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510(k) Data Aggregation

    K Number
    K233695
    Manufacturer
    Date Cleared
    2024-05-07

    (172 days)

    Product Code
    Regulation Number
    890.3480
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Cyberdyne Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Medical HAL Lower Limb Type orthotically fits to the lower limbs and trunk; HAL is a gait training device intended to temporarily help improve ambulation upon completion of the HAL gait training intervention. HAL must be used with a Body Weight Support system. HAL is not intended for sports or stair climbing. HAL gait training is intended to be used in conjunction with regular physiotherapy.

    The device is intended for individuals with:

    • spinal cord iniurv at levels C4 to L5 (ASIA C. ASIA D) and T11 to L5 (ASIA A with Zones of Partial Preservation, ASIA B);

    • post stroke paresis

    • paraplegia due to progressive neuromuscular diseases (spinal muscular atrophy, spinal and bulbar muscular atrophy, amyotrophic lateral sclerosis, Charcot-Marie-Tooth disease, distal muscular dystrophy, inclusion body myositis, congenital myopathy, muscular dystrophy)

    -cerebral palsy and are 12 years or older

    -spastic paraplegia caused by either HTLV-1 Associated Myelopathy (HAM) or hereditary spastic paraplegia (HSP)

    who exhibit sufficient residual motor and movement-related functions of the hip and knee to trigger and control HAL.

    In preparation for HAL gait training, the controller can be used while the exoskeleton is not donned to provide biofeedback training through the visualization of surface electromyography bioelectrical signals recorded.

    HAL is intended to be used inside healthcare facilities while under trained medical supervision in accordance with the user assessment and training certification program.

    Device Description

    Medical HAL Lower Limb Type is a battery powered bi-lateral ower extremity exoskeleton that provides assistive torque at the knee and hip joints for gait training. HAL is comprised of a controller, a main unit, and sensor shoes in 30 size variations (variation same as predicate: 3 different leg lengths, 2 different leg lengths, 2 different waist widths >> total 24. New size variation: 3 different leg configurations, 1 leg lengths, 2 different waist widths >> total 6) and weighs ~9.5 kg (21 lbs). The main difference between the Model ML05 and ML07 is the leglengths. ML05 has S.M, L, XL sizes, while ML07 has 2S sizes. The device uses legally marketed electrodes (up to 18 electrodes) to record surface electromyography bioelectrical signals that are processed using a propriety signal processing algorithm. The propriety processing algorithm allows the detect surface electromyography bioelectrical signals to control the HAL device in CVC mode and provide visualization of the surface electromyography bioelectrical signals during biofeedback training. The assistive torque can be adjusted using three parameters: sensitivity level, torque tuner, and balance tuner. The device can also provide two additional modes: Cybernic Autonomous Control (CAC) mode and Cybernic Impedance Control (ClC) mode. CAC mode provides assistive torque leg trajectories based on postural cues and sensor shoe measurements. CC mode provides torque to compensate for frictional resistance of the motor based on joint motion. CIC mode does not provide torque assistance for dictating joint trajectories. A trained medical professional (i.e., physical therapist, etc.) can configure, operate, and monitor the device during gait training to make adjustments as needed.

    Patients must exhibit sufficient residual motor and movement-related functions of the hip and knee to trigger and control HAL. The patient must be supported by a Body Weight Support (BWS) system before and during device use. The BWS must not be detached from the patient before doffing this device. HAL is not intended to provide sit-stand or stand-sit movements. HAL is capable of gait speeds up to approximately 2 km/hour on level ground. HAL is not intended for sports or stairclimbing.

    In preparation to using HAL, the controller can be used while the exoskeleton is not donned to provide biofeedback training through the visualization of surface electromyography bioelectrical signals recorded. HAL is intended to be used in conjunction with regular physiotherapy. HAL is intended to be used inside a medical facility under the supervision of trained medical professionals who have successfully completed the HAL training program.

    AI/ML Overview

    The provided text, a 510(k) summary for the Medical HAL Lower Limb Type (HAL-ML), describes the device, its intended use, and its equivalence to a predicate device (HAL for Medical Use (Lower Limb Type), K201559). It primarily focuses on regulatory approval and equivalence, particularly regarding the expansion of indications for use to include Cerebral Palsy and Spastic Paraplegia.

    While the document references "clinical data to support the safety and efficacy" and "clinical evaluation procedure," it does not provide a detailed breakdown of acceptance criteria or the specific study results proving the device meets those criteria in the format requested. It states that the "nonclinical and clinical tests submitted demonstrate that the device is as safe and as effective, and performs as well as the legally marketed device cleared as K201559." However, it does not offer the granular information needed to fulfill all aspects of your request (e.g., specific performance metrics, sample sizes for test sets, expert qualifications, or MRMC study details).

    Therefore, based only on the provided text, I can infer some information regarding the clinical evaluation but cannot fully populate the table or answer all sub-questions as the detailed study design, acceptance criteria with numerical performance data, and other specifics are not disclosed in this regulatory summary.

    Here's an attempt to answer your questions based on the available information, with clear indications where the information is not provided in the text:

    1. A table of acceptance criteria and the reported device performance

    The document does not specify quantitative acceptance criteria or report specific performance metrics for the efficacy of the device in a table format. It broadly states that the clinical evaluation "results are sufficient to support the claims identified in the Indications for Use for this submission" and that the device is "sufficiently safe".

    2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    • Sample Size for Test Set: Not provided. The document mentions clinical evaluations for five indication groups but does not state the number of subjects in these evaluations.
    • Data Provenance: Not provided. The country of origin of the data (e.g., Japan, where the manufacturer is located) and whether the studies were retrospective or prospective are not mentioned.

    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 information is not provided in the document. Ground truth for a device like HAL-ML would likely refer to clinical outcomes or functional improvements, which are assessed by medical professionals during the study, rather than "experts establishing ground truth" in the same way it might apply to an imaging AI algorithm. The document mentions "trained medical professionals (i.e., physical therapist, etc.)" configure, operate, and monitor the device, but not their specific role in establishing ground truth for a study.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    This information is not provided.

    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

    An MRMC study is typically performed for diagnostic imaging devices where human readers interpret medical images. This type of study is not applicable to the Medical HAL Lower Limb Type, which is a gait training device. Therefore, no information on MRMC studies or human reader improvement with AI assistance is present or relevant here.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    The device is a physical exoskeleton used for gait training, highly dependent on human interaction (patient and trained medical professional). It's not an algorithm-only device. The "propriety processing algorithm" processes sEMG signals to control the device, but its performance is intrinsically tied to the Human-in-the-loop interaction for gait training. Therefore, a "standalone algorithm only" performance study in the typical AI sense is not relevant or described.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    The document states "The safety and effectiveness of the subject device is demonstrated through the following clinical evaluation procedure for each of the 5 indication groups... The evaluation results are sufficient to support the claims identified in the Indications for Use." This strongly implies that the ground truth would be based on clinical outcomes data related to ambulation improvement, safety, and effectiveness in the specified patient populations. However, the specific metrics or "ground truth" definitions (e.g., specific scores on mobility scales) are not detailed.

    8. The sample size for the training set

    The document describes clinical evaluation for the safety and effectiveness of the device as a whole. It does not mention a "training set" in the context of an AI/ML model for which a distinct training set would be used. The "propriety processing algorithm" is part of the device's functionality, but the document does not provide details about its development, including specific training set sizes if machine learning were used this way.

    9. How the ground truth for the training set was established

    As there is no mention of a "training set" in the context of an AI/ML model with externally established ground truth for training purposes, this information is not provided. The algorithm processes sEMG signals to control the device, which is an engineering function, not necessarily a machine learning model that requires a distinct "training set ground truth" in the way a diagnostic AI would.


    In summary, the provided 510(k) summary serves as a regulatory document for substantial equivalence, not a detailed scientific publication of clinical trial results. It confirms that clinical evaluations were performed to support the expanded indications but does not provide the granular data, methodology, or specific acceptance criteria and performance statistics that you've requested beyond a general statement of safety and effectiveness.

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    K Number
    K201559
    Manufacturer
    Date Cleared
    2020-10-02

    (114 days)

    Product Code
    Regulation Number
    890.3480
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Cyberdyne Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    HAL for Medical Use (Lower Limb Type) orthotically fits to the lower limbs and trunk;

    HAL is a gait training device intended to temporarily help improve ambulation upon completion of the HAL gait training intervention. HAL must be used with a Body Weight Support system. HAL is not intended for sports or stair climbing. HAL gait training is intended to be used in conjunction with regular physiotherapy.

    The device is intended for individuals with:

    • spinal cord injury at levels C4 to L5 (ASIA C, ASIA D) and T11 to L5 (ASIA A with Zones of Partial Preservation, ASIA B);

    • post stroke paresis

    • paraplegia due to progressive neuromuscular diseases (spinal muscular atrophy, spinal and bulbar muscular atrophy, amyotrophic lateral sclerosis, Charcot-Marie-Tooth disease, distal muscular dystrophy, inclusion body myositis, congenital myopathy, muscular dystrophy) who exhibit sufficient residual motor and movement-related functions of the hip and knee to trigger and control HAL

    In preparation for HAL gait training, the controller can be used while the exoskeleton is not donned to provide biofeedback training through the visualization of surface electromyography bioelectrical signals recorded.

    HAL is intended to be used inside medical facilities while under trained medical supervision in accordance with the user assessment and training certification program

    Device Description

    HAL for Medical Use (Lower Limb Type) is a battery powered lower extremity exoskeleton that provides assistive torque at the knee and hip joints for gait training. HAL is comprised of a controller, a main unit, and sensor shoes. The device comes in 8 size variations (4 different leg lengths and 2 different hip widths) for each of the 3 configuration types (doubleleg, right-leg, and left-leg) and weighs ~14 kg (30 lbs). The device uses legally marketed cutaneous electrodes (up to 18 electrodes) to record surface electromyography bioelectrical signals of the hip and knee extensor and flexor muscles when the device is used in Cybernic Voluntary Control (CVC) mode. This mode provides assistive torque at the corresponding ioint (e.g., hip or knee) using surface electromyography bioelectrical signals that are processed using a propriety signal processing algorithm. The propriety processing algorithm allows the device to detect surface electromyography bioelectrical signals to control the HAL device in CVC mode and provide visualization of the surface electromyography bioelectrical signals during biofeedback training. The assistive torque can be adjusted using three parameters: sensitivity level, torque turner, and balance turner. The device can also provide two additional modes: Cybernic Autonomous Control (CAC) mode and Cybernic Impedance Control (CIC) mode. CAC mode provides assistive torque leg trajectories based on postural cues and sensor shoe measurements. CIC mode provides torque to compensate for frictional resistance of the motor based on joint motion. CIC mode does not provide torque assistance for dictating joint trajectories. A trained medical professional (i.e., physician, physical therapist, etc.) can configure, operate, and monitor the device during gait training to make adjustments as needed.

    AI/ML Overview

    The provided document is a 510(k) Summary for the HAL for Medical Use (Lower Limb Type) device. It describes the device, its intended use, and substantial equivalence to a predicate device (K171909). The document focuses on demonstrating safety and effectiveness, particularly for new patient populations.

    It's important to note that this document is an FDA 510(k) summary, which typically presents summarized findings rather than a detailed breakdown of all study methodologies. Therefore, some specific details for each point requested might not be explicitly stated or might require inference from the provided text.

    Here's an analysis of the provided information against your requested points:


    Acceptance Criteria and Device Performance

    The acceptance criteria are not explicitly stated as distinct numerical targets for each performance metric in a single table. Instead, the document demonstrates meeting acceptance criteria through compliance with recognized standards, successful bench testing, and consistent or improved clinical outcomes compared to baseline or control groups across various studies. The "results" sections for non-clinical and clinical data effectively serve as proof of meeting implicit or explicit acceptance criteria related to safety, functionality, and efficacy.

    Table of Acceptance Criteria and Reported Device Performance:

    CategoryAcceptance Criteria (Implicit/Explicit)Reported Device Performance/Results
    Non-Clinical Performance
    Safety Standards ComplianceConformance with AAMI/ANSI ES60601-1, IEC 60601-1-2, IEC 60601-1-6, IEC 62366, IEC 62133, IEC 60335-1, IEC 60335-2-29, ANSI/UL 1012, IEC 62304."Subject devices demonstrate conformance with the following recognized standards" (listed above). "Results of all non-clinical testing support the safety and effectiveness of the subject devices."
    Stopper Strength Test (Durability)Mechanical stopper endures mechanical force applied by patient and maintains conformance after 100 cycles.Conformance was maintained after 100 cycles. "The mechanical stopper is expected to endure the impact in the joints."
    Consecutive Landing Test (Durability)HAL mechanical/electrical systems withstand repeated impacts for 5-years worth of service life (1,000,000 cycles) without missing parts, cracks, loosening, abnormal noises, etc.All 3 samples withstood 3,000,000 cycles, with no issues. "it is sufficiently durable."
    Effective Output Test (Torque/Velocity)Actuator meets specifications for effective output torque and provides maximum angular velocity within human knee joint tolerance.Output verified to meet specification and risk management requirements. Angular velocity verified within human tolerance.
    Driving Parts Performance TestActual torque output falls within performance criteria range compared to control algorithm's intended output.Test results show actual torque output falls within criteria range, meeting expected performance.
    Joint Angle Measurement (Accuracy)Accuracy of joint angle sensing meets specification."Accuracy of joint angle measurement was verified to meet specification."
    Body Trunk Absolute Angle Measurement (Accuracy)Accuracy of body trunk absolute angle sensing allows sufficient detection of stable posture for safety and effectiveness.Measurement results "can sufficiently detect the stable posture... thus ensuring the safety and effectiveness."
    Plantar Load Measurement (Accuracy)Accuracy of plantar load measurement allows sufficient detection of planting/lifting of sole to determine leg phase for safety and effectiveness.Measurement results "can sufficiently detect the planting and lifting of the sole... thus ensuring the safety and effectiveness."
    Surface Electromyography Bioelectrical Signal Measurement (Accuracy)Accuracy of sEMG bioelectrical signal measurement performance meets specifications (input impedance, CMRR, frequency characteristics)."Accuracy for all measurements were verified to meet specifications."
    Ankle Durability TestAnkle parts withstand repeated twisting impacts for 5-years worth of service life (implied ~300,000 impacts for turning movements) without missing parts, cracks, loosening, abnormal noises, etc.All 3 samples withstood 300,000 impacts, with no issues. "The ankle part of the device is sufficiently durable."
    Clinical Performance (Effectiveness)
    SCI - Gait Improvement (10MWT speed)Significant improvement in 10MWT speed. (e.g., from ~0.25-0.28 m/s pre to ~0.50 m/s post)Reported differences range from +0.22 m/s to +0.25 m/s, or time improvements of 28.99s to 35.23s (faster). "meaningful improvements for SCI patients in terms of walking ability."
    SCI - Gait Improvement (6MWT distance)Significant improvement in 6MWT distance. (e.g., from ~70-90m pre to ~140-160m post)Reported differences range from +22.75m to +93.2m. "meaningful improvements for SCI patients in terms of walking ability."
    Stroke - Gait Improvement (10MWT speed)Overall improvement in 10MWT speed, especially in control-inclusive studies or where natural recovery is accounted for. MCID (Minimum Clinically Important Difference) as a benchmark.Chronic stage: Reported differences up to +0.21 m/s (p
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    K Number
    K171909
    Manufacturer
    Date Cleared
    2017-12-17

    (174 days)

    Product Code
    Regulation Number
    890.3480
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    CYBERDYNE Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    HAL for Medical Use (Lower Limb Type) orthotically fits to the lower limbs and trunk; the device is intended for individuals with spinal cord injury at levels C4 to L5 (ASIA C, ASIA D) and T11 to L5 (ASIA A with Zones of Partial Preservation, ASIA B), who exhibit sufficient residual motor and movement-related functions of the hip and knee to trigger and control HAL.

    HAL is a gait training device intended to temporarily help improve ambulation upon completion of the HAL gait training intervention. HAL must be used with a Body Weight Support system. HAL is not intended for sports or stair climbing. HAL gait training is intended to be used in conjunction with regular physiotherapy.

    In preparation for HAL gait training, the controller can be used while the exoskeleton is not donned to provide biofeedback training through the visualization of surface electromyography bioelectrical signals recorded.

    HAL is intended to be used inside medical facilities while under trained medical supervision in accordance with the user assessment and training certification program

    Device Description

    HAL for Medical Use (Lower Limb Type) is a battery powered bi-lateral lower extremity exoskeleton that provides assistive torque at the knee and hip joints for gait training. HAL is comprised of a controller, a main unit, and sensor shoes. The device comes in 8 size variations (4 different leg lengths and 2 different hip widths) and weighs ~14 kg (30 lbs). The device uses legally marketed cutaneous electrodes (up to 18 electrodes) to record surface electromyography bioelectrical signals of the hip and knee extensor and flexor muscles when the device is used in Cybernic Voluntary Control (CVC) mode. This mode provides assistive torque at the corresponding joint (e.g., hip or knee) using sufface electromyography bioelectrical signals that are processed using a propriety signal processing algorithm. The propriety processing algorithm allows the device to detect surface electromyography bioelectrical signals to control the HAL device in CVC mode and provide visualization of the surface electromyography bioelectrical signals during biofeedback training. The assistive torque can be adjusted using three parameters: sensitivity level. torque turner. and balance turner. The device can also provide two additional modes: Cybernic Autonomous Control (CAC) mode and Cybernic Impedance Control (CIC) mode. CAC mode provides assistive torque leq trajectories based on postural cues and sensor shoe measurements. CIC mode provides torque to compensate for frictional resistance of the motor based on joint motion. CIC mode does not provide torque assistance for dictating joint trajectories. A trained medical professional (i.e., physician, physical therapist, etc.) can configure, operate, and monitor the device during gait training to make adjustments as needed.

    Patients must exhibit sufficient residual motor and movement-related functions of the hip and knee to trigger and control HAL. The patient must be supported by a Body Weight Support (BWS) system before donning the device and during device use. The BWS must not be detached from the patient before doffing this device. HAL is not intended to provide sit-stand or stand-sit movements. HAL is capable of gait speeds up to approximately 2 km/hour on level ground. HAL is not intended for sports or stairclimbing.

    In preparation to using HAL, the controller can be used while the exoskeleton is not donned to provide biofeedback training through the visualization of surface electromyography bioelectrical signals recorded.

    HAL is intended to be used in conjunction with regular physiotherapy. HAL is intended to be used inside a medical facility under the supervision of trained medical professionals who have successfully completed the HAL training program.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and study information for the HAL for Medical Use (Lower Limb Type), based on the provided document:

    Acceptance Criteria and Device Performance

    The document doesn't explicitly state "acceptance criteria" in a separate, quantifiable table for clinical performance endpoints. Instead, it presents the results of two clinical studies and highlights whether the observed improvements are statistically and clinically significant. The key clinical measures used to demonstrate effectiveness are:

    Acceptance Criteria (Implied by Clinical Significance)Reported Device Performance (Average Improvement Post-Intervention)P-value (vs. baseline)Clinical Significance Thresholds (MCID)
    10 Meter Walk Test (speed) improvement0.20 m/s (DE-02 Study, 55 subjects)
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