(107 days)
The UltraShape System delivers focused ultrasound energy that can disrupt subcutaneous adipose tissue (SAT) for lipolysis (breakdown of fat) to provide a non-invasive a desired aesthetic effect. It is intended for non-invasive reduction in abdominal circumference and fat reduction in the flanks and thighs.
The UltraShape System is comprised of multiple components, including the control unit and two ultrasonic transducers. The UltraShape System selectively targets subcutaneous adipose tissue via focused ultrasound for the purpose of non-invasive aesthetic body contouring. The transducers are electro-mechanical devices that convert an electrical signal into mechanical (acoustical) energy. The operating parameters of the UltraShape System achieve selective disruption of adipose tissue without damaging neighboring tissues such as blood vessels, nerves, or muscle. The UltraShape System has two treatment modes available, the Single Focus Deep Mode and the Super Mode.
- Table of Acceptance Criteria and Reported Device Performance:
| Acceptance Criteria (Primary Effectiveness Endpoint) | Reported Device Performance |
|---|---|
| Blinding reviewers, when shown randomized pairs of thigh photographs, correctly identify both pre- versus post-treatment and treated versus untreated thighs in at least 80% of cases. (Based on visual assessment of randomized photographs of before (baseline) versus after (16 weeks following last treatment), as well as treated versus untreated thighs.) | Met endpoint: Blinded reviewers correctly identified (by agreement between the blinded reviewers) both the pre-/post-treatment photographs as well as the treated/un-treated thighs in 81% (30 of 37) subjects. Furthermore, even in the Intent-to-Treat population, with worst case imputation where all missing data were treated as failures, 64% of the subjects were successes. |
-
Sample Size Used for the Test Set and Data Provenance:
- Sample Size: 47 subjects (all female).
- Data Provenance: Prospective, single-arm, self-controlled, multicenter clinical study conducted at 3 U.S. sites.
-
Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications:
- Number of Experts: 2 blinded reviewers.
- Qualifications: The document does not specify the qualifications of the blinded reviewers (e.g., radiologist with X years of experience). It only states they were "blinded reviewers."
-
Adjudication Method for the Test Set:
- The device performance indicates that the primary endpoint was met by "agreement between the blinded reviewers." This implies a consensus-based adjudication method, likely 2 out of 2 agreement, for the visual assessment of photographs.
-
Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:
- No, a multi-reader multi-case (MRMC) comparative effectiveness study was not done. The study design was a prospective, single-arm, self-controlled study rather than a comparative effectiveness study comparing AI with and without human assistance. The primary endpoint involved human reviewers assessing photographs, but it was for standalone device effectiveness, not to measure human improvement with AI assistance.
-
Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study:
- No, this study was not a standalone (algorithm only) performance study. The primary effectiveness endpoint relied on assessment by "blinded reviewers" of photographs, which inherently involves human-in-the-loop performance for evaluation.
-
Type of Ground Truth Used:
- The primary ground truth for the effectiveness endpoint was expert consensus (agreement between the two blinded reviewers) based on visual assessment of photographs of pre- and post-treatment thighs, as well as treated vs. untreated thighs.
- Secondary endpoints used objective measurements like ultrasound and caliper measurements for fat thickness reduction, and investigator and subject satisfaction assessments.
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Sample Size for the Training Set:
- The document describes a clinical study to evaluate the device, not an AI or algorithm, so there is no mention of a "training set" in the context of machine learning. The clinical study itself served to demonstrate the device's performance in humans.
-
How the Ground Truth for the Training Set Was Established:
- Not applicable, as this is not an AI/machine learning device that would require a separate training set with established ground truth. The study evaluated the direct effects of the UltraShape System on human subjects.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
November 17, 2016
Syneron Medical Ltd. % Ms. Janice Hogan Hogan Lovells Us Llp 1835 Market Street 29th Floor Philadelphia, Pennsylvania 19103
Re: K162163
Trade/Device Name: Ultrashape System Regulation Number: 21 CFR 878.4590 Regulation Name: Focused Ultrasound Stimulator System for Aesthetic Use Regulatory Class: Class II Product Code: OHV Dated: October 21, 2016 Received: October 21, 2016
Dear Ms. Hogan:
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 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in
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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.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education 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. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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 Industry and Consumer Education 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,
Jennifer R. Stevenson -A
For Binita S. Ashar, M.D., M.B.A., F.A.C.S. Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration Indications for Use
510(k) Number (if known)
Device Name
UltraShape System
Indications for Use (Describe)
The UltraShape System delivers focused ultrasound energy that can disrupt subcutaneous adipose tissue (SAT) for lipolysis (breakdown of fat) to provide a non-invasive a desired aesthetic effect. It is intended for non-invasive reduction in abdominal circumference and fat reduction in the flanks and thighs.
| Type of Use (Select one or both, as applicable) |
|---|
| ☒ Prescription Use (Part 21 CFR 801 Subpart D) |
| ☐ Over-The-Counter Use (21 CFR 801 Subpart C) |
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510(k) SUMMARY
Syneron Medical Ltd.'s UltraShape System
Submitter's Name, Address, Telephone Number, Contact Person and Date Prepared
Ruthie Amir, MD, Global Vice President of Clinical, Regulatory and Education Syneron Medical Ltd. P.O.B. 550 Industrial Zone, Tavor Building Yokneam Illit, 20692 Israel Phone: 972-73-244-2200 Facsimile: 972-73-244-2202
Contact Person: Janice Hogan Hogan Lovells U.S. LLP 1835 Market Street, 29th Floor Philadelphia, PA 19103 Phone: 267 675 4600 Facsimile: 267 675 4601
Date Prepared: November 17, 2016
Name of Device
Syneron UltraShape System
Common or Usual Name
Focused Ultrasound Stimulator System for Aesthetic Use
Classification
21 C.F.R. § 878.4590, Class II, product code OHV
Predicate/Reference Devices
Predicate: Syneron UltraShape System (K141708)
Intended Use / Indications for Use
The UltraShape System delivers focused ultrasound energy that can disrupt subcutaneous adipose tissue (SAT) for lipolysis (breakdown of fat) to provide a non-invasive approach to achieve a desired aesthetic effect. It is intended for non-invasive reduction in abdominal circumference and fat reduction in the flanks and thighs.
Device Description
The UltraShape System is comprised of multiple components, including the control unit and two ultrasonic transducers. The UltraShape System selectively targets subcutaneous adipose tissue via focused ultrasound for the purpose of non-invasive aesthetic body
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contouring. The transducers are electro-mechanical devices that convert an electrical signal into mechanical (acoustical) energy. The operating parameters of the UltraShape System achieve selective disruption of adipose tissue without damaging neighboring tissues such as blood vessels, nerves, or muscle. The UltraShape System has two treatment modes available, the Single Focus Deep Mode and the Super Mode.
Technological Characteristics
The UltraShape System has similar technological characteristics compared to its predicate. Both devices are comprised of the system console, including the computer, and two ultrasonic transducers. The transducers deliver the focused ultrasound energy beam to the targeted treatment area, and real-time optical and acoustic feedback (optional) on the treatment is provided via the tracking and guidance system. With both the UltraShape and its predicate, the transducers' functionality is based on the piezoelectric effect implemented with the ceramic element. The transducers' membranes of the subject UltraShape are composed of the same material as previously cleared for the U-Sculpt transducer of the predicate.
In addition, the subject UltraShape System has the same treatment parameters as the previously cleared UltraShape device, including the same frequency, burst duration, node duration, and user interface. The power intensity levels were previously cleared for the UltraShape, and the focal distribution of the energy beams delivered to the treatment area is consistent between the device and its predicate, including the focal depth, diameter, and length.
Therefore, the subject UltraShape System has very similar technological characteristics as its predicate.
Performance Data
Nonclinical Performance Testing. The following nonclinical performance testing was previously conducted to support the substantial equivalence of the UltraShape System to the predicate device, consistent with FDA's Class II Special Controls Guidance Document: Focused Ultrasound Stimulator System for Aesthetic Use (2011). In all instances, the UltraShape System functioned as intended.
- Biocompatibility testing in accordance with ISO 10993 for skin irritation, sensitization, and cytotoxicity supported the biocompatibility of the patient-contacting components of the device.
- . Beam profile testing demonstrated that the acoustic energy is delivered and concentrated in the desired target location.
- Acoustic power testing demonstrated that the acoustic power of the transducers is highly predictable with low variability.
- In vitro acoustic and thermal measurements demonstrated the safety of non-targeted tissues both proximal and distal to the targeted region.
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- Software verification and validation was performed, and demonstrated that the ● software performs as intended.
- . Electrical safety (IEC 60601-1), electromagnetic compatibility (IEC 60601-1-2) and electromagnetic immunity testing was conducted and results were passing.
- . In vivo testing in an animal model was performed which demonstrated the treatment effects of the UltraShape, and supported its safety and efficacy profile for the intended use.
Clinical Data: In addition, clinical evaluation of the UltraShape device for non-invasive lipolysis of the thighs was performed in a prospective, single-arm, self-controlled study. A total of 47 subjects (all female) across a range of ages, ethnicities, and skin types were enrolled at 3 U.S. sites. The mean age was 46 years and the majority of the subjects were Caucasian. The mean weight at baseline was 70±10 kg (range 51-103 kg). Each subject received 3 biweekly treatments on one randomized thigh, while the other thigh remained untreated throughout the study to serve as a control. Subject follow up was conducted at 4 weeks, 8 weeks, and 16 weeks after the last treatment.
The study met its primary effectiveness endpoint, where blinded reviewers who were shown randomized pairs of thigh photographs correctly identified both pre- versus post-treatment and treated versus untreated thighs in 81% of cases. Further, even in the Intent-to-Treat population, with worst case imputation where all missing data were treated as failures, 64% of the subjects were successes. UltraShape treated thighs showed statistically significantly greater circumference reduction compared to the control thighs at each follow-up visit. Fat thickness reduction results following UltraShape treatment were statistically significantly greater compared to controls as measured by ultrasound. Investigators were satisfied with results following UltraShape treatment for 77% of the subjects at 4 week follow up, 81% of the subjects at 8 week follow up, and 68% of the subjects at 16 week follow up. At 4, 8 and 16 weeks following end of treatments. 62%, 61% and 68% of the subjects were satisfied or very satisfied. Finally, treatment with the UltraShape System in the thigh area demonstrated a strong positive safety profile, with no adverse events reported after 128 treatment sessions and only mild anticipated treatment responses (e.g., erythema) that resolved without intervention. This is consistent with the results observed for prior UltraShape clearances, including the predicate device.
The study design and results are further summarized in the table below.
| Study Design | Prospective, single-arm, self-controlled, multicenter clinical study |
|---|---|
| Sample size | 47 subjects at 3 sites were enrolled in the study |
| PrincipalEligibilityCriteria | • Fat thickness of at least 1.5 cm in the treated area as measured bycalibrated caliper.• BMI interval: 22 ≤ BMI ≤ 30 (normal to overweight, but not obese).• General good health confirmed by medical history and skin examinationof the treated area. |
| Follow upintervals | 3 treatment visits and follow up visits at 4 weeks, 8 weeks, and 16 weeks. |
| Endpoints | Primary: Circumference and fat reduction in thighs was based on visualassessment of randomized photographs of before (baseline) versus after (16weeks following last treatment), as well as treated versus untreated thighs by 2blinded reviewers. The primary endpoint was achieved when at least 80% oftreated versus control thighs and pre- versus post-treatment photographs werecorrectly identified. |
| Secondary:- Circumference reduction on treated thigh compared to control thigh.- Fat thickness reduction on the treated thigh compared to the controlthigh, measured by ultrasound.- Fat thickness reduction on the treated thigh compared to the controlthigh, measured by caliper.- Investigator satisfaction assessment.- Subject satisfaction self-assessment.- Subjects' comfort level assessed immediately after each treatment. | |
| EffectivenessResults | Primary: Met endpoint; blinded reviewers identified correctly (by agreementbetween the blinded reviewers) both the pre-/post-treatment photographs aswell as the treated/un-treated thighs in 81% (30 of 37) subjects. |
| Secondary:- UltraShape treated thighs showed statistically significantly greatercircumference reduction compared to the control thighs at each follow-up visit.- Fat thickness reduction results following UltraShape treatment werestatistically significantly greater compared to controls as measured byultrasound.- Fat thickness reduction results following UltraShape treatment weregreater compared to controls as measured by caliper, although thedifference was not statistically significant at all visits.- Investigators were satisfied with results following UltraShape treatmentfor 77% of the subjects at 4 week follow up, 81% of the subjects at 8week follow up, and 68% of the subjects at 16 week follow up.- At 4, 8 and 16 weeks following end of treatments, 62%, 61% and 68% ofthe subjects were satisfied or very satisfied.- Subjects reported no to minimal pain on average for each of the threetreatments. | |
| SafetyResults | No adverse events were reported after 128 treatment sessions were conducted.The only immediate responses recorded were mild and resolved completelywithin days without any intervention. |
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Therefore, clinical evaluation of the subject UltraShape device demonstrated its favorable performance and safety profile for lipolysis of the thighs. Results thus further support substantial equivalence of the device as compared to the predicate.
Substantial Equivalence
The UltraShape has the same intended use and very similar indications for use, technological characteristics, and principles of operation as its predicate device. The technological differences between the UltraShape and its predicate mainly consist of minor improvements to the device to facilitate use. Nonclinical and clinical studies of the
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UltraShape have demonstrated the device's safety and effectiveness profile in the intended population. Thus, the UltraShape is substantially equivalent to the predicate device.
Conclusion
Syneron's UltraShape System is a Focused Ultrasound Stimulator System for Aesthetic Use Class II device that has been evaluated in nonclinical testing in accordance with FDA's corresponding Special Controls Guidance Document. Testing demonstrated that the device performs as intended. The UltraShape device is substantially equivalent to its predicate device (K141708).
§ 878.4590 Focused ultrasound stimulator system for aesthetic use.
(a)
Identification. A Focused Ultrasound Stimulator System for Aesthetic Use is a device using focused ultrasound to produce localized, mechanical motion within tissues and cells for the purpose of producing either localized heating for tissue coagulation or for mechanical cellular membrane disruption intended for noninvasive aesthetic use.(b)
Classification. Class II (special controls). The special control for this device is FDA's “Class II Special Controls Guidance Document: Focused Ultrasound Stimulator System for Aesthetic Use.” See § 878.1(e) for the availability of this guidance document.