(128 days)
The Excalibur Light Therapy System is a non-heating lamp, infrared as described under the provisions of 21 CFR §890.5500 and is clinically indicated for: Adjunctive use in providing temporary relief of minor chronic neck and shoulder pain i of musculoskeletal origin.
The Excalibur Light Therapy System is a band-held, non-invasive, pain therapy system which utilizes non-heating lamps consisting of two laser diodes in one applicator head. It combines the clinically accepted therapeutic treatment of numerous predicate light therapy systems currently in commercial distribution and 510(k) cleared. The system consists of a basic hand-held, battery operated control unit and a permanently attached applicator head. The laser operates at a measured wavelength of 635mm (±1%) and complies with all performance, labeling, and manufacturing standards set forth in 21CFR Part 1040. Stargate International, Inc. is a registered laser manufacturer with the Food and Drug Administration. The laser applicator head produces an output power of ≤4.5mw2 measured, per non-convergent beam and is classified as a Class IIIa laser.
The provided text describes the Excalibur Light Therapy System and its predicate devices, focusing on demonstrating substantial equivalence. However, it does not contain information about formal acceptance criteria or a study designed to specifically prove the device meets such criteria through clinical performance metrics (like sensitivity, specificity, accuracy, or effect sizes).
Instead, the submission relies on demonstrating substantial equivalence to existing predicate devices (Tuco Erchonia PL3000 and Quantum System) based on:
- Identical Intended Use: "Adjunctive use in providing temporary relief of minor chronic neck and shoulder pain of musculoskeletal origin."
- Similar Technological Characteristics: Wavelength (635nm), power output (≤4.5mW), and the use of Gallium Aluminum Arsenide (GaAlAs) diodes with non-convergent beams.
- Compliance with Standards: FCC, UL, and Class IIIa Laser (21CFR Part 1040).
- Functional Performance, Electrical Safety, and Component Specification Testing: This refers to engineering and manufacturing tests, not clinical performance studies.
Therefore, many of the requested fields cannot be filled as they pertain to clinical validation studies, which were not performed or reported in this 510(k) summary.
Here's a breakdown of the available information based on your request:
1. Acceptance Criteria and Reported Device Performance
The document does not explicitly state "acceptance criteria" in terms of clinical performance metrics (e.g., "device must achieve X% pain reduction in Y% of patients"). Instead, the "acceptance criteria" for this 510(k) appear to be demonstrating substantial equivalence to predicate devices based on:
| Characteristic | Acceptance Criterion (Implied by Substantial Equivalence) | Reported Device Performance (Excalibur) |
|---|---|---|
| Intended Use | Same as predicate devices: adjunctive use in providing temporary relief of minor chronic neck and shoulder pain of musculoskeletal origin. | The Excalibur Light Therapy System has the identical intended use as the predicate devices: "Adjunctive use in providing temporary relief of minor chronic neck and shoulder pain of musculoskeletal origin." |
| Technological Characteristics | Similar to predicate devices in wavelength, power output, and mechanism (LLLT). Will provide same treatment benefits/regimens as cleared predicate devices. | Uses two laser diodes in one applicator head. Operates at a measured wavelength of 635nm (±1%). Produces an output power of ≤4.5mW per non-convergent beam. Uses Gallium Aluminum Arsenide (GaAlAs) diodes with non-convergent beam output to emit visible photonic energy. Variables (frequency, wavelength, time, power output) conform to predicate device parameters. Classified as a Class IIIa laser. |
| Safety and Standards | Compliance with relevant electrical, laser, and manufacturing standards. | Manufactured, performs, is labeled, and is tested to comply with: FCC Standard - 47CFR Part 15B, All Electrical Components Utilized Are UL® Approved, Class IIIa Laser 21CFR Part 1040. System testing includes functional performance, electrical safety, and component specification, including four-staged manufacturing testing and verification. No software incorporated. |
| Clinical Efficacy | No new regulatory, safety, and/or clinical efficacy issues are raised compared to predicate devices. | "The Excalibur System will provide the same treatment benefits and regimens for clinical presentations already cleared by the Food and Drug Administration for the predicate devices." "The performance parameters and intended use of the Excalibur Light Therapy System are identical to all predicate devices." "The Excalibur Light Therapy System is manufactured and performs as intended and does not raise any new regulatory, safety, and/or clinical efficacy issues." These claims are based on equivalence to predicate substantial devices. |
2. Sample size used for the test set and the data provenance
- Sample Size for Test Set: Not applicable. No clinical test set data is provided or referenced for this device (Excalibur). The submission relies on the clinical data supporting the predicate devices.
- Data Provenance: Not applicable for this device's clinical performance. The 510(k) refers to "clinically accepted therapeutic uses" and "clinical parameters used by the predicate devices," implying the provenance is from studies previously submitted and reviewed for the predicate devices.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Not applicable. No ground truth for a clinical test set for this device is established or reported.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable. No clinical test set.
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 a light therapy system, not an AI-assisted diagnostic or therapeutic tool with human readers.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not applicable. This device is a physical light therapy system. There is no algorithm or AI component. The document explicitly states: "There is no software incorporated into the operation of the Excalibur Light Therapy System."
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
- Not applicable for this device. The efficacy of the underlying technology (Low Level Laser Therapy for pain relief) is implicitly accepted based on the prior clearance of the predicate devices. The "ground truth" for the predicate devices' efficacy would have been established through clinical studies, likely using patient-reported outcomes (e.g., pain scales, functional assessments). However, such data is not provided for Excalibur.
8. The sample size for the training set
- Not applicable. There is no AI or machine learning component requiring a training set.
9. How the ground truth for the training set was established
- Not applicable. There is no AI or machine learning component requiring a training set with ground truth.
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K041530 1/3
510(k) Summary
(as required por 21CFR; §807.92)
Excalibur Light Therapy System
OCT 1 4 2004
| 1. Applicant | Stargate International, Inc. |
|---|---|
| 10235 South Progress Way #7 | |
| Parker, CO 80134 | |
| Phone: 303-840-8206 | |
| Fax: 303-840-8320 |
| II. Contact Name: | Robert H. Walker; CEOrwalker@stargateinternational.com |
|---|---|
| ------------------- | ------------------------------------------------------------ |
III. Device Name
| Proprietary Name | Excalibur Light Therapy System |
|---|---|
| Common/Usual Name (s) | Low Level Laser Therapy (LLLT) |
| Therapeutic Light System | |
| Classification Name | Infrared Lamp; (21CFR; §890.5500) |
| Product Code | NHN |
IV. Predicate Device/Substantial Equivalency
The Excalibur Light Therapy System is substantially equivalent to other pulsed low level therapeutic lasers and light therapy systems currently in commercial distribution. The Excalibur Light Therapy System has the same intended use and similar tochnological characteristics to predicate devices. It combines the clinically accepted therapcutic uses of previously FDA 510(k) approved light therapy systems currently in commercial distribution into onc compact and cost-effective system.
The technological equivalence to the predicate devices is substantiated by the wavelength and power output generated by the one Excalibur System applicator head permanently attached to the basic unit. The Excalibur System will provide the same treatment benefits and regimens for clinical presentations already cleared by the Food and Drug Administration for the predicate devices.
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K041530 2/3
The predicate devices the Excalibur System establishes equivalence to include the following:
| Predicate Device | 510(k) # | Manufacturer |
|---|---|---|
| Tuco Erchonia PL3000 ......................... | K012580 | Tuco Innovations |
| Quantum System ......................... | K032816 | Stargate International |
V. Intended Use of the Device
The Excalibur Light Therapy System is a non-heating lamp, infrared as described under the provisions of 21 CFR $890.5500 and is clinically indicated for:
- Adjunctive use in providing temporary relief of minor chronic neck and shoulder pain i of musculoskeletal origin.
As with the predicate device, pain therapy treatment can be prescribed for pain associated with with the clinical presentation specified above by having the beams pulsed or continuous with time considerations. The Excalibur Light Therapy System's variables conform to the performance specifications of the clinical parameters used by the predicate devices in frequency, wavelength, time, and power output.
VI. Description of the Device
The Excalibur Light Therapy System is a band-held, non-invasive, pain therapy system which utilizes non-heating lamps consisting of two laser diodes in one applicator head. It combines the clinically accepted therapeutic treatment of numerous predicate light therapy systems currently in commercial distribution and 510(k) cleared.
The system consists of a basic hand-held, battery operated control unit and a permanently attached applicator head. The laser operates at a measured wavelength of 635mm (±1%) and complies with all performance, labeling, and manufacturing standards set forth in 21CFR Part 1040. Stargate International, Inc. is a registered laser manufacturer with the Food and Drug Administration.
The laser applicator head produces an output power of ≤4.5mw2 measured, per non-convergent beam and is classified as a Class IIIa laser.
VII. Summary of Technical Characteristics of the Device To Referenced Predicate Devices
The Excalibur Light Therapy System and the aforementioned predicate devices use Gallium Aluminum Arsenide (GaAlAs) diodes with non-convergent beam output to emit visible photonic energy to human tissue. The technology is dependent on the laws of physics in that the variables are frequency, wavolongth, power output, and time.
The performance parameters and intended use of the Excalibur Light Therapy System are identical to all predicate devices.
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K041530 3/3
VIII. System Testing
The testing of the Excalibur Light Therapy System includes functional performance, electrical safety, and component specification. This includes four-staged manufacturing testing and verification.
There is no software incorporated into the operation of the Excalibur Light Therapy System.
The Excalibur Light Therapy System is manufactured, performs, is labeled, and is tested to comply with the following standards:
- . FCC Standard - 47CFR Part 15B
- All Electrical Components Utilized Are UL® Approved ●
- Class IIIa Laser 21CFR Part 1040. .
IX. Conclusions
In accordance with testing and comparison to the predicate devices, and pursuant to 21CFR; §890.500, the Excalibur Light Therapy System has the same intended use, with similar functional and performance characteristics.
The device meets or exceeds the design, testing, and labeling standards required by law. The Excalibur Light Therapy System is manufactured and performs as intended and does not raise any new regulatory, safety, and/or clinical efficacy issues.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/3/Picture/1 description: The image is a circular seal or logo. The seal contains the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the top half of the circle. In the center of the circle is a stylized emblem that resembles an eagle or bird with three wing-like shapes and a flowing tail.
Public Health Service
OCT 1 4 2004
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
Mr. Robert H. Walker Chief Executive Officer Stargate International, Inc. 10235 South Progress Way, #7 Parker, Colorado 80134
Re: K041530
Trade/Device Name: Excalibur Light Therapy System Regulation Number: 21 CFR 890-5500 Regulation Name: Lamp, non-heating for adjunctive use in pain therapy Regulatory Class: II Product Code: NHN Dated: September 3, 2004 Received: September 7, 2004
Dear Mr. Walker:
We have reviewed your Section 510(k) premarket notification of intent to market the device wt have reviewed your became in ad the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate for use stated in the encreated of the enactment date of the Medical Device Amendments, or to conniner by provision in accordance with the provisions of the Federal Food, Drug, de vices that have been require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The r ou may, incress, while Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it rr your device to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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Page 2 - Mr. Robert H. Walker
This letter will allow you to begin marketing your device as described in your Section 510(k) I his letter will anow you to begin mailioning of substantial equivalence of your device to a legally premarket notification: The PDF mailing of cation for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please If you desire specific advice for your 240) 276-0115. Also, please note the regulation entitled, Colliact the Office of Compremarket notification" (21CFR Part 807.97). You may obtain other general information on your responsibilities under the Act from the Division of Small other general information on your response Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html
Sincerely yours,
Miriam C. Provost
Celia M. Witten, Ph.D., M.D. Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Indications For Use
K041530 510(k) Number (if known):
Device Name: Excalibur Light Therapy System
The Excalibur Light Therapy System is a non-heating lamp, infrared as Indications For Use: described under the provisions of 21 CFR §890.5500 and is indicated for:
Adjunctive use in providing temporary relief of minor chronic neck and shoulder pain of musculoskeletal origin.
Prescription Use (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use_ (21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Muriam C. Provost
(Division Sign-Off) Division of General, Restorative, and Neurological Devices
510(k) Number K041530
Page 10 - Excalibur 510(k) dated June 4, 2004
§ 890.5500 Infrared lamp.
(a)
Identification. An infrared lamp is a device intended for medical purposes that emits energy at infrared frequencies (approximately 700 nanometers to 50,000 nanometers) to provide topical heating.(b)
Classification. Class II (special controls). The device, when it is an infrared therapeutic heating lamp, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 890.9.