(95 days)
The Exceed Unlimited is a microneedling device and accessories intended for the treatment of wrinkles in Fitzpatrick skin types I. Il and/or III in the following facial areas: qlabellar frown lines, periorbital lines and cheek folds in adults aged 22 years or older.
The Exceed Unlimited is a microneedling device and accessories intended to be used as a treatment to improve the appearance of facial acne scars in Fitzpatrick skin types I, II, III and IV in adults aged 22 years or older.
The Exceed Unlimited device is intended to create many, very tiny, microscopic punctures in the epidermal and dermal layers of the skin using sterile stainless steel needles.
The Exceed Unlimited device consists of 7 component parts; Handpiece, sterile single use Safety needle cartridge, Handpiece holder, Barrier Sleeve, Battery, Charger incl. USB cable, power supply. The handpiece contains a motor that moves the needles. The handpiece receives power via a Li-Ion battery with an output of 3,7 V. The battery charger receives power from a standard 100-240V, 50-60Hz, 0.45A wall socket transformer with an USB output of 5 V, 3.2A.
The frequency of the handpiece can be adjusted from 100-150Hz and is indicated on a display. The needle penetration is adjusted by the needle protrusion setting dial, which can be adjusted between 0.0 (min.) and 1.9 mm (max.).
The standard safety needle cartridge (6-needle plate) contains 6 stainless steel microneedles of 1.5 mm length (0.35 mm gauge) and an internal safety membrane. The safety needle cartridge is screwed into the handpiece. The safety needle cartridge is sterile and for single use ONLY.
The provided text is a 510(k) Summary for the Exceed Unlimited microneedling device. It describes the device, its intended use, and compares it to a predicate device (Exceed Microneedling device) to demonstrate substantial equivalence.
However, the document does not contain specific acceptance criteria for a study demonstrating device performance, nor does it present the results of such a study in a quantitative manner (e.g., a table of performance metrics). Instead, it primarily focuses on non-clinical performance testing and risk mitigation measures to establish substantial equivalence.
Based on the provided text, I can infer some aspects and highlight what is explicitly stated versus what is absent:
1. A table of acceptance criteria and the reported device performance:
- Absent. The document does not provide a table of acceptance criteria nor reported quantitative device performance metrics from a study. It only lists performance characteristics that were tested during non-clinical performance testing.
2. Sample size used for the test set and the data provenance:
- Absent directly. The document mentions "non-clinical performance data" and "accuracy of needle penetration depth and puncture rate in pig skin." While this indicates the type of test, it does not specify the sample size used (e.g., number of pigs, number of punctures, number of test runs).
- Data Provenance: The pig skin tests would be considered experimental/laboratory data, not human patient data. The document does not mention the country of origin for these tests. It implicitly would be from the manufacturer's testing facilities or a contracted lab. The tests are not from retrospective or prospective human clinical studies for performance metrics.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Absent. This information is relevant for human-in-the-loop studies or studies relying on expert-verified data, typically clinical studies. Since the described performance testing is non-clinical (on pig skin), the concept of "experts establishing ground truth" in the diagnostic sense is not applicable here. The "ground truth" for the pig skin tests would be the measured physical properties (e.g., actual penetration depth, puncture rate) using high-speed cameras or other measurement tools.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Absent. Adjudication methods are typically used in clinical trials where multiple readers or experts assess outcomes. As the described performance testing is non-clinical/technical, this concept does not apply.
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:
- Absent. This device is a microneedling device, not an AI or imaging diagnostic tool. Therefore, an MRMC study comparing human readers with and without AI assistance is not relevant to its function and was not performed or described.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable in the typical sense of AI/software. This is a hardware microneedling device. Its "performance" is evaluated by its physical characteristics (e.g., needle penetration accuracy, frequency, safety features). There isn't an "algorithm only" performance metric in the way it would apply to a diagnostic AI. The performance data mentioned (e.g., accuracy of needle penetration) are inherent to the device's mechanical operation.
7. The type of ground truth used:
- For the non-clinical performance testing mentioned ("Accuracy of needle penetration depth and puncture rate in pig skin with high-speed camera measurement"), the ground truth would be physical measurements (e.g., actual depth measured from camera footage or other instruments). It is not expert consensus, pathology, or outcomes data in the clinical sense.
8. The sample size for the training set:
- Not applicable. This section is relevant for machine learning models. The Exceed Unlimited is a physical medical device, not a software AI model that requires a training set.
9. How the ground truth for the training set was established:
- Not applicable. As per point 8, there is no training set for this type of device.
In summary, based solely on the provided text, the document focuses on demonstrating substantial equivalence through non-clinical performance and safety testing, rather than presenting a performance study with acceptance criteria and quantitative results. The provided information is insufficient to complete the requested table and fully answer all questions, as many are relevant to AI/diagnostic software devices, not a microneedling device.
§ 878.4430 Microneedling device for aesthetic use.
(a)
Identification. A microneedling device for aesthetic use is a device using one or more needles to mechanically puncture and injure skin tissue for aesthetic use. This classification does not include devices intended for transdermal delivery of topical products such as cosmetics, drugs, or biologics.(b)
Classification. Class II (special controls). The special controls for this device are:(1) The technical specifications and needle characteristics must be identified, including needle length, geometry, maximum penetration depth, and puncture rate.
(2) Non-clinical performance data must demonstrate that the device performs as intended under anticipated conditions of use. The following performance characteristics must be tested:
(i) Accuracy of needle penetration depth and puncture rate;
(ii) Safety features built into the device to protect against cross-contamination, including fluid ingress protection; and
(iii) Identification of the maximum safe needle penetration depth for the device for the labeled indications for use.
(3) Performance data must demonstrate the sterility of the patient-contacting components of the device.
(4) Performance data must support the shelf life of the device by demonstrating continued sterility, package integrity, and device functionality over the intended shelf life.
(5) Performance data must demonstrate the electrical safety and electromagnetic compatibility (EMC) of all electrical components of the device.
(6) Software verification, validation, and hazard analysis must be performed for all software components of the device.
(7) The patient-contacting components of the device must be demonstrated to be biocompatible.
(8) Performance data must validate the cleaning and disinfection instructions for reusable components of the device.
(9) Labeling must include the following:
(i) Information on how to operate the device and its components and the typical course of treatment;
(ii) A summary of the device technical parameters, including needle length, needle geometry, maximum penetration depth, and puncture rate;
(iii) Validated methods and instructions for reprocessing of any reusable components;
(iv) Disposal instructions; and
(v) A shelf life.
(10) Patient labeling must be provided and must include:
(i) Information on how the device operates and the typical course of treatment;
(ii) The probable risks and benefits associated with use of the device; and
(iii) Postoperative care instructions.