, Particle Size Distribution, Bacterial endotoxins, Sterility, Viscoelastic Properties, Osmolality, Elemental Impurities, Residual Proteins, Enzymatic Degradation, Extrusion Force).All acceptance criteria were met, with minimal variation between production lots.
    Performance Testing (Animal): Minimal to no reaction to irradiated Barrigel compared to non-irradiated control, and complete absorption (≥ 90%) with subsided tissue reactivity.Test results demonstrated minimal to no reaction to irradiated Barrigel compared to the non-irradiated control. Barrigel Injectable Gel was considered completely absorbed per ISO 10993-6 criteria.
    Long-term Resorption: Complete resorption of the gel.From IDE G190206: Limited follow-up: 73.6% mean resorption at 18 months in 20 patients. Lack of complete resorption data for all subjects. From Goñi data (Restylane SubQ): Complete resorption at 60 months post-injection in 27 male subjects. From RPAH1 data (Restylane SubQ): Complete gel resorption for 18.5% of patients at 1-year, and 42.3% after 2 years in 36 male subjects.
    Adverse Events: No unexpected adverse device effects (UADEs) or Barrigel-related adverse events.There were no reports of unexpected adverse device effects (UADEs) or Barrigel-related adverse events in the IDE G190206 study.

    2. Sample Size Used for the Test Set and the Data Provenance:

    • IDE G190206 (Main Clinical Study):
      • The document mentions "98.6% of the complete cases in the Barrigel group" for the primary effectiveness endpoint, suggesting a test set derived from the subjects randomized to the Barrigel group. The exact number of patients in the Barrigel group that formed the "complete cases" for this analysis is not explicitly stated as a single number but would be a subset of the total enrolled subjects for IDE G190206.
      • For the key secondary safety objective, the proportion of subjects with Grade 2+ GI toxicities was 0.028 in the Barrigel group and 0.147 in the control group. The total number of subjects in each of these groups is not explicitly provided in this section but implies a comparison between the Barrigel and control groups.
      • Provenance: Prospective, multicenter study conducted over 14 study sites. Country of origin not specified, but typically US for an FDA IDE study.
    • Goñi data: 27 male subjects. Retrospective clinical study.
    • RPAH1 clinical study: 36 male subjects. Prospective clinical study.
    • Resorption Data from IDE G190206 (Table 1):
      • Immediate Post-Injection: 98 patients
      • 3-Month Visit: 96 patients
      • 12-Month Visit: 55 patients
      • 18-Month Visit: 20 patients
      • This data represents a portion of the IDE study subjects followed for resorption.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts:

    The document does not explicitly state the number of experts or their qualifications for establishing ground truth for the clinical study (IDE G190206). Outcomes like "25% reduction in the volume of the rectum receiving 90% of the prescription radiation dose" and "acute Grade 2+ GI toxicity" would be assessed by medical professionals during the study, but the specific process for establishing "ground truth" (e.g., blinded review by a panel of experts) is not detailed. The assessment of toxicity (Grade 2+ GI toxicity) would typically follow standardized grading scales (e.g., CTCAE) applied by treating physicians or study investigators.

    4. Adjudication Method for the Test Set:

    The document does not explicitly describe an adjudication method (like 2+1, 3+1, or none) for the test set's ground truth, especially for the efficacy and safety endpoints. The assessments were part of a "randomized, controlled, single-blinded multicenter study," which suggests that patients and possibly some study personnel were blinded, but the specific process for confirming the endpoints (e.g., independent review of imaging or toxicity by multiple blinded experts) is not provided.

    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. The study described is a clinical trial comparing Barrigel Injectable Gel (a physical spacer) to a control group without the spacer. It does not involve human readers using or not using AI, nor does it measure an "effect size of how much human readers improve with AI vs without AI assistance."

    6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done:

    No. Barrigel Injectable Gel is a medical device (an injectable gel), not an algorithm or AI system. Therefore, a standalone algorithm performance study is not applicable.

    7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.):

    The ground truth for the effectiveness endpoint (rectal volume reduction) was based on:

    • Pre-injection and immediate post-treatment CT and MRI scans.
    • This is based on imaging data and objective measurements.

    The ground truth for the safety endpoint (GI toxicity) was based on:

    • Clinically assessed acute Grade 2+ GI toxicity within the first 3 months following treatment.
    • This represents clinical outcomes data, likely assessed by investigators based on defined criteria (e.g., CTCAE grading).

    For resorption, it was based on:

    • Clinical data from patient visits for the IDE study (volume changes).
    • Follow-up MRIs for the Goñi data.
    • Follow-up digital rectal examinations for the RPAH1 data.

    8. The Sample Size for the Training Set:

    The document does not describe a "training set" in the context of an AI/algorithm. Barrigel is a physical medical device. The "training set" concept is typically relevant for machine learning models. The clinical study (IDE G190206) involved a patient population for evaluating the device's performance.

    9. How the Ground Truth for the Training Set Was Established:

    This question is not applicable as there is no "training set" in the context of an AI/algorithm given this product description. The ground truth for the clinical evaluation data was established as described in point 7.

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    K Number
    K202224
    Device Name
    SpaceOAR System
    Date Cleared
    2020-08-28

    (21 days)

    Product Code
    Regulation Number
    892.5725
    Reference & Predicate Devices
    Predicate For
    Why did this record match?
    510k Summary Text (Full-text Search) :

    Way MARLBOROUGH MA 01752

    Re: K202224

    Trade/Device Name: SpaceOAR System Regulation Number: 21 CFR 892.5725
    SpaceOAR Hydrogel System, Model Number: SO-2101 Common / Usual Name: Hvdrogel Spacer Regulation Number: 892.5725
    SpaceOAR Hydrogel System, Model Number: SO-2101 Common / Usual Name: Hydrogel Spacer Regulation Number: 892.5725

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    SpaceOAR System is intended to temporarily position the anterior rectal wall away from the prostate during radiotherapy for prostate cancer and in creating this the intent of SpaceOAR System to reduce the radiation dose delivered to the anterior rectum.

    The SpaceOAR System is composed of biodegradable material and maintains space for the entire course of prostate radiotherapy treatment and is completely absorbed by the patient's body over time.

    Device Description

    The SpaceOAR Hydrogel System consists of components for the preparation of a synthetic, absorbable hydrogel spacer and a delivery mechanism provided in a sterile, single use package. The SpaceOAR hydrogel is a synthetic, absorbable polyethylene glycol (PEG)based hydrogel that upon injection creates a space that temporarily positions the anterior rectal wall away from the prostate during radiotherapy for prostate cancer, and in creating this space it is the intent of the perirectal spacer to reduce the radiation dose delivered to the anterior rectum. SpaceOAR hydrogel is completely synthetic with no animal or human derived components. It is composed of biodegradable material and maintains space for the entire course of prostate radiotherapy treatment (approximately 3 months) and is completely absorbed by the patient's body over time (approximately 6 months).

    AI/ML Overview

    This submission describes a modification to an already cleared device (SpaceOAR Hydrogel System), not a new device requiring a full de novo clearance or a new 510(k) for a substantially different device. Therefore, the "acceptance criteria" and "study" described are focused on demonstrating that the modified device performs equivalently to the predicate device and does not introduce new safety or effectiveness concerns, rather than establishing efficacy of the device from scratch.

    Here's a breakdown of the requested information based on the provided text, recognizing the context of a device modification:


    Description of Acceptance Criteria and the Study Proving Device Meets Acceptance Criteria

    The acceptance criteria for the modified SpaceOAR System are implicitly defined as demonstrating that the changes do not negatively impact the device's functional and performance specifications compared to the predicate device and that it remains biologically safe.

    The study described is a series of design verification tests and assessments conducted to confirm that the modified device continues to function as intended and is substantially equivalent to the previously cleared SpaceOAR System (K181465).


    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Implicit)Reported Device Performance
    Functional and Performance Equivalence to Predicate DeviceVerified through repetition of design verification tests, confirming the modified device meets the same functional and performance specifications as the predicate.
    - Sterilization Validation"Sterilization Validation" was repeated and confirmed.
    - Shelf Life Testing"Shelf Life Testing" was repeated and confirmed.
    - System Needle to Hub Tensile Strength"System Needle to Hub Tensile Strength" was repeated and confirmed.
    - Fluid Connection"Fluid Connection" was repeated and confirmed.
    - SpaceOAR Hydrogel System Prep and Assembly Time"SpaceOAR Hydrogel System Prep and Assembly Time" was repeated and confirmed.
    - PEG Vial Puncture Force"PEG Vial Puncture Force" was repeated and confirmed.
    - Packaging Performance Testing"Packaging Performance Testing" was repeated and confirmed.
    Biological Safety Equivalence"A risk-based biocompatibility assessment of these limited changes indicates that no new biocompatibility testing is required to assess the proposed device change. The proposed SpaceOAR System is biologically safe for its intended use." This implies the acceptance criterion of not introducing new biocompatibility risks was met.
    No New Issues of Safety or Effectiveness"The conclusion of the assessments demonstrates that the modified device continues to function as intended in a manner equivalent to the predicate device. The modified device raises no new issues of safety or effectiveness compared to the predicate." This is the overarching conclusion related to meeting general safety and effectiveness acceptance criteria for device modifications.

    2. Sample Size Used for the Test Set and the Data Provenance

    The document does not explicitly state the specific sample sizes for each of the repeated design verification tests (e.g., number of units tested for tensile strength, shelf life, etc.). It only mentions that the tests were "repeated."

    Data Provenance: The testing appears to be internal design verification and validation testing conducted by Boston Scientific Corporation. The provenance is internal company data, not clinical data from external sources.


    3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts

    Not applicable. This device modification submission relies on engineering design verification and validation testing to demonstrate equivalence, not on expert-adjudicated clinical ground truth for a test set. Clinical data and expert ground truth were not used for this specific submission given the "limited changes to device components, packaging and labeling."


    4. Adjudication Method for the Test Set

    Not applicable. As noted in point 3, this was not a clinical study requiring expert adjudication of a test set. The assessment relied on a risk analysis to determine the necessary verification tests.


    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. The SpaceOAR System is a medical device (hydrogel spacer), not an AI-powered diagnostic or assistive technology for human readers. Therefore, an MRMC study comparing human readers with and without AI assistance is irrelevant to this submission.


    6. If a Standalone (i.e. algorithm only, without human-in-the-loop performance) Was Done

    Not applicable. The SpaceOAR System is a physical medical device, not an algorithm, so standalone algorithm performance is not relevant.


    7. The Type of Ground Truth Used

    For this specific submission (device modification), the "ground truth" is essentially the established performance specifications and safety profile of the predicate device (K181465). The "study" aims to verify that the modified device continues to meet these same engineering specifications and does not introduce new safety concerns.


    8. The Sample Size for the Training Set

    Not applicable. This submission concerns a physical medical device and its manufacturing/component changes, not a machine learning model that requires a training set.


    9. How the Ground Truth for the Training Set Was Established

    Not applicable. As noted in point 8, there is no training set for a machine learning model in this submission.

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    K Number
    K182971
    Manufacturer
    Date Cleared
    2019-07-19

    (266 days)

    Product Code
    Regulation Number
    892.5725
    Reference & Predicate Devices
    Predicate For
    N/A
    Why did this record match?
    510k Summary Text (Full-text Search) :

    Building BEDFORD MA 01730

    Re: K182971

    Trade/Device Name: SpaceOAR Vue Hydrogel Regulation Number: 21 CFR 892.5725

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    SpaceOAR Vue Hydrogel is intended to temporarily position the anterior rectal wall away from the prostate during radiotherapy for prostate cancer and in creating this space it is the intent of SpaceOAR Vue Hydrogel to reduce the radiation dose delivered to the anterior rectum. The SpaceOAR Vue Hydrogel is composed of biodegradable material and maintain space for the entire course of prostate radiotherapy treatment and is completely absorbed by the patient's body over time.

    Device Description

    The SpaceOAR Vue Hydrogel consists of components for the preparation of a synthetic, absorbable hydrogel spacer and a delivery mechanism provided in a sterile, single use package. The SpaceOAR Vue Hydrogel is a synthetic, absorbable polyethylene glycol (PEG)-based hydrogel that upon injection creates a space that temporarily positions the anterior rectal wall away from the prostate during radiotherapy for prostate cancer and in creating this space it is the intent of the perirectal spacer to reduce the radiation dose delivered to the anterior rectum. SpaceOAR Vue Hydrogel is completely synthetic with no animal or human derived components. It is composed of biodegradable material and maintains space for the entire course of prostate radiotherapy treatment (approximately 3 months) and is completely absorbed by the patient's body over time (about 6 months).

    The SpaceOAR Vue Hydrogel consists of two syringes containing the PEG Precursor solution and the Accelerator solution (a buffered salt solution). The Precursor solution is formed by the user through the reconstitution of PEG powder with a Diluent (Trilysine buffer) solution (that is provided in a third syringe). The Accelerator solution is provided ready for use. The Syringes filled with the Precursor solution and the Accelerator solution are assembled with other applicator components, including a Y-connector for mixing the Precursor and Accelerator, and a needle to facilitate delivery of the hydrogel by injection to the tissue located between the anterior rectal wall and the prostate.

    AI/ML Overview

    The provided document does not contain acceptance criteria for device performance or a study that specifically proves the device meets such criteria in terms of clinical outcomes or reader performance.

    The document is a 510(k) summary for the SpaceOAR Vue Hydrogel. It focuses on demonstrating substantial equivalence to a legally marketed predicate device (SpaceOAR® Hydrogel System) rather than presenting a de novo clinical study with specific performance metrics for the new device.

    Here's what can be extracted based on the provided text, addressing your questions where possible:

    1. A table of acceptance criteria and the reported device performance

    No explicit table of acceptance criteria with numerical performance targets (e.g., sensitivity, specificity, accuracy) for clinical effectiveness is provided in the document. The performance data section lists types of testing performed, but not the specific acceptance criteria or results for each beyond stating that "The subject device has met the same device specifications as the predicate device."

    Acceptance Criteria CategoryReported Device Performance
    Sterilization ValidationMet requirements
    Modulus TestingMet requirements
    Gel Volume (Swell) TestingMet requirements
    Gel Time TestingMet requirements
    Pot Life TestingMet requirements
    Usability TestingMet requirements
    Biocompatibility TestingMet requirements
    Preclinical TestingMet requirements
    Overall Device SpecificationMet the same finished device specifications as the predicate device

    2. Sample size used for the test set and the data provenance

    The document does not detail a "test set" in the context of clinical performance or image interpretation. The testing mentioned in Section VII ("PERFORMANCE DATA") appears to be primarily related to engineering, material science, and safety testing of the device itself (e.g., sterilization, gel properties, usability, biocompatibility, preclinical testing). Therefore, information on sample size for a test set (e.g., patient cases) or data provenance (country of origin, retrospective/prospective) is not available.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    This information is not provided as the submission focuses on substantial equivalence based on technical characteristics and predicate device performance, not a new clinical study assessing image interpretation or a specific disease outcome requiring expert ground truth establishment.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    Not applicable, as no clinical test set requiring adjudication by experts is described.

    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 is mentioned. This device is a hydrogel spacer, not an AI-powered diagnostic tool, so the concept of human readers improving with AI assistance is not relevant to this submission.

    6. If a standalone (i.e. algorithm only, without human-in-the-loop performance) was done

    This question is not applicable. The device is a physical hydrogel spacer used in conjunction with radiotherapy, not a standalone algorithm.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    The document does not describe a clinical study that would require "ground truth" in the sense of comparing device output to a definitive diagnosis. The device's primary function is to physically create space and reduce radiation dose, which would be evaluated through physical properties and radiation dosimetry, not diagnostic accuracy.

    8. The sample size for the training set

    The document does not describe a training set. This is not an AI/machine learning device.

    9. How the ground truth for the training set was established

    Not applicable, as there is no training set for an AI/machine learning algorithm.

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    K Number
    K181465
    Device Name
    SpaceOAR System
    Manufacturer
    Date Cleared
    2018-06-25

    (21 days)

    Product Code
    Regulation Number
    892.5725
    Reference & Predicate Devices
    Predicate For
    Why did this record match?
    510k Summary Text (Full-text Search) :

    BEDFORD MA 01730

    Re: K181465

    Trade/Device Name: SpaceOAR Hydrogel System Regulation Number: 21 CFR 892.5725

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    SpaceOAR Hydrogel System is intended to temporarily position the anterior rectal wall away from the prostate during radiotherapy for prostate cancer and in creating this space it is the intent of SpaceOAR Hydrogel System to reduce the radiation dose delivered to the anterior rectum. The SpaceOAR Hydrogel System is composed of biodegradable material and maintains space for the entire course of prostate radiotherapy treatment and is completely absorbed by the patient's body over time.

    Device Description

    The SpaceOAR® Hydrogel System consists of components for the preparation of a synthetic, absorbable hydrogel spacer and a delivery mechanism provided in a sterile, single use package. The SpaceOAR® hydrogel is a synthetic, absorbable polyethylene glycol (PEG)-base hydrogel that upon injection creates a space that temporarily positions the anterior rectal wall away from the prostate during radiotherapy for prostate cancer and in creating this space it is the intent of the perirectal spacer to reduce the radiation dose delivered to the anterior rectum. SpaceOAR® hydrogel is completely synthetic with no animal or human derived components. It is composed of biodegradable material and maintains space for the entire course of prostate radiotherapy treatment (approximately 3 months) and is completely absorbed by the patient's body over time (about 6 months).

    The SpaceOAR® Hydrogel System consists of two syringes containing the PEG Precursor solution and the Accelerator solution (a buffered salt solution). The Precursor solution is formed by the user through the reconstitution of PEG powder with a Diluent (Trilysine buffer) solution (that is provided in a third syringe. The Accelerator solution is provided ready for use. The Syringes filled with the Precursor solution and the Accelerator solution are assembled with other applicator components, including a Yconnector for mixing the Precursor and Accelerator, and a needle to facilitate delivery of the hydrogel by injection to the tissue located between the anterior rectal wall and the prostate.

    AI/ML Overview

    This document is an FDA 510(k) summary for the SpaceOAR Hydrogel System. It is primarily focused on demonstrating substantial equivalence to a previously cleared predicate device, rather than providing detailed acceptance criteria and study results for a new device's performance.

    Therefore, many of the requested items (e.g., sample size for test set, number of experts for ground truth, MRMC study, training set details) are not present in this type of FDA submission. The submission relies on the established performance of the predicate device.

    Here's an analysis based on the provided text:

    1. A table of acceptance criteria and the reported device performance

    The document states: "The subject SpaceOAR® Hydrogel System met all acceptance criteria for verification and validation." However, it does not list specific quantitative acceptance criteria or their corresponding performance results in a table format. It only lists categories of tests performed.

    Acceptance Criteria CategoryReported Device Performance
    Sterilization ValidationMet all acceptance criteria
    Modulus TestingMet all acceptance criteria
    Gel Volume (Swell) TestingMet all acceptance criteria
    Gel Time TestingMet all acceptance criteria
    Pot Life TestingMet all acceptance criteria
    Endotoxin TestingMet all acceptance criteria

    2. Sample size used for the test set and the data provenance

    The document does not specify a sample size for a "test set" or provide data provenance in the context of clinical performance for the subject device. The submission relies on equivalence to a predicate device. The performance data listed (sterilization, modulus, etc.) are engineering/laboratory tests.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    This information is not provided as the submission does not detail a clinical study with a "test set" requiring expert ground truth in the traditional sense of diagnostic AI or imaging device evaluation.

    4. Adjudication method for the test set

    This information is not provided for the reasons stated above.

    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

    An MRMC comparative effectiveness study was not mentioned or provided in this 510(k) summary. This type of study is typically for diagnostic imaging devices and AI systems, not for a physical implantable device like a hydrogel spacer.

    6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done

    This concept is not applicable to the SpaceOAR Hydrogel System, which is a physical medical device and not an algorithm.

    7. The type of ground truth used

    For the engineering/laboratory tests listed (Sterilization Validation, Modulus Testing, etc.), the "ground truth" would be established by pre-defined engineering specifications and validated test methods. The submission implies that the results of these tests (e.g., sterilization effectiveness, material properties like modulus, gel volume, gel time, pot life, endotoxin levels) adhered to these specifications.

    8. The sample size for the training set

    This information is not applicable/not provided as this is a physical device, not an algorithm that requires a training set.

    9. How the ground truth for the training set was established

    This information is not applicable/not provided as this is a physical device.


    Summary of Device Performance (based on this 510(k) summary):

    The 510(k) application for the SpaceOAR Hydrogel System (K181465) demonstrates substantial equivalence to its predicate device (cleared under DEN140030). The core argument is that the subject device has identical design, materials, and sterilization cycle to the predicate device.

    To support this claim, the manufacturer performed several verification and validation tests:

    • Sterilization Validation: Confirmed the device's sterility.
    • Modulus Testing: Evaluated the material's stiffness/elasticity.
    • Gel Volume (Swell) Testing: Assessed how much the hydrogel swells.
    • Gel Time Testing: Measured the time it takes for the components to form a gel.
    • Pot Life Testing: Determined how long the mixed components remain viable for use.
    • Endotoxin Testing: Ensured the absence of harmful bacterial endotoxins.

    The document explicitly states: "The subject device is identical to the predicate device in design, materials and sterilization cycle; therefore, biocompatibility testing, shelf life testing, and clinical data were not required to support a determination of substantial equivalence." This means that the clinical performance and safety of the device are inferred from the predicate device, and the current submission focuses on verifying the manufacturing and design equivalence of the new device to the existing one. The "acceptance criteria" here largely pertain to meeting the engineering specifications and demonstrating manufacturing consistency with the already-cleared device.

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    K Number
    DEN140030
    Device Name
    SpaceOAR System
    Manufacturer
    Date Cleared
    2015-04-01

    (182 days)

    Product Code
    Regulation Number
    892.5725
    Type
    Direct
    Reference & Predicate Devices
    N/A
    Predicate For
    N/A
    Why did this record match?
    510k Summary Text (Full-text Search) :

    .

    NEW REGULATION NUMBER: 21 CFR 892.5725

    CLASSIFICATION: II

    PRODUCT CODE: OVB

    BACKGROUND

    OVB Device Type: Absorbable perirectal spacer Class: Class II (special controls) Regulation: 21 CFR 892.5725

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    SpaceOAR System is intended to temporarily position the anterior rectal wall away from the prostate during radiotherapy for prostate cancer and in creating this space it is the intent of SpaceOAR System to reduce the radiation dose delivered to the anterior rectum. The SpaceOAR System is composed of biodegradable material and maintains space for the entire course of prostate radiotherapy treatment and is completely absorbed by the patient's body over time.

    Device Description

    SpaceOAR System is a polyethylene glycol (PEG) hydrogel that upon injection creates a space that temporarily positions the anterior rectal wall away from the prostate during radiotherapy for prostate cancer with the intent to reduce the radiation dose delivered to the anterior rectum. The SpaceOAR System consists of components for the preparation of a synthetic, absorbable hydrogel spacer and a delivery mechanism provided in a sterile, single use package. Once assembled as shown in the figure above, the Y-connector allows for hydrogel injection via an 18 gauge needle. The spacer is formed by mixing two solutions, the Precursor and the Accelerator. The Precursor solution is formed through the mixing of the Diluent solution (Trilysine buffer solution) with the PEG powder. The Accelerator solution is a salt buffer solution.

    AI/ML Overview

    This document describes the regulatory decision for the SpaceOAR System, an absorbable perirectal spacer. It outlines the acceptance criteria (defined as "Special Controls" by the FDA) and summarizes the study used to demonstrate the device meets these criteria.

    Acceptance Criteria and Reported Device Performance

    The FDA's special controls serve as the acceptance criteria for the absorbable perirectal spacer. The device's performance, as reported in the clinical study, is summarized below:

    Acceptance Criteria (Special Controls)Reported Device Performance and Evidence
    1. Non-clinical and Clinical Performance TestingBased on independent Core Lab measurements, 97.3% [95% CI: 93.2, 99.3] of SpaceOAR treated subjects achieved a >25% reduction in rV70. Clinical results showed that the primary effectiveness hypothesis was met (percent of SpaceOAR subjects with 25% reduction in dose in the rectal V70 region was > 70% with statistical significance, p<0.0001). The study results support that SpaceOAR increased the space between the prostate and rectum and resulted in less radiation in the rectal area. There were no device-related serious adverse events.
    (i) Performance bench testing must demonstrate appropriate perirectal space creation and maintenance for the duration of prostate radiotherapy.Bench tests (gel time, pot life, swelling, in vitro disappearance) were conducted on final, finished, sterilized devices, often exposed to worst-case irradiation, to assess functional performance. Animal studies demonstrated simple injection and hydrogel space maintenance through 13 weeks (sufficient for radiotherapy).
    (ii) Performance bench testing must demonstrate that therapeutic radiation levels do not alter the performance of the device.Bench tests were performed on final manufactured product, often exposed to worst-case irradiation prior to testing. Animal studies demonstrated no effect on local tissue response due to irradiation.
    (iii) Performance in vivo testing must demonstrate appropriate deployment of spacer as indicated in the accompanying labeling, and demonstrate appropriate expansion and absorption characteristics in a clinically relevant environment.Animal studies successfully demonstrated SpaceOAR System product specifications, specifically gel time, pot life, and swelling. They also showed that the hydrogel completely absorbs in vivo. The clinical study demonstrated deployment via injection and subsequent reduction in rectal radiation dose. The hydrogel maintains space for approximately 3 months and is completely absorbed via hydrolysis (renal filtration) in approximately 6 months.
    (iv) Clinical study must demonstrate appropriate spacer stability and lack of migration for the entire course of radiotherapy, complete absorption, and lack of long-term toxicity.The clinical study indicated that the device remained in place, leading to a sustained reduction in rectal radiation. The hydrogel is designed to maintain space for approximately 3 months (the duration of radiotherapy) and then completely absorb within 6 months. Long-term follow-up from European and US clinical trials and post-market AE data on over 2600 SpaceOAR systems did not record any AE's or complications related to persistent hydrogel or long-term safety issues. There were no CTCAE Grade 3 or Grade 4 procedural or rectal events.
    (v) Sterility testing must demonstrate the sterility of the device and the effects of the sterilization process on the physical characteristics of the spacer.Sterilization is performed via (b)(4) contract sterilization facility to a Sterility Assurance Level (SAL) of 1x10. Sterility was validated in accordance with ISO 11137-2. The clinical study reported no incidences of infections associated with the device.
    (vi) Shelf-life testing must demonstrate the stability of the physical characteristics of the spacer throughout the shelf-life as indicated in the accompanying labeling.Functionality testing was performed on SpaceOAR System devices following irradiation and storage under specified conditions. This testing supports a 24-month shelf life.
    (vii) The device must be demonstrated to be biocompatible.Biocompatibility testing was performed on both the hydrogel and non-patient contacting components consistent with ISO 10993-1. Results demonstrated the product is non-cytotoxic, non-irritating, non-sensitizing, non-mutagenic, and elicits no acute or sub-acute systemic toxicity. Animal studies confirmed local and systemic compatibility with no signs of toxicity.
    2. Risk Management Activities (end-user initial training program for proper spacer deployment technique)The labeling includes detailed instructions for system preparation, assembly, positioning, and injection, along with guidance on ultrasound imaging and preventing rectal wall penetration. Note: The document explicitly states the requirement for an end-user training program in the Special Controls, but does not detail the implementation or evaluation of such a program in the provided study summary.
    3. Device Labeling Requirements (summary of complications, warnings, detailed instructions, expiration date)The labeling is consistent with clinical data and covers hazards, warnings, contraindications, and other relevant information. It includes detailed instructions, warnings on transrectal administration, precautions for implantation, observed injection failures, potential complications, and mitigation strategies. An expiration date supported by performance data is included. Note: The document confirms the content of the labeling meets the requirements, rather than describing a study to prove adherence to these labeling controls.

    Study Information

    The acceptance criteria are addressed by the results of a prospective, randomized, parallel-arm, multicenter clinical study and various non-clinical (bench and animal) studies.

    1. A table of acceptance criteria and the reported device performance:
    See table above.

    2. Sample size used for the test set and the data provenance:

    • Clinical Study (Test Set):
      • Total Randomized: 222 subjects
      • Treatment Group (SpaceOAR): 149 subjects
      • Control Group (No Spacer): 73 subjects
      • Data Provenance: The study was conducted at 20 investigational sites in the United States. It was a prospective study.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    • The clinical study mentions that "All adverse events were reviewed by an independent Clinical Events Committee (CEC)."
    • It also states: "Based on independent Core Lab measurements, 97.3% [95% CI: 93.2, 99.3] of SpaceOAR treated subjects achieved a >25% reduction in rV70."
    • The specific number and qualifications of experts for the CEC or Core Lab are not detailed in the provided text.

    4. Adjudication method for the test set:

    • Adverse events were reviewed by an independent Clinical Events Committee (CEC). This suggests an adjudication process, but the specific rules (e.g., majority vote, single expert decision, etc.) for the CEC are not described.
    • Rectal V70 reduction measurements were assessed by an independent Core Lab, implying expert review and calculation, but the details of their adjudication (if any across multiple readers) are not provided.

    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 was not an MRMC comparative effectiveness study involving human readers and AI assistance.
    • This study was a head-to-head comparison of a physical medical device (SpaceOAR System) versus a control group (no spacer) in the context of prostate cancer radiation therapy, focusing on the device's ability to reduce rectal radiation dose and associated adverse events. It does not involve AI or human interpretation performance.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

    • No, this is not applicable. The SpaceOAR System is a physical medical device (a hydrogel spacer), not an algorithm or AI system. Therefore, standalone algorithm performance was not relevant or assessed.

    7. The type of ground truth used:

    • Clinical Outcomes/Measurements:
      • Primary Effectiveness Endpoint: Percentage of subjects achieving a >25% reduction in rV70 (rectal volume receiving at least 70Gy). This was measured via "independent Core Lab measurements" and "investigator measurements," which rely on medical imaging (likely CT scans used for treatment planning) and calculation of radiation dose distribution.
      • Primary Safety Endpoint: Proportion of subjects with Grade 1 or greater rectal adverse events or procedure adverse events through 6 months. This was based on clinical assessment of adverse events reviewed by an independent Clinical Events Committee.
      • Secondary Endpoints included incidence of CTCAE Grade 1 or greater or Grade 2 or greater rectal or procedural events, changes in EPIC Urinary and Sexual domains, and medication changes.
    • Non-clinical Ground Truth: Bench testing used predefined performance specifications (e.g., gel time, pot life, swelling, in vitro disappearance). Animal studies used observations of hydrogel behavior, tissue response, and absorption.

    8. The sample size for the training set:

    • Not applicable in the conventional sense for an AI/algorithm. The clinical study described is the primary clinical evidence for the device's effectiveness and safety, not a training set for an algorithm.
    • However, the document does mention "long term follow up from the European and US clinical trials and post market AE data on over 2600 SpaceOAR System since CE Mark approval in 2010 and Australian TGA approval in 2011" as additional supporting evidence for safety, particularly regarding long-term toxicity which could be considered a form of real-world "training" or validation data if one were to stretch the analogy. This data was not described as a formal training set for an algorithm.

    9. How the ground truth for the training set was established:

    • Not applicable, as there was no AI/algorithm training set. The clinical study formed the basis for establishing the device's performance against its intended use and safety profile through rigorous scientific methodology (randomized controlled trial with pre-defined endpoints and independent review).
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