(148 days)
The ActiTrainer is a small worn activity monitor designed for documenting physical movement associated with applications in physiological monitoring. The device is intended to monitor the activity associated with movement during sleep. The ActiTrainer can be used to analyze circadian rhythms and assess activity in any instance where quantifiable analysis of physical motion is desirable.
The ActiTrainer is housed in a polycarbonate plastic housing. It is 8.5 cm long by 3.4 cm wide by 1.6 cm thick and it weights 51 grams. It also has an optional Polar heart strap. Data is downloaded into a PC via a USB plug and the data is displayed with ActiGraph LLC's ActiLife software.
This document describes the ActiTrainer, an activity monitor, and its substantial equivalence to a predicate device, the Actigraph. However, it does not contain a study that quantitatively proves the device meets specific acceptance criteria with numerical performance values for parameters like sensitivity, specificity, accuracy, or other commonly used metrics in medical device studies.
Instead, the document focuses on demonstrating substantial equivalence based on technological characteristics and intended use, which is a common pathway for 510(k) clearance.
Therefore, many of the requested sections regarding acceptance criteria and performance study details cannot be fully answered from the provided text.
Here is an attempt to answer based on the information available:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly state numerical acceptance criteria. Instead, the "acceptance criterion" for 510(k) clearance is demonstrating substantial equivalence to a predicate device in terms of intended use and technological characteristics. The performance is assessed by comparing the ActiTrainer's specifications to those of the Actigraph (K040554).
| Parameter | Acceptance Criteria (Predicate Actigraph - K040554) | Reported Device Performance (ActiTrainer) |
|---|---|---|
| Intended Use | Document physical movement, monitor activity during sleep, analyze circadian rhythms, assess quantifiable physical motion. | Document physical movement, monitor activity during sleep, analyze circadian rhythms, assess quantifiable physical motion. |
| Technological Characteristics | Records movement with accelerometer, saves data internally on RAM, uses on-board microprocessor, data displayed with ActiLife software. | Records movement with accelerometer, saves data internally on RAM, uses on-board microprocessor, data displayed with ActiLife software. |
| Size | 5.1 x 5.1 x 1.1 cm | 8.5 x 3.4 x 1.6 cm |
| Weight | 42.5 grams | 51 grams |
| Battery Type | Lithium/Manganese Dioxide | Lithium Ion |
| Accelerometer Sensitivity | 16 milliGs | 4 milliGs |
| Enclosure | Polycarbonate | Polycarbonate |
| Sampling Intervals | 1 second and 4 minutes | 1 second to 4 minutes |
| Recording Time @ 1min. Epoch | 11 days | 14 days |
| Memory | 256kB | 1024kB |
| Storage Temperature | -10°C to 50°C | -10°C to 50°C |
| Operating Temperature | 0°C to 40°C | 0°C to 40°C |
| Heart Rate | Not applicable (n.a.) | BPM (Optional Polar heart strap) |
Study Details (as much as can be inferred from the document):
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
The document does not describe a "test set" in the context of a performance study with human subjects or a dataset for algorithm validation. The comparison is based on the specifications of the new device (ActiTrainer) against the specifications of the predicate device (Actigraph). This is a technical comparison, not a clinical trial or algorithm validation study. Therefore, there is no sample size for a test set or data provenance in the traditional sense.
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 is not applicable as there was no "test set" requiring ground truth establishment by experts for performance evaluation. The ground truth for proving substantial equivalence lies in the technical specifications and intended uses being comparable.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable, as no test set was described that would require adjudication.
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 ActiTrainer is an activity monitor, not an AI-assisted diagnostic tool that would involve human readers or MRMC studies.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
This refers to the device's inherent function. The ActiTrainer operates as an algorithm-only device (it records and processes physical movement data without continuous human intervention during data collection). The "study" presented is a comparison of its technical specifications to a predicate, not an evaluation of its standalone performance in a clinical setting with numerical outcomes.
7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)
For the purpose of 510(k) clearance in this context, the "ground truth" is primarily the established technical specifications and intended use of the legally marketed predicate device (Actigraph K040554). The ActiTrainer's specifications and intended use are compared against these predicate "truths" to demonstrate substantial equivalence.
8. The sample size for the training set
Not applicable. This document describes a 510(k) submission for a physical activity monitor, not an AI/machine learning algorithm that requires a "training set."
9. How the ground truth for the training set was established
Not applicable, as there is no training set for an AI/machine learning algorithm.
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Image /page/0/Picture/0 description: The image shows the logo for ActiGraph. The logo features the word "ActiGraph" in a bold, sans-serif font. Above the word is the tagline "...for technology of health". Below the word is a line that resembles an EKG. The website address "www.theActigraph.com" is also present.
Koro545
VII 510(k) Summary
JUL 2 4 2008
Applicant: ActiGraph, LLC 15 W. Main St. Pensacola, FL 32502 Phone: (850) 332-7900 Fax: (859) 332-7904
Point of Contact: John G. Schneider, VP of R&D
Trade Name: ActiTrainer
Common Names: Activity Recording Device
Classification Name: ISD
Equivalent Legally Marketed device: The ActiTrainer is similar in function to the ActiGraph LLC's legally marketed activity monitor, the Actigraph, K040554.
Description of Device: The ActiTrainer is housed in a polycarbonate plastic housing. It is 8.5 cm long by 3.4 cm wide by 1.6 cm thick and it weights 51 grams. It also has an optional Polar heart strap. Data is downloaded into a PC via a USB plug and the data is displayed with ActiGraph LLC's ActiLife software.
Intended Use. The ActiTrainer is a small worn activity monitor designed for documenting physical movement associated with applications in physiological monitoring. The device is intended to monitor the activity associated with movement during sleep. The ActiTrainer can be used to analyze circadian rhythms and assess activity in any instance where quantifiable analysis of physical motion is desirable.
Technological Characteristics: The ActiTrainer is substantially equivalent to the Actigraph, they both record and same movement with accelerometer and save the data internally on RAM. They both use an on board microprocessor for controlling the data which can be displayed with ActiGraph LLC's ActiLife data. ActiTrainer has an optional heart rate channel and expanded memory capability to handle the extra data.
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Image /page/1/Picture/0 description: The image shows the logo for ActiGraph. The logo features a stick figure standing in the middle of a heartbeat line. Above the word ActiGraph is the phrase "...the technology of health". Below the heartbeat line is the website address www.theactigraph.com.
:
| Comparison Table | ||
|---|---|---|
| Parameter | Actigraph (Predicate) | ActiTrainer |
| Size | 5.1 x 5.1 x 1.1 | 8.5 x 3.4 x 1.6 |
| Weight | 42.5 grams | 51 grams |
| Battery Type | Lithium/Manganese Dioxide | Lithium Ion |
| Accelerometer Sensivity | 16 milliGs | 4 milliGs |
| Enclosure | Polycarbonate | Polycarbonate |
| Sampling Intervals | 1 second and 4 minutes | 1 second to 4 minutes |
| Recording Time @ 1min. Epoch | 11 days | 14 days |
| Memory | 256kB | 1024kB |
| Storage Temperature | -10°C to 50°C | -10°C to 50°C |
| Operating Temperature | 0°C to 40°C | 0°C to 40°C |
| Heart Rate | n.a. | BPM |
Table 1. Comparing the ActiTrainer to the Actigraph
:
1
:
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Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
Actigraph, LLC. % Mr. John Schneider Vice President of R & D 15 West Main Street Pensacola, Florida 32502
JUL 2 4 2008
Re: K080545
Trade Name: ActiTrainer Regulation Number: 21 CFR 890.5360 Regulation Name: Measuring Exercise Equipment Regulatory Class: Class II Product Code: ISD Dated: June 6, 2008 Received: June 11, 2008
Dear Mr. Schneider:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the 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 may be subject 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. John Schneider
This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification 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 contact the Center for Devices and Radiological Health's (CDRH's) Office of Compliance at (240) 276-0120. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding postmarket surveillance, please contact CDRH's Office of Surveillance and Biometric's (OSB's) Division of Postmarket Surveillance at (240) 276-3474. For questions regarding the reporting of device adverse events (Medical Device Reporting (MDR)), please contact the Division of Surveillance Systems at (240) 276-3464. You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at toll-free number (800) 638-2041 or (240) 276-3150 or the Internet address http://www.fda.gov/cdrh/industry/support/index.html
Sincerely yours.
Mark M. Mullican
Mark N. Melkerson Director Division of General. Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health
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Image /page/4/Picture/0 description: The image shows the logo for ActiGraph. The logo features a stylized human figure with outstretched arms, forming the letter 'A' in 'ActiGraph'. Above the text, it reads '...the technology of health'. Below the text is the website address 'www.theActigraph.com'.
Indications for Use
510(k) Number (if known):
Device Name: ActiTrainer ActiTrainer
Indications for Use:
The ActiTrainer is a small worn activity monitor designed for documenting physical movement associated with applications in physiological monitoring. The device is intended to monitor the activity associated with movement during sleep. The ActiTrainer can be used to analyze circadian rhythms and assess activity in any instance where quantifiable analysis of physical motion is desirable.
Prescription Use X (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)
| Concurrence of CDRH, Office of Device Evaluation (ODE) | |
|---|---|
| (Division Sign-Off) | |
| Division of General, Restorative, and Neurological Devices | |
| 510(k) Number K080548 | |
| Page 1 of 1 |
Fax: 850-332-7904 Pensacola, FL USA Ph: 850-332-7900 15 West Main Street Website: www.TheActiGraph.com
§ 890.5360 Measuring exercise equipment.
(a)
Identification. Measuring exercise equipment consist of manual devices intended for medical purposes, such as to redevelop muscles or restore motion to joints or for use as an adjunct treatment for obesity. These devices also include instrumentation, such as the pulse rate monitor, that provide information used for physical evaluation and physical planning purposes., Examples include a therapeutic exercise bicycle with measuring instrumentation, a manually propelled treadmill with measuring instrumentation, and a rowing machine with measuring instrumentation.(b)
Classification. Class II (special controls). The device, when it is a measuring exerciser or an interactive rehabilitation exercise device for prescription use only, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 890.9.