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510(k) Data Aggregation

    K Number
    DEN100024
    Device Name
    ZAP-IT!
    Manufacturer
    Date Cleared
    2014-11-07

    (1520 days)

    Product Code
    Regulation Number
    882.5894
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Zap-It! is indicated for temporarily reducing the itching caused by mosquito bites.

    Device Description

    The Zap-It! is a hand held device, consisting primarily of housing, a push button (which the user de presses to excite the piezoelectric crystal), a "Piezo unit" (containing piezoelectric crystal) and electrical output terminals (placed flush to the user's skin) intended to deliver electrical current to the skin.

    AI/ML Overview

    Here's a summary of the acceptance criteria for Zap-It! and the study data proving it meets those criteria, based on the provided text:

    Acceptance Criteria and Reported Device Performance for Zap-It!

    Acceptance Criteria CategorySpecific CriteriaReported Device Performance / Study Findings
    I. EffectivenessPrimary Outcome: Proportion of subjects whose itching at t=15 minutes decreased 40% or greater relative to baseline itching at t=5 minutes (Visual Analog Scale - VAS).Achieved. 19 out of 27 (70.4%) active treatment subjects met the success criterion, compared to 3 out of 26 (11.5%) placebo subjects. The difference was statistically significant (p<0.05). Mean VAS score for the active group was statistically significantly lower than the placebo group at all time points after baseline.
    II. Safety (General)No adverse events reported during human performance study. Risks of cutaneous burns, adverse skin reactions, damage to sensitive tissue, infection, burns from flammable substances, interference with implanted devices, failure to identify correct population/condition, and device failure are appropriately mitigated.Achieved. "Subjects were monitored for 24 hours and no adverse events were noted." All identified risks are mitigated through labeling, biocompatibility assessment, and non-clinical testing.
    III. Device PerformanceElectrical Output Specifications: Characterization of total charge delivered, maximum instantaneous output current, maximum instantaneous output voltage, pulse duration, charge density.Achieved. Open circuit output measured as 13kV, 0.7mA, and 20 µS pulse duration. Specifics on total charge delivered and charge density are not explicitly detailed in the summary but fall under the general heading of characterization.
    Mechanical Bench Testing: Device withstands labeled number/duration of uses.Achieved. Testing showed the device still conferred charge after 5000 actuations, though with a 34% decrease in measured open circuit voltage. Labeling advises users to replace the device after "several (e.g., 1,000) uses" if effectiveness degrades.
    Biocompatibility: All patient-contacting materials assessed to be biocompatible.Achieved. Justification was provided supporting biocompatibility of the acrylonitrile butadiene styrene (ABS) patient-contacting material for an externally-contacting device.
    IV. Labeling & UsabilityValidated Instructions: Addresses appropriate/inappropriate body areas, conjunction with flammable materials, use near implanted devices, and identification of skin condition. Technical Parameters: Includes max output voltage, current, and pulse duration. Adverse Event Reporting: Directs users to manufacturer and MedWatch. Anticipated Uses: States anticipated number of uses prior to failure.Achieved. The labeling addresses all these points: warnings against using with pacemakers, over open wounds, eyes, lips, inside mouth, over viral lesions; warnings regarding flammable materials; instructions on maximum 5 activations per bite to mitigate burns; stating the device's effectiveness degrades over time and to replace after "several (e.g., 1,000) uses"; explicit output parameters (13kV, 0.7mA, 10µS); and instructions for reporting adverse events to the manufacturer and MedWatch. The labeling comprehension study also demonstrated that 15 subjects understood the cautionary language and instructions for use.
    V. PopulationSafe and effective in the intended user population (adults and adolescents). Neonates, infants, and children excluded.Achieved for adults; extrapolated for adolescents. The clinical trial enrolled healthy subjects 18-65 years of age. Data was extrapolated to adolescents "based on the similarities of skin between adults and adolescents." Labeling explicitly states safety and effectiveness "has not been established in neonates, infants and children."

    Study Details:

    1. Sample sizes used for the test set and the data provenance:

      • Test Set Sample Size: 53 healthy subjects (18-65 years of age) with a history of mosquito bite reaction. Randomized 1:1 into active treatment (n=27) and placebo (n=26) groups.
      • Data Provenance: The study was a clinical trial, implying prospective data collection. The location/country of origin of the data is not explicitly stated in the provided text, but it’s a regulatory submission to the FDA (indicating likely a US-based study or one for US market approval).
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

      • Not applicable / No external experts needed for ground truth. For this device, the "ground truth" for effectiveness was the subjects' self-reported itching via a Visual Analog Scale (VAS) and objective measurement of edema. The "ground truth" for safety was the monitoring of adverse events directly from subjects. There was no need for external expert consensus on an image or diagnostic finding.
    3. Adjudication method for the test set:

      • Not applicable. The primary outcome (reduction in itching) was a direct measurement from the subjects themselves (VAS scores), compared against a baseline. The secondary outcome (edema size) was also an objective measurement. There was no mention of an adjudication process involving multiple reviewers for subjective interpretation.
    4. 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:

      • No. This was not an MRMC comparative effectiveness study. This study evaluated the direct effectiveness of a physical device (Zap-It!) on human subjects, not a diagnostic AI system assisting human readers.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

      • Yes, in essence. The study evaluated the " Zap-It!" device's performance standalone, meaning its direct effect on individuals without any human intervention or interpretation of its output needed for the primary outcome. The device itself is not an AI algorithm, but a non-AI medical device.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

      • Outcomes Data: The primary ground truth was self-reported itching severity (patient-reported outcome) using a Visual Analog Scale (VAS).
      • Objective Measurement: A secondary outcome involved objective measurement of edema length and width from the mosquito bite.
      • Safety Monitoring: Direct observation/reporting of adverse events served as the ground truth for safety.
    7. The sample size for the training set:

      • Not applicable. The Zap-It! device contains no software or AI algorithms, so there was no "training set" in the context of machine learning. The clinical trial described served as the primary performance evaluation.
    8. How the ground truth for the training set was established:

      • Not applicable. As there was no training set for an AI algorithm, this question is not relevant.
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