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510(k) Data Aggregation

    K Number
    K213925
    Manufacturer
    Date Cleared
    2022-04-25

    (130 days)

    Product Code
    Regulation Number
    882.5810
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Myolyn, LLC

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

    The MyoCycle is intended for general rehabilitation for:

    1. Relaxation of muscle spasms
    2. Prevention or retardation of disuse atrophy
    3. Increasing local blood circulation
    4. Maintaining or increasing range of motion
    5. Muscle re-education
    Device Description

    The MyoCycle is a stationary Functional electrical stimulation (FES) cycle ergometer which is composed of:

    1. a motorized cycle ergometer
    2. an FES controller /stimulator
    3. a stimulation cable which connects the controller / stimulator to cutaneous electrodes (at maximum 20 cutaneous electrodes for 10 channels)
    4. cutaneous electrodes

    This system allows a person with impaired lower extremity movement to undertake cycle ergometry both actively (utilized FES evoked lower extremity muscle contractions) and passively (utilizing power developed by the ergometer's motor). The electric motor inside the MyoCycle ensures that the pedals always rotate at 35 revolutions per minute (r/min) (isokinetic cycling), so it automatically assists or resists the patient, depending on the magnitude and direction of the torque applied to the crank by the patient.

    The system software has four different configurations:

    1. Pro – allows for multiple users by storing unique user data that can be accessed by a unique user identification code; extended FES parameter adjustability; up to six channels of stimulation
    2. Home – only stores data for one user; limited FES parameter adjustability; up to six channels of stimulation
    3. Pro Plus (+) – same as Pro but allows for up to ten channels of stimulation and uses patient cabling with additional leads
    4. Home Plus (+) – same as Home but allows for up to ten channels of stimulation and uses patient cabling with additional leads
    AI/ML Overview

    The provided document is an FDA 510(k) clearance letter for the MyoCycle MC-2 device. It describes the device, its intended use, and its substantial equivalence to a predicate device. However, it does not contain specific acceptance criteria, reported device performance metrics (numerical results), details about a test set (sample size, provenance), expert qualifications, adjudication methods, MRMC studies, or standalone algorithm performance data.

    The document primarily focuses on demonstrating substantial equivalence through:

    • Comparison of Indications for Use: Showing the MyoCycle MC-2 has substantially equivalent indications to the predicate device, with an added "muscle re-education" indication that is standard for this type of device and does not raise new safety/effectiveness questions.
    • Comparison of Technological Characteristics: Highlighting similarities and minor differences (e.g., increased stimulation channels, wider parameter range, larger touchscreen, wireless communication, database interface) that do not raise new safety/effectiveness questions.
    • Performance Data (Bench Testing): Stating that testing was conducted to ensure equivalent functionality and verify performance to specifications, primarily through a review of documentation and bench testing against recognized consensus standards (e.g., electrical safety, EMC, usability).

    Therefore, I cannot populate most of the requested sections as the information is not present in the provided text.

    Here's what can be extracted based on the document:


    Acceptance Criteria and Study Details for MyoCycle MC-2

    The FDA 510(k) submission for the MyoCycle MC-2 primarily relies on demonstrating substantial equivalence to a predicate device (MyoCycle MC-HP-1, K170132) rather than presenting new clinical performance data with numeric acceptance criteria for specific outcomes. The "performance data" referred to in the document pertains to bench testing against recognized consensus standards to ensure safety and functionality, not a clinical study to evaluate device effectiveness in patients.

    1. Table of Acceptance Criteria and Reported Device Performance

    The document describes no specific quantitative acceptance criteria or reported device performance metrics in a clinical context (e.g., "device achieved X% accuracy," "device improved range of motion by Y degrees"). Instead, the "acceptance criteria" are implied to be the successful demonstration of:

    • Substantially equivalent Indications For Use.
    • Similar technological characteristics that do not raise new questions of safety or effectiveness.
    • Compliance with recognized consensus standards for device safety and electrical performance.
    Acceptance Criteria CategoryReported Device Performance (as per document)
    Indications for Use Equivalence"The MyoCycle MC-2 device's Indications for Use (IFU) Statement is substantially equivalent to that of the predicate device... addition of this indication... does not raise any new questions of safety and effectiveness."
    Technological Characteristics Equivalence"The MyoCycle MC-2 has similar technological characteristics and output specifications to those of the predicate device... The different characteristics and specifications do not raise new questions of safety and effectiveness."
    Safety and Functional Performance"MYOLYN's non-clinical testing, including bench testing against recognized consensus standards, have demonstrated that the MC-2 device is as safe and effective as the predicate device and is therefore substantially equivalent."
    Stimulator OutputOutput characteristic measurement of new device confirmed technical specifications: 0-140 mA charge balanced stimulator (predicate: 0-126 mA).
    Compliance with StandardsSystem testing made general use of recognized consensus standards (e.g., ANSI AAMI ES60601-1, IEC 60601-1-2, 60601-1-6, 60601-1-11, 60601-2-10).

    2. Sample Size Used for the Test Set and Data Provenance

    The document does not describe a test set in the conventional sense of a patient-based clinical study. The "testing" mentioned is primarily non-clinical bench testing and review of documentation. Therefore, information on sample size and data provenance for a clinical test set is not provided.

    3. Number of Experts Used to Establish Ground Truth and Qualifications

    Not applicable, as no clinical test set requiring expert ground truth or adjudication is described.

    4. Adjudication Method for the Test Set

    Not applicable, as no clinical test set requiring adjudication is described.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was Done

    No, an MRMC comparative effectiveness study was not mentioned or described in the provided document. The submission focuses on substantial equivalence based on technological characteristics and bench testing, not on comparative clinical effectiveness with human readers/users.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was Done

    Not applicable. The MyoCycle MC-2 is a physical medical device (an FES cycle ergometer) rather than a software algorithm intended for standalone diagnostic or interpretive performance. Its functionality is tied to its interaction with a user.

    7. The Type of Ground Truth Used

    For the bench testing and design verification, the "ground truth" would be established by the specifications defined for the device and the requirements of the recognized consensus standards. For example, an electrical safety standard dictates specific performance criteria that the device must meet, and this standard serves as the "ground truth" for compliance. There is no mention of patient-level "ground truth" (e.g., pathology, outcomes data) for clinical efficacy.

    8. The Sample Size for the Training Set

    Not applicable. The document describes a physical medical device, not an AI/ML algorithm that requires a training set.

    9. How the Ground Truth for the Training Set Was Established

    Not applicable, as no training set is described.

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    K Number
    K170132
    Manufacturer
    Date Cleared
    2017-04-25

    (98 days)

    Product Code
    Regulation Number
    882.5810
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    MYOLYN, LLC

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

    The MyoCycle is intended for general rehabilitation for:

    1. Relaxation of muscle spasms
    2. Prevention or retardation of disuse atrophy
    3. Increasing local blood circulation
    4. Maintaining or increasing range of motion
    Device Description

    The MyoCycle is a stationary FES cycle ergometer which is composed of:

    1. a motorized cycle ergometer
    2. an FES controller / stimulator
    3. a stimulation cable which connects the controller / stimulator to cutaneous electrodes (at maximum 12 cutaneous electrodes for 6 channels)
    4. cutaneous electrodes
      This system allows a person with impaired lower extremity movement to undertake cycle ergometry both actively (utilized FES evoked lower extremity muscle contractions) and passively (utilizing power developed by the ergometer's motor). The electric motor inside the MyoCycle ensures that the pedals always rotate at 35 revolutions per minute (r/min) (isokinetic cycling), so it automatically assists or resists the patient, depending on the magnitude and direction of the torque applied to the crank by the patient. The system software operates in two modes:
    5. Pro mode allows for multiple users by storing unique user data that can be accessed by a unique user identification code
    6. Home mode only stores data for one user
    AI/ML Overview

    This document is a 510(k) summary for the MyoCycle Home and MyoCycle Pro devices, which are functional electrical stimulation (FES) cycle ergometers. It seeks to establish substantial equivalence to a predicate device, the RT300-S (K050036), manufactured by Restorative Therapies Inc.

    Here's the breakdown of the acceptance criteria and study information based on the provided document:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly state "acceptance criteria" in a quantitative manner (e.g., minimum accuracy percentages, specific thresholds for safety measurements). Instead, it describes a series of tests performed to demonstrate substantial equivalence to a predicate device, validating its safety and effectiveness. The "reported device performance" is framed in terms of meeting recognized consensus standards and demonstrating similar functionality and safety characteristics to the predicate.

    Given the information, the table would look like this, extrapolating "acceptance criteria" from the performed tests and implied equivalency:

    Acceptance Criteria (Implied)Reported Device Performance
    Functional Equivalence to Predicate Device
    - Equivalent functionality specified and implemented- "Review of user documentation for predicate device" confirmed equivalent functionality is specified and implemented in the MyoCycle.
    - MyoCycle IFU Statement is substantially equivalent- MyoCycle IFU Statement is identical to the RT300-S (K050036) for relaxation of muscle spasms, prevention/retardation of disuse atrophy, increasing local blood circulation, and maintaining/increasing range of motion.
    Technical Specifications and Output Characteristics
    - Technical specifications for new device confirmed- "Output characteristic measurement of new device" confirmed technical specifications for the MyoCycle.
    - Similar output characteristics to predicate device- Stimulator delivers 0-126 mA charge balanced, compared to predicate's 0-140 mA. This difference is not stated to raise new safety/effectiveness questions. Other technological characteristics (power source, flywheel, seating, passive cycling) are similar or equivalent in function.
    Performance to Specification
    - Verified performance to specification- "Conduct of system testing" verified performance to specification.
    Safety and Essential Performance (Compliance with Standards)
    - Compliance with IEC 60601-2-10 Ed. 2.0 (Nerve/Muscle Stimulators)- MyoCycle met this standard.
    - Compliance with AAMI ANSI ES60601-1 (General Safety/Performance)- MyoCycle met this standard.
    - Compliance with IEC 60601-1-2 Ed. 4.0 (EMC)- MyoCycle met this standard.
    - Compliance with IEC 60601-1-11 Ed. 2.0 (Home Healthcare)- MyoCycle met this standard.
    - Compliance with AAMI ANSI HA60601-1-11 (Home Healthcare)- MyoCycle met this standard.
    Usability/Operability by Intended Users
    - Operable by lay operators- Validated with five lay operators using the device with an able-bodied, simulated patient.
    - Operable by clinician operators- Validated with seven clinician operators using the device with six spinal cord injured patients.
    - Operable by patient operators (without assistance)- Validated with five spinal cord injured patients using the device without assistance.

    2. Sample Sizes Used for the Test Set and the Data Provenance

    The document describes several "testing" activities, primarily focused on verification and usability, rather than a traditional "test set" for an AI algorithm's performance against a ground truth.

    • Lay Operators Test: 5 lay operators, with an able-bodied, simulated patient. (Likely prospective, country of origin not specified but assumed US given FDA filing)
    • Clinician Operators Test: 7 clinician operators, with 6 spinal cord injured patients. (Likely prospective, country of origin not specified but assumed US)
    • Patient Operators Test: 5 spinal cord injured patients, using the device without assistance. (Likely prospective, country of origin not specified but assumed US)

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts

    This type of information is not applicable and not present in the document. The "testing" described is about evaluating device function, safety, and usability by various user types, not about establishing ground truth for an AI algorithm's diagnostic or predictive output. The "experts" involved are the clinician operators (7 of them), whose specific qualifications (e.g., years of experience, specific medical specialty beyond "clinician operator") are not detailed.

    4. Adjudication Method for the Test Set

    Not applicable as there is no specific "ground truth" to adjudicate for these functional and usability tests. The assessment would likely involve observing successful operation, gathering user feedback, and confirming adherence to operational specifications.

    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

    Not applicable. The MyoCycle is an FES cycle ergometer, not an AI-powered diagnostic or assistive tool for human readers. There is no AI component described in the context of improving human reader performance.

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

    Not applicable. The MyoCycle is a physical medical device (an FES cycle ergometer) that primarily relies on its hardware and embedded software for its function, not a standalone AI algorithm operating independently. While it has embedded microcontrollers running custom software, this is for controlling the mechanical and stimulation aspects of the device, not a diagnostic or predictive AI.

    7. The Type of Ground Truth Used (Expert Consensus, Pathology, Outcomes Data, etc.)

    Ground truth, in the context of evaluating an AI algorithm's performance against a known reality, is not a concept explicitly applied here. The "truth" being established is the device's adherence to engineering specifications, safety standards, and its ability to be used effectively by its intended operators (lay, clinician, and patient). This is achieved through direct performance verification and observation during testing.

    8. The Sample Size for the Training Set

    Not applicable. The MyoCycle is not an AI system that undergoes "training" on a data set in the way a machine learning model would. Its development would involve engineering design, prototyping, and iterative testing, not data-driven training.

    9. How the Ground Truth for the Training Set was Established

    Not applicable, as there is no "training set" in the context of AI described for this device.

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