(209 days)
The Theradome LH80 PRO is an over-the-counter (OTC) therapeutic device intended to treat Androgenetic Alopecia and promote hair growth in males who have Norwood-Hamilton Classifications of IIa to V patterns of hair loss and to treat Androgenetic Alopecia and promote hair growth in females who have Ludwig-Savin Scale I-1 to I-4, II-1, II-2; both with Fitzpatrick Skin Types I to IV.
The Theradome LH80 PRO for men and women is a low level coherent light therapy (LLLT) device utilised to promote hair growth. The coherent lights are contained inside a lightweight, one-size fits all helmet. The Theradome LH80 PRO uses 80 coherent light diodes in the helmet to deliver coherent light stimulation to the entire scalp for hands-free operation during treatment. An audible timer automatically turns the coherent lights off after the 20 minutes treatment is completed. This coherent light helmet is not constructed to be a safety helmet.
The provided text describes the Theradome LH80 PRO device and its FDA submission (K171775). While it states that "all acceptance criteria were met by the devices," and refers to compliance with IEC-60825-2007-03, it does not explicitly list specific acceptance criteria or present the full details of a study with performance metrics in a way that allows for a direct table comparing acceptance criteria to reported device performance.
Instead, the document primarily focuses on establishing "substantial equivalence" to predicate devices based on similar technological characteristics and intended use. It explicitly states "Brief Description of Clinical Testing: Not applicable." This indicates that a clinical study designed to test efficacy against specific hair growth metrics was not performed for this 510(k) submission.
Therefore, many sections of your request cannot be fully answered from the provided text. I will answer what is available and indicate when information is not provided.
1. Table of Acceptance Criteria and Reported Device Performance
The document states that "Performance testing was conducted to confirm compliance to design specifications; all functions have been verified to operate as designed. All acceptance criteria were met by the devices." It also notes compliance with standard IEC-60825-2007-03, which establishes the AEL (accessible emission limits) as 5 milliwatts maximum. However, specific, measurable "acceptance criteria" related to efficacy (e.g., percentage increase in hair count, reduction in hair loss rate) and corresponding reported performance from a specific study are not provided in this document. The focus is on safety and technical specifications, and substantial equivalence to a predicate.
| Acceptance Criterion | Reported Device Performance | Comments |
|---|---|---|
| Compliance with design specifications | All functions verified to operate as designed. | General statement, specific metrics not detailed. |
| Compliance with IEC-60825-2007-03 (Coherent Light Class 3R) | AEL (accessible emission limits) meets 5 milliwatts maximum. | This is a safety standard, not an efficacy criterion. |
| Usability for self-selection | Verified. | Details of "verification" are not provided. |
| Comprehension of user instructions | Verified. | Details of "verification" are not provided. |
| Comprehension of warnings | Verified. | Details of "verification" are not provided. |
| Comprehension of precautions | Verified. | Details of "verification" are not provided. |
| Efficacy-related metrics (e.g., hair count) | Not provided in this document for the K171775 submission. | The submission relies on substantial equivalence and does not report on clinical efficacy trials for this specific submission. |
2. Sample Size Used for the Test Set and Data Provenance
- Sample size for the test set: Not applicable for clinical performance as "Clinical Testing: Not applicable" is stated. For the "self-selection and usability" tests, the sample size is not mentioned.
- Data provenance: Not specified for the usability tests. For the technical compliance, it's typically internal testing by the manufacturer.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
- Not applicable as clinical efficacy studies with ground truth established by experts are explicitly stated as "Not applicable" for this submission (K171775). For usability, no information on experts is provided.
4. Adjudication Method for the Test Set
- Not applicable, as no clinical efficacy test set is described.
5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study Was Done
- No, an MRMC comparative effectiveness study was not done. The document states "Brief Description of Clinical Testing: Not applicable."
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) Was Done
- Not applicable. The Theradome LH80 PRO is a low-level light therapy device, not an algorithm or AI system.
7. The Type of Ground Truth Used
- For the technical performance and safety aspects, the ground truth is established by adherence to recognized standards (e.g., IEC-60825-2007-03) and design specifications.
- For usability and self-selection, the ground truth would typically be user feedback or observation, but specific details are not provided.
- For clinical efficacy (e.g., hair growth), no ground truth data from a clinical study is included in this submission.
8. The Sample Size for the Training Set
- Not applicable, as this is a medical device for light therapy, not an AI/ML algorithm that requires a training set.
9. How the Ground Truth for the Training Set Was Established
- Not applicable, as this is not an AI/ML algorithm.
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January 9, 2018
Theradome Inc. Tamim Hamid President and CEO 4900 Hopyard Rd, Ste 100 Pleasanton, California 94588
Re: K171775
Trade/Device Name: Theradome LH80 PRO Regulation Number: 21 CFR 890.5500 Regulation Name: Infrared Lamp Regulatory Class: Class II Product Code: OAP Dated: December 6, 2017 Received: December 11, 2017
Dear Tamim Hamid:
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 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.
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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.
For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely.
Jennifer R. Stevenson -ਟਤ 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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Indications for Use
510(k) Number (if known) K171775
Device Name Theradome LH80 PRO
Indications for Use (Describe)
The Theradome LH80 PRO is an over-the-counter (OTC) therapeutic device intended to treat Androgenetic Alopecia and promote hair growth in males who have Norwood-Hamilton Classifications of IIa to V patterns of hair loss and to treat Androgenetic Alopecia and promote hair growth in females who have Ludwig-Savin Scale I-1 to I-4, II-1, II-2; both with Fitzpatrick Skin Types I to IV.
Type of Use (Select one or both, as applicable)
| Foundation Use (Part 21 CFR 201.66) - Select One | |
|---|---|
| Own Firm Construction (21 CFR 211.111) - Select One |
| | Prescription Use (Part 21 CFR 801 Subpart D)
|X | Over-The-Counter Use (21 CFR 801 Subpart C)
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5.0 Traditional 510(k) Summary
Date Prepared: Thursday, January 4, 2018
Image /page/3/Picture/2 description: The image shows the logo for Theradome Hair Growth Treatment System. The word "theradome" is written in a combination of gray and blue colors. Above the word "theradome" are three blue curved lines, and below the word is the phrase "Hair Growth Treatment System" in blue.
| Submitter's Contact Information: | Sarah Mersereau, MBA PMPConsultant, Theradome Inc.4900 Hopyard Road, Suite 100Pleasanton, CA 94588Telephone: 510-714-0525Email: sarah@theradome.com |
|---|---|
| Name of Device and Name / Address of Sponsor: | Theradome LH80 PROTheradome Inc.4900 Hopyard Road, Suite 100Pleasanton, CA 94588Telephone: 510-714-0525Fax: 925-374-1202Establishment Registration# 274120 |
| Sponsor Contact Information: | Tamim Hamid, PhDCEO, Theradome Inc.4900 Hopyard Road, Suite 100Pleasanton, CA 94588Telephone: 510-714-0525Fax: 925-374-1202Email: tamim@theradome.com |
| Device Name and Classification | Product/Trade Name: Theradome LH80 PROCommon or Usual Name: Theradome LH80 PROClassification Name: Infrared lamp per 21 CFR 890.5500Product Code: OAP (Coherent light, Comb, Hair)Regulation Number: 21 CFR 890.5500Panel: General and Plastic SurgeryClass: II |
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Predicate Devices:
| Predicate | 510(k) Number | Device Name | Manufacturer |
|---|---|---|---|
| Primary | K122950 | Theradome LH80 PRO | Theradome Inc. |
| Reference | K163170 | Capillus82 | Capillus LLC |
| Additional | K162782 | iHelmet | Slinph TechnologiesCo., Ltd |
Device Trade Name Manufacturer 510(k)
Device Description Summary
The Theradome LH80 PRO for men and women is a low level coherent light therapy (LLLT) device utilised to promote hair growth. The coherent lights are contained inside a lightweight, one-size fits all helmet. The Theradome LH80 PRO uses 80 coherent light diodes in the helmet to deliver coherent light stimulation to the entire scalp for hands-free operation during treatment. An audible timer automatically turns the coherent lights off after the 20 minutes treatment is completed. This coherent light helmet is not constructed to be a safety helmet.
Intended Use / Indications for Use
The Theradome LH80 PRO is an over-the-counter (OTC) therapeutic device intended to treat Androgenetic Alopecia and promote hair growth in males who have Norwood-Hamilton Classifications of IIa to V patterns of hair loss and to treat Androgenetic Alopecia and promote hair growth in females who have Ludwig-Savin Scale I-1 to I-4, II-2; both with Fitzpatrick Skin Types I to IV.
Technological Characteristics
The Theradome LH80 PRO coherent light Helmet is a low level coherent light therapy (LLLT) device used to promote hair growth. The coherent lights are contained inside a lightweight onesize-fits-all helmet. The Theradome LH80 PRO utilizes 80 coherent light diodes to deliver coherent light stimulation to the entire scalp for hands-free operation during treatment. The device is onebutton operated, and has an audible timer that automatically turns the coherent lights off after the 20 minute treatment completes.
Performance Data
Performance testing was conducted to confirm compliance to design specifications; all functions have been verified to operate as designed. All acceptance criteria were met by the devices. The Theradome LH80 PRO conforms to the standard IEC-60825-2007-03. This IEC standard is a recognized and accepted standard by the FDA. The guidance document for this accepted standard is found in the Federal register, July 26, 2001 (volume 66, Number 144) [page 39049 39050]. This report validates for the Theradome LH80 PRO the coherent light class of 3R which establishes the AEL (accessible emission limits) as 5 milliwatts maximum. The data presented in this submission is restricted to self-selection and usability to include comprehension of user instructions, warnings, and precautions.
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Brief Description of NonClinical Testing
As part of establishing substantial equivalence between LH80 PRO, iHelmet, and Capillus82 devices within the LH80 PRO (K171775) 510(k) submission, the technological characteristics, such as, fluence, irradiance, treatment time, number of diodes, etc. are compared within the subject and predicate devices.
Brief Description of Clinical Testing
Not applicable.
Substantial Equivalence
Theradome LH80 PRO utilizes the same fundamental technology and comparable technological parameters as the predicates. Please see table below.
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| Theradome LH80 PRO | Theradome LH80 PRO | Capillus82 | iHelmet |
|---|---|---|---|
| - Females only | |||
| K171775 | K122950 | K163170 | K162782 |
| LLLT Device Type | LLLT Device Type | LLLT Device Type | LLLT Device Type |
| Prescription Use/OTC | Prescription Use/OTC | Prescription Use/OTC | Prescription Use/OTC |
| Intended Use - | Intended Use - | Intended Use - | Intended Use - |
| Androgenic Alopecia | Androgenic Alopecia | Androgenic Alopecia | Androgenic Alopecia |
| Contains coherent | Contains coherent | Contains coherent | Contains coherent |
| light diodes- Class 3R | light diodes- Class 3R | light diodes- Class 3R | light diodes- Class 3R |
| Helmet/Cap Design | Helmet/Cap Design | Helmet/Cap Design | Helmet/Cap Design |
| 678nm | 678nm | 650nm | 650nm |
| Marketing clearance | Marketing clearance | Marketing clearance | Marketing clearance |
| for Males and Females | for Females | for Males and Females | for Males and Females |
| Passive Use-Hands | Passive Use-Hands | Passive Use-Hands | Passive Use-Hands |
| Free | Free | Free | Free |
| Features - One button | Features - One button | Features - One button | Features - One button |
| operation, audible | operation, audible | operation, audible | operation, audible |
| timer, status LED | timer, status LED | timer, status LED | timer, status LED |
| Treatment time- 20 | Treatment time- 20 | Treatment time- 30 | Treatment time- 20 |
| minutes | minutes | minutes | minutes |
| Irradiance = same | Irradiance = same | Irradiance = | Irradiance = |
| comparable | comparable | ||
| Fluence = same | Fluence = same | Fluence = comparable | Fluence = comparable |
| 80 coherent light | 80 coherent light | 82 Coherent light | 200 Coherent light |
| diodes | diodes | diodes | diodes |
| OAP Classification | OAP Classification | OAP Classification | OAP Classification |
| Classification Name - | Classification Name - | Classification Name - | Classification Name - |
| Infrared Lamp | Infrared Lamp | Infrared Lamp | Infrared Lamp |
| Common Usage Name | Common Usage Name | Common Usage Name | Common Usage Name |
| -Lamp, Non-Heating | -Lamp, Non-Heating | -Lamp, Non-Heating | -Lamp, Non-Heating |
| General & Plastic | General & Plastic | General & Plastic | General & Plastic |
| Surgery Committee | Surgery Committee | Surgery Committee | Surgery Committee |
| Fitzpatrick Skin | Fitzpatrick Skin | Fitzpatrick Skin | Fitzpatrick Skin |
| Phototypes - I- IV | Phototypes - I- IV | Phototypes - I- IV | Phototypes - I- IV |
| Ludwig-Savin I-II | Ludwig-Savin I-II | Ludwig-Savin I-II | Ludwig-Savin I-II |
| (females) Norwood | (females) | (females) Norwood | (females) Norwood |
| Hamilton IIA-V (males) | Hamilton IIA-V (males) | Hamilton IIA-V (males) | Hamilton IIA-V (males) |
| Device Class II | Device Class II | Device Class II | Device Class II |
Conclusion
Based on the comparable indications for use and technological characteristics the subject device is substantially equivalent to the predicates.
§ 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.