(279 days)
The MEP-90 is a non-heating lamp as described under the provisions of 21 CFR §890.5500 and is indicated for: Medically prescribed use for the treatment of androgenic alopecia in females: The treatment of androgenic alopecia in females by promoting hair growth of females with androgenetic alopecia who have Ludwig and Savin Hair Loss Scale classifications of I to II and who have been determined to have a Fitzpatrick Skin Typing of I to IV.
The MEP-90 is a stationary low-level laser device that promotes hair growth and provides treatment for androgenic (androgenetic) alopecia in females. The device provides automated and timed equal distribution of laser light to 100% of the scalp. The MEP-90 operation is controlled by an operating system that affords the user maximum flexibility for individual treatments. The device applies a measured very high tolerance (≤+.76%) wavelength (λ) to the scalp stimulating hair growth by the proven concept of biostimulation.
The MEP-90 Hair Growth Stimulation System, identified by 510(k) number K091496, is indicated for the treatment of androgenic alopecia in females with specific Ludwig and Savin Hair Loss Scale classifications (I to II) and Fitzpatrick Skin Typing (I to IV), by promoting hair growth.
Here's an analysis of the provided information regarding acceptance criteria and the study that supports it:
1. Acceptance Criteria and Reported Device Performance
The provided document does not explicitly state pre-defined "acceptance criteria" as a set of quantified thresholds that needed to be met for device approval. Instead, it describes "therapeutic results standards" and "statistical significance." However, based on the performance data presented, we can infer the device's efficacy targets related to hair count increase and stabilization of hair loss.
| Acceptance Criteria (Inferred from Study Results) | Reported Device Performance |
|---|---|
| Increased Hair Count | |
| After 20 treatments (10-Weeks): | |
| - Percentage of subjects with ≥10% increase in hair count | 92% of subjects demonstrated an increased hair count of ≥10%. |
| - Percentage of subjects with ≥30% increase in hair count | 57% of subjects demonstrated an increase of ≥30%. |
| After 36 treatments (18-Weeks): | |
| - Percentage of subjects with ≥20% increase in hair count | 97% of the subject population demonstrated an increased hair count of ≥20%. |
| - Percentage of subjects with ≥30% increase in hair count | 89% of all subjects demonstrated an increased hair count of ≥30%. |
| - Percentage of subjects with ≥50% increase in hair count | 57% of all subjects demonstrated an increased hair count of ≥50%. |
| Stabilization of Hair Loss | |
| After 20 treatments (10-Weeks): | |
| - Percentage of subjects with medically significant stabilization of hair loss | 98% of subjects indicated a medically significant stabilization of their rate of hair loss. |
| Overall Perception | |
| After 36 treatments (18-Weeks): | |
| - Percentage of subjects feeling treatments helped their condition | 87% of subjects indicated the treatments have helped their condition. |
| - Percentage of subjects reporting further slowed loss rate (from 10-week period) | 60% reported their loss rate has further slowed down from the 10-week period. |
| - Percentage of subjects reporting smaller visible bald spot | 65% reported their visible area of the alopecia (bald spot) had gotten smaller. |
| Adverse Events | No subject experienced any adverse event and/or effect from the treatments. |
| Trend of Hair Growth | 100% of the linear trend plotting for all subjects of their Initial, 10-Week, and 18-Week hair counts demonstrated a historical rate of increased hair growth. The clinical data acquired confirms both the safety and effectiveness of the MEP-90... The data demonstrates clear statistical significance of the treatment results obtained and provide mathematical certainty that the results attained did not occur by chance. (This suggests the primary "acceptance criterion" was statistically significant improvement compared to baseline, rather than necessarily performing better than a comparator device or a predefined threshold for superiority, given it's a 510(k) where substantial equivalence is the goal) |
2. Sample Size and Data Provenance for the Test Set
- Sample Size Used for the Test Set: While the exact number of subjects for the study is not explicitly stated, the document consistently refers to "subjects" and "subject population" in singular. However, given the percentages mentioned (e.g., 92% of subjects, 57% demonstrating an increase), it implies a reasonable number of participants to make these percentages meaningful, suitable for statistical analysis. It is described as a "multi-phased experimental study."
- Data Provenance: The study was "performed with Institutional Review Board (IRB) preapproval and oversight, in accordance with all applicable references of the Food and Drug Cosmetic Act and Title 21; Code of Federal Regulations." This indicates a prospective clinical study designed to evaluate the device. The country of origin for the data is implicitly the USA, given the FDA submission and compliance with US regulations.
3. Number of Experts and Qualifications for Ground Truth
The document pertains to a clinical efficacy study for a medical device that promotes hair growth. The "ground truth" here is the actual biological response to the treatment, measured by hair count and observed changes in alopecia. This is a direct physiological outcome rather than an interpretation task requiring expert consensus on images.
- Number of Experts: Not applicable in the traditional sense of image review or diagnosis confirmation. The "ground truth" is established by direct measurement of hair count and self-reported patient perceptions.
- Qualifications of Experts: The study indicates that "Androgenic alopecia in women is a chronic medical condition requiring diagnosis, treatment, and monitoring by a licensed medical physician." This implies that initial diagnosis and potentially evaluations were performed by licensed medical professionals, but this isn't explicitly described as an "expert consensus" process for establishing ground truth within the efficacy measurements themselves.
4. Adjudication Method for the Test Set
Not applicable. The study measures objective physiological changes (hair count) and subjective patient reports. There's no indication of a diagnostic "test set" requiring adjudication by multiple experts in the context of image interpretation or complex diagnostic calls. The data likely comes from direct clinical measurements and patient questionnaires.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No, a multi-reader multi-case (MRMC) comparative effectiveness study was not conducted. This type of study typically evaluates diagnostic performance (e.g., radiologists reading images) with and without AI assistance. The MEP-90 study is a direct clinical efficacy study of a therapeutic device designed to stimulate hair growth.
6. Standalone (Algorithm Only) Performance
Yes, a standalone study was done in the sense that the clinical efficacy described is the algorithm (device) only performance, without human-in-the-loop assistance for diagnosis or treatment application. The device, the MEP-90 Hair Growth Stimulation System, is a standalone therapeutic device that applies laser light. The study directly measures its effectiveness in promoting hair growth in human subjects when used as prescribed.
7. Type of Ground Truth Used for the Test Set
The ground truth used for the test set was a combination of:
- Objective Biophysical Measurements: Hair count increases at specified intervals (10-weeks and 18-weeks) compared to baseline. The report mentions "linear trend plotting for all subjects of their Initial, 10-Week, and 18-Week hair counts," confirming direct measurement.
- Patient-Reported Outcomes/Observations: Self-reported stabilization of hair loss, perception of treatment effectiveness, slowed loss rate, and reduction in the visible area of alopecia (bald spot).
8. Sample Size for the Training Set
The document describes a single "multi-phased experimental study" conducted on human subjects to determine the efficacy of the MEP-90. There is no mention of a separate "training set" in the context of machine learning. The clinical study is the evaluation of the device's performance, not the training of an AI algorithm on data for later validation. Therefore, this concept is not applicable here as the device itself is a physical light therapy system, not an AI diagnostic tool.
9. How the Ground Truth for the Training Set was Established
As mentioned above, there is no "training set" in the context of an AI algorithm. The MEP-90 is a physical device, and its design and parameters (like wavelength, power output, treatment duration) are based on the established scientific understanding of biostimulation and predicate devices, rather than being "trained" on a dataset in a machine learning sense. The clinical study was to confirm the efficacy and safety of the already designed device.
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as required per 21CFR; §807.92)
FEB 2 8 2010
MEP-90 Hair Growth Stimulation System
| I. Applicant | Midwest RF LLC |
|---|---|
| 1050 Walnut Ridge Drive | |
| Hartland, WI 53029 USA |
Phone: (262) 867-8254 Fax: (262) 867-8554
| II. Contact Name | Helmut Keidl, President |
|---|---|
| helmut@midwestcomposite.com |
III. Device Name
| Proprietary Name................................................................ | MEP-90 Hair Growth Stimulation System |
|---|---|
| Common/Usual Name(s) ............................................................ | Light Therapy Hair System |
| Classification Name ................................................................ | Infrared Lamp per 21CFR 890.5500 |
| Product Code(s) ...................................................................... | OAP; NHN |
IV. Predicate Devices
| 510(k) Number | Device | Manufacturer |
|---|---|---|
| K060305 | Hairmax Lasercomb | Lexington International LLC |
| K032816 | Quantum Light Therapy System | Stargate International |
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VI. Indications For Use
The MEP-90 is a non-heating lamp as described under the provisions of 21 CFR §890.5500 and is indicated for:
Medically prescribed use for the treatment of androgenic alopecia in females:
The treatment of androgenic alopecia in females by promoting hair growth of females with androgenetic alopecia who have Ludwig and Savin Hair Loss Scale classifications of I to II and who have been determined to have a Fitzpatrick Skin Typing of I to IV.
VII. Technological Characteristics
The MEP-90 is a stationary low-level laser device that promotes hair growth and provides treatment for androgenic (androgenetic) alopecia in females. The device provides automated and timed equal distribution of laser light to 100% of the scalp.
The MEP-90 operation is controlled by an operating system that affords the user maximum flexibility for individual treatments. The device applies a measured very high tolerance (≤+.76%) wavelength (λ) to the scalp stimulating hair growth by the proven concept of biostimulation.
VII. Performance Data And Clinical Efficacy
A multi-phased experimental study was performed with Institutional Review Board (IRB) preapproval and oversight, in accordance with all applicable references of the Food and Drug Cosmetic Act and Title 21; Code of Federal Regulations.
Androgenic alopecia in women is a chronic medical condition requiring diagnosis, treatment, and monitoring by a licensed medical physician. The condition in women demonstrates both physical and emotional symptoms, which requires addressing by a licensed medical professional.
For the MEP-90 efficacy determination, each subject received a total of 36 each, 20-minute treatments with the MEP-90, over a period of 18 weeks. Results were reviewed at the 10-Week (20 treatment) and 18-Week (36 treatment) levels.
After 20 treatments (10-Weeks), 92% of the subjects demonstrated an increased hair count of ≥10% with 57% demonstrating an increase of ≥30%. 98% of the subjects indicated a medically significant stabilization of their rate of hair loss.
After the 36th treatment, 97% of the subject population demonstrated an increased hair count of ≥20%. A total of 89% of all subjects demonstrated an increased hair count of ≥30%, with 57% demonstrating an increased hair count of ≥50%.
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87% of the subjects indicated the treatments have helped their condition, with 60% reporting their loss rate has further slowed down from the 10-week period, and 65% reported their visible area of the alopecia (bald spot) had gotten smaller.
100% of the linear trend plotting for all subjects of their Initial, 10-Week, and 18-Week hair counts demonstrated a historical rate of increased hair growth.
No subject experienced any adverse event and/or effect from the treatments.
VI. Substantial Equivalency
The MEP-90 is substantially equivalent to other pulsed therapeutic light therapy systems currently in commercial distribution. The MEP-90 has the same intended use to the predicate device approved for commercial distribution under 510(k) number K060305 and technological and safety characteristics to the predicate device approved for commercial distribution under 510(k) number K032816.
It exceeds the clinically accepted therapeutic results standards of FDA 510(k) K060305 previously approved light therapy system into a system which provides a more controlled application and larger treatment coverage area at no increased risk to the patient.
The technological equivalence to the predicate devices is substantiated by the wavelength and power output generated by the MEP-90. The MEP-90 provides expanded treatment benefits and regimens for clinical presentations already approved by the Food and Drug Administration for the predicate device.
The MEP-90 is as safe and effective as a combination of the predicate devices listed and numerous others. It has the same intended use of affecting hair growth as the hair growth predicate device (K060305). In addition, the MEP-90 has the same general indications, i.e., treating androgenic alopecia, and the same specific indication of promoting hair growth as the predicate device.
The MEP-90 also has many of the same or similar technological characteristics as a combination of its predicate devices. These include multiple lasers and visible laser wavelength.
The technological differences between the MEP-90 and its predicate devices, specifically the use of red laser to treat androgenic alopecia in females, does not raise new questions of safety or effectiveness for several reasons:
First, the safety and effectiveness profile of the type, wavelength, and power output of this type of laser is well established and previously cleared by the FDA.
Second, FDA's clearance of the predicate device with a much wider wavelength tolerances then the MEP-90's, confirms the favorable risk benefit ratio of visible lasers.
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Third, the clinical data acquired confirms both the safety and effectiveness of the MEP-90 for prescription use in promoting hair growth in the intended patient population, despite the difference in technological characteristics between the MEP-90 and K060305. The data demonstrates clear statistical significance of the treatment results obtained and provide mathematical certainty that the results attained did not occur by chance.
These facts exceed FDA's substantial equivalence requirements with respect to the intended use, clinical efficacy, and technological characteristics of the MEP-90.
While there are some technological differences between the MEP-90 and its predicate devices, Midwest conducted an Institutional Review Board approved and monitored clinical study, with the MEP-90, to show that the device functions as intended for its proposed indication for use without any serious side effects or risks.
The clinical and effectiveness data demonstrates that the MEP-90 is effective in promoting hair growth, does not present any safety issues, is classified by the FDA as a non-significant risk (NSR) device, therefore the FDA should approve the medical device by approval of the 510(k).
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Image /page/4/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized image of an eagle or bird with outstretched wings.
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room W-O66-0609 Silver Spring, MD 20993-0002
FEB 2 3 2010
Midwest RF. LLC % Mr. Helmut Keidl President 1050 Walnut Ridge Drive Hartland, Wisconsin 53029
Re: K091496
Trade/Device Name: MEP-90 Hair Growth Stimulation System Regulation Number: 21 CFR 890.5500 Regulation Name: Infrared lamp Regulatory Class: Class II Product Code: OAP Dated: January 15, 2010 Received: January 20, 2010
Dear Mr. Keidl:
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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you; however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to 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
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Page 2 - Mr. Helmut Keidl
CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm
Sincerely yours,
Sincerely yours,
Mark N. Melkerson
Director Division of Surgical, Orthopedic And Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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INDICATIONS FOR USE
510(k) Number: K091496
Device Name: MEP-90 Hair Growth Stimulation System
Indications For Use: The MEP-90 is a non-heating lamp as described under the provisions of 21 CFR §890.5500 and is indicated for:
The treatment of androgenic alopecia in females by promoting hair growth of females with androgenetic alopecia who have Ludwig and Savin Hair Loss Scale classifications of I to II and who have been determined to have a Fitzpatrick Skin Typing of I to IV.
Prescription Use: AND/OR (Part 21 CFR 801 Subpart D)
Over The Counter Use:
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Dhtro
(Division Sign-Off) Division of Surgical, Orthepedic, and Restorative Devices
510(k) Number
16091496
Revised page 10 of 102 Pages - MEP-90 510(k) K091496 Application Dated May 15, 2009
§ 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.