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510(k) Data Aggregation
(376 days)
This system is indicated for pain management in adults who have severe intractable chronic pain of peripheral nerve origin, as the sole mitigating agent, or as an adjunct to other modes of therapy used in a multidisciplinary approach. The system is not intended to treat pain in the craniofacial region.
The trial devices are solely used for trial stimulation (no longer than 30 days) to determine efficacy before recommendation for a permanent (long term) device.
The Nalu Neurostimulation System for Peripheral Nerve Stimulation (also referred to as the "Nalu System") is used for peripheral nerve stimulation to provide therapeutic relief for chronic, intractable pain of peripheral nerve origin. The Nalu System incorporates a miniature implantable pulse generator, powered by an externally worn Therapy Disc device. The Nalu Neurostimulation therapy utilizes pulsed electrical current to create an energy field that acts on the peripheral nerves to inhibit the transmission of pain signals to the brain. The Nalu System may be implanted following a successful trial period using the Nalu Neurostimulation trial system. The Nalu System is comprised of 5 elements: Nalu Implantable Pulse Generator, Leads, Surgical and Trial Tools, Externally worn Therapy Disc, and Clinician Programmer and Remote Control.
This document describes a 510(k) premarket notification for the Nalu Neurostimulation System for Peripheral Nerve Stimulation. The submission aims to establish substantial equivalence to a previously cleared predicate device (K183579), primarily focusing on an update to the device's Magnetic Resonance (MR) Conditional Labeling to include full body scans.
Based on the provided text, there is no acceptance criteria table or specific study performance data for a device meeting acceptance criteria in the traditional sense of an AI/ML model for diagnostic or predictive purposes. This document is a regulatory submission for a physical medical device (implantable neurostimulator) and its associated external components and software, not an AI/ML diagnostic software. The "performance" discussed here relates to the safety and functionality of the device itself, particularly its compatibility with MRI, rather than the accuracy of a diagnostic algorithm.
Therefore, many of the requested elements (e.g., sample size for test set, data provenance, number of experts for ground truth, adjudication method, MRMC study, standalone performance, training set details) are not applicable to this type of medical device submission.
However, I can extract the relevant information regarding the device's "performance" as presented in the context of this 510(k) submission, specifically concerning the MRI compatibility, as this is the primary change necessitating the resubmission.
Summary of Acceptance Criteria and Device (MRI) Performance:
Since this is not an AI/ML diagnostic device, the "acceptance criteria" are not framed in terms of metrics like accuracy, sensitivity, or specificity. Instead, they are related to established safety standards for medical devices, particularly regarding MRI compatibility. The "device performance" refers to the results of testing performed to ensure these safety standards are met.
1. Table of Acceptance Criteria and Reported Device Performance (Focusing on MRI Compatibility):
| Acceptance Criteria Category | Specific Criteria (Implicitly based on standards) | Reported Device Performance / Assessment |
|---|---|---|
| Magnetic Resonance (MR) Safety and Compatibility for Full Body Scans | Conformance to MR Conditional Labeling for full body scans. | Testing included in this submission demonstrates the safety and compatibility of the Nalu System for PNS in the Magnetic Resonance (MR) Environment for full body. |
| Magnetically Induced Displacement Force | Meet limits defined in ASTM F2052-15 | Testing performed to standard. |
| Magnetically Induced Torque | Meet limits defined in ASTM F2213-17 | Testing performed to standard. |
| MR Image Artifacts | Meet limits defined in ASTM F2119-2013 | Testing performed to standard. |
| Safety of Active Implantable Medical Device in MRI | Conformance to ISO/TS 10974 | Testing performed to standard. |
| General Device Safety and Performance | Conformance to ISO 14708 (Parts 1 & 3) | Testing performed to standard. |
| Design Controls | Adherence to 21 CFR 820.30 | Nalu follows these procedures. |
| Risk Management | Adherence to ISO 14971 | Nalu follows these procedures. |
| Quality Management System | Adherence to ISO 13485:2016 | Nalu follows these procedures. |
| Biocompatibility | Demonstrated through testing. | Testing performed. |
| Sterilization | Demonstrated through testing. | Testing performed. |
| Human Factors and Usability | Demonstrated through testing. | Testing performed. |
| Functional Specification | Device meets user needs. | Validation and performance testing demonstrate this. |
| Substantial Equivalence | Identical indications for use, performance, and technological characteristics to predicate. | Stated as "identical" and "no differences that would impact safety or effectiveness." The only noted difference is the updated MR Conditional Labeling, which is supported by new testing. |
2. Sample Size Used for the Test Set and the Data Provenance:
- Sample Size: The document does not specify the sample sizes used for the engineering tests (e.g., number of devices tested for MRI compatibility, displacement, torque, or artifacts). These are typically bench tests on physical units, not clinical data sets.
- Data Provenance: Not applicable in the context of clinical data. The tests are laboratory-based, non-clinical performance and bench testing.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts:
- Not Applicable. This is not a study assessing the performance of a diagnostic algorithm where expert ground truth is established for medical images. The "ground truth" for this device's performance relies on engineering measurements and adherence to international and national standards (e.g., ISO, ASTM) for device safety and functionality.
4. Adjudication Method for the Test Set:
- Not Applicable. As there are no human readers or diagnostic interpretations involved in the "test set" (which consists of physical device tests), no adjudication method is necessary.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done:
- No. This type of study is typically done for diagnostic imaging devices or AI tools that assist human readers. This submission is for an implantable neurostimulation system, not a diagnostic imaging or AI assistance tool.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done:
- Not Applicable. There is no "algorithm only" performance being evaluated in this submission in the context of diagnostic AI. The device's functionality (e.g., electrical stimulation parameters) and safety (e.g., MRI compatibility) are evaluated.
7. The Type of Ground Truth Used:
- The "ground truth" for the device's safety and performance is established through adherence to recognized international and national consensus standards (e.g., ISO/TS 10974, ISO 14708, ASTM F2052-15, ASTM F2213-17, ASTM F2119-2013) and engineering verification and validation testing. It is not based on expert consensus on medical image interpretations or clinical outcomes data in the context of diagnostic accuracy.
8. The Sample Size for the Training Set:
- Not Applicable. This is not an AI/ML device that requires a training set of data.
9. How the Ground Truth for the Training Set was Established:
- Not Applicable. (See point 8).
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(29 days)
Spinal Cord Stimulation (SCS)
This system is indicated as the sole mitigating agent, or as an adjunct to other modes of therapy used in a multidisciplinary approach for chronic, intractable pain of the trunk and/or limbs, including unilateral pain. The trial devices are solely used for trial stimulation (no longer than 30 days) to determine efficacy before recommendation for a permanent (long term) device.
Peripheral Nerve Stimulation (PNS)
This system is indicated for pain management in adults who have severe intractable chronic pain of peripheral nerve origin, as the sole mitigating agent, or as an adjunct to other modes of therapy used in a multidisciplinary approach. The system is not intended to treat pain in the craniofacial region.
The trial devices are solely used for trial stimulation (no longer than 30 days) to determine efficacy before recommendation for a permanent (long term) device.
The Nalu Neurostimulation System has been cleared by the FDA for spinal cord stimulation (SCS; K203547) and peripheral nerve stimulation (PNS; K203547) to provide therapeutic relief for chronic, intractable pain of the trunk and/or limbs including unilateral, bilateral nerve pain. The Nalu Neurostimulation therapy utilizes pulsed electrical current to create an energy field that acts on nerves in the spinal cord or peripheral nerve to inhibit the transmission of pain signals to the brain. The Nalu System is implanted only following a successful trial period using the Nalu Neurostimulation trial system.
The Nalu Neurostimulation System consists of five (5) components. The implantable pulse generator (IPG) provides electrical stimulation pulses that are transmitted through the leads, to the desired location, either on the spinal cord or peripheral nerve site. The leads are implantable and designed to deliver electrical pulses to the nerves via an array of four (4) or eight (8) cylindrical electrodes at the distal end. The Trial Therapy Disc or the Therapy Disc houses the battery and electronics for RF power and controls the IPG for therapy delivery via the remote programmer. Implantation of the Nalu IPG and lead components for Spinal Cord Stimulation (SCS) or Peripheral Nerve Stimulation (PNS) is performed via standard surgical tools and techniques, as described in (K203547).
This looks like a 510(k) summary, which typically focuses on demonstrating substantial equivalence to a predicate device rather than presenting a standalone study with specific acceptance criteria and performance metrics for a novel AI device. The document mostly highlights the similarities between the subject device (K221376) and its predicate (K203547).
Based on the provided text, there is no specific AI component or algorithm mentioned, nor are there acceptance criteria or a study described to demonstrate the performance of such a component. The device is a "Nalu Neurostimulation System" which appears to be a hardware device for spinal cord and peripheral nerve stimulation. The changes referenced are related to "Clinician Programmer" software differences for therapy configuration, rather than an AI/ML algorithm that interprets data or makes diagnostic decisions.
Therefore, most of the questions you've asked about acceptance criteria, study details, ground truth, sample sizes, and involvement of experts/AI effectiveness are not applicable to this submission as it doesn't describe an AI/ML device in the context of the typical information provided if it were an AI/ML device.
Here's an attempt to answer your questions based only on the provided text, highlighting where the information is absent because the device does not appear to be an AI/ML product as you seem to be assuming:
1. A table of acceptance criteria and the reported device performance
The document does not explicitly state acceptance criteria in the form of performance metrics (e.g., sensitivity, specificity, AUC) that would be expected for an AI device. Instead, it demonstrates an acceptance of "substantial equivalence" to a predicate device by showing that the technological characteristics and indications for use are the same, and that non-clinical testing confirms safety and performance within established limits.
The tables (Table 1, Table 2, Table 3) provided in the document compare the technological characteristics and therapeutic parameters of the subject device (K221376) and its predicate device (K203547). The "reported device performance" in this context is that these characteristics are "Same as predicate" or that any differences "do not impact the safety and effectiveness of the device."
Table of Acceptance Criteria and Reported Device Performance (as inferred from the document):
| Acceptance Criteria Category | Specific Criteria (Implicitly Met by Predicate Equivalence) | Reported Device Performance (Subject Device K221376) |
|---|---|---|
| Product Code and Class | GZB and GZF, Class II (for SCS and PNS) | Same as predicate (K203547) |
| Regulation Number | 21 CFR 882.5880 (GZB), 21 CFR 882.5870 (GZF) | Same as predicate (K203547) |
| Classification Name | Implanted spinal cord stimulator for pain relief / Implanted peripheral nerve stimulator for pain relief | Same as predicate (K203547) |
| Trade Name | Nalu Neuromodulation System | Same as predicate (K203547) |
| Manufacturer | Nalu Medical, Inc. | Same as predicate (K203547) |
| Intended Use | Stimulation of spinal cord/peripheral nerves for chronic intractable pain | Same as predicate (K203547) |
| Indications for Use | For chronic, intractable pain of the trunk and/or limbs (SCS); For severe intractable chronic pain of peripheral nerve origin (PNS) | Same as predicate (K203547) |
| Clinical Application | Treatment of chronic, intractable pain | Same as predicate (K203547) |
| Prescription Use | Yes | Same as predicate (K203547) |
| Environmental Use | Hospital, Home | Same as predicate (K203547) |
| Intended Clinician | Orthopedic, Neurosurgeon, Anesthesiologist | Same as predicate (K203547) |
| Intended User | Physician, Layperson | Same as predicate (K203547) |
| Implant Site, Leads | Epidural space (SCS) or peripheral nerve areas (PNS) | Same as predicate (K203547) |
| Principle of Operation | Stimulation of spinal cord/peripheral nerve to provide therapeutic relief | Same as predicate (K203547) |
| Mode of Action | RF wireless transmission of energy to deliver stimulation | Same as predicate (K203547) |
| Software Level of Concern | Moderate | Same as predicate (K203547) |
| Therapeutic Electrical Parameters (e.g., Pulse Frequency, Pulse Width, Current, Voltage, Waveform, Charge/Current Density, Net Charge, Power, Pulse Delivery Mode, etc.) | Within specified ranges and identical to predicate | Same as predicate (K203547) |
| Clinician Programmer Software | Software to communicate to Trial Therapy or Therapy Disc; Manual control of current and optional model-based allocation; Safety parameters (charge per phase, charge density, current density) unchanged and within limits. | Differences do not impact safety and effectiveness. New method is an option for faster programming, with patient feedback for effectiveness. |
| Patient Remote Control Software | Software to pair with Trial Therapy or Therapy Disc; SW update to reflect Clinician Programmer changes | No impact on safety or effectiveness (implied by lack of further analysis). |
| Externally Worn Devices Firmware | Firmware update to reflect Clinician Programmer and Remote Control changes | No impact on safety or effectiveness (implied by lack of further analysis). |
| Labeling | Updated to support Clinical Programmer Current Steering options | Differences to labeling do not impact safety and effectiveness. |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
Not applicable. The document states, "Nalu Medical determined that bench and non-clinical testing are sufficient to demonstrate that the Nalu Neurostimulation system is as safe and effective as the predicate device." No clinical data (which might involve a test set, sample size, or patient data provenance) was required or submitted for this 510(k) submission, as the device's substantial equivalence was established through non-clinical testing and comparison to the predicate.
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)
Not applicable. As no clinical study or test set for an AI/ML algorithm was conducted/submitted, there was no need for experts to establish ground truth. The device is a neurostimulation system, not an AI diagnostic or interpretive tool.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. No test set requiring adjudication was used.
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. This device is not an AI-assisted diagnostic or interpretive tool, and no MRMC study was performed.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This device is not an AI algorithm. Its functionality involves hardware for neurostimulation, with software controlling the programming and delivery of stimulation.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
Not applicable. Ground truth for an AI algorithm is not relevant here as the device is not an AI/ML product. The "ground truth" for this submission is implicitly the established safety and effectiveness of the predicate device, validated through non-clinical engineering and performance testing.
8. The sample size for the training set
Not applicable. No AI/ML model training was described or performed for this device.
9. How the ground truth for the training set was established
Not applicable. As no training set for an AI/ML model was used, no ground truth needed to be established for it.
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(111 days)
For Spinal Cord Stimulation: This system is indicated as the sole mitigating agent, or as an adjunct to other modes of therapy used in a multidisciplinary approach for chronic, intractable pain of the trunk and/or limbs, including unilateral or bilateral pain. The trial devices are solely used for trial stimulation (no longer than 30 days) to determine efficacy before recommendation for a permanent (long term) device.
For Peripheral Nerve Stimulation: This system is indicated for pain management in adults who have severe intractable chronic pain of peripheral nerve origin, as the sole mitigating agent, or as an adjunct to other modes of therapy used in a multidisciplinary approach. The system is not intended to treat pain in the craniofacial region. The trial devices are solely used for trial stimulation (no longer than 30 day) to determine efficacy before recommendation for a permanent (long term) device.
The Nalu Neurostimulation System has been cleared by the FDA for spinal cord stimulation, and peripheral nerve stimulation (K201618), to provide therapeutic relief for chronic, intractable pain of the trunk and/or limbs including unilateral, bilateral nerve pain. The Nalu Neurostimulation therapy utilizes pulsed electrical current to create an energy field that acts on nerves in the spinal cord or peripheral nerve to inhibit the transmission of pain signals to the brain. The Nalu System is implanted only following a successful trial period using the Nalu Neurostimulation trial system. The Nalu Neurostimulation System consists of several components. The implantable pulse generator (IPG) provides electrical stimulation pulses that are transmitted through the leads, to the desired location, either on the spinal cord or peripheral nerve site. The leads are implantable and designed to deliver electrical pulses to the nerves via an array of four or eight cylindrical electrodes at the distal end. The Trial Therapy Disc or the Therapy Disc houses the battery and electronics for RF power and controls the IPG for therapy delivery via the remote programmer. Implantation of the Nalu IPG and lead components for spinal cord stimulation (SCS) or peripheral nerve stimulation (PNS) is performed via standard surgical tools and techniques, as described in (K201618).
Here's a 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 present a table of acceptance criteria or performance metrics in the way one might expect for a diagnostic or AI-based device's clinical performance. Instead, the submission describes the Nalu Neurostimulation System and its substantial equivalence to predicate devices, focusing on technical specifications and safety rather than a measurable clinical outcome in a performance study.
The closest to "acceptance criteria" are the parameters defining the device's operational range, and the "reported device performance" is that these parameters are within acceptable limits compared to predicate devices, demonstrating substantial equivalence.
| Acceptance Criteria (Implied) | Reported Device Performance |
|---|---|
| Pulse Width Range | Subject Device: 12 to 2000 µs (Predicate: 12 to 1000 µs; Reference: 50 to 1000 µs) - Analysis: Available programmable pulse width will be capped to maintain Maximum Phase Charge and Maximum Charge Density within limits of Medtronic Xtrel reference device limit. No impact to safety and effectiveness. |
| Maximum Phase Charge (300 Ohms) | Subject Device: 18.0 µC/pulse (Predicate: 10.2 µC/pulse; Reference: 18.0 µC/pulse) - Analysis: Same as Medtronic Xtrel reference device. |
| Maximum Phase Charge (500 Ohms) | Subject Device: 18.0 µC/pulse (Predicate: 10.2 µC/pulse; Reference: 14.2 µC/pulse) - Analysis: Same as Medtronic Xtrel reference device at 300 Ohms. Maximum Phase Charge constant in current controlled system and enforced below maximum reference device value (at 300 Ohms). No impact to safety and effectiveness. |
| Maximum Phase Charge (800 Ohms) | Subject Device: 18.0 µC/pulse (Predicate: 10.2 µC/pulse; Reference: 10.5 µC/pulse) - Analysis: Same as Medtronic Xtrel reference device at 300 Ohms. Maximum Phase Charge constant in current controlled system and enforced below maximum reference device value (at 300 Ohms). No impact to safety and effectiveness. |
| Maximum Charge Density (300 Ohm) | Subject Device: 146.94 µC/cm² (Predicate: 83.3 µC/cm²; Reference: 150.0 µC/cm²) - Analysis: Within maximum limit as set by Medtronic Xtrel reference device. |
| Maximum Charge Density (500 Ohm) | Subject Device: 146.94 µC/cm² (Predicate: 83.3 µC/cm²; Reference: 118.3 µC/cm²) - Analysis: Same as Medtronic Xtrel reference device at 300 Ohms. Maximum Phase Charge constant in current controlled system and enforced below maximum reference device value (at 300 Ohms). No impact to safety and effectiveness. |
| Maximum Charge Density (800 Ohm) | Subject Device: 146.94 µC/cm² (Predicate: 83.3 µC/cm²; Reference: 87.5 µC/cm²) - Analysis: Same as Medtronic Xtrel reference device at 300 Ohms. Maximum Phase Charge constant in current controlled system and enforced below maximum reference device value (at 300 Ohms). No impact to safety and effectiveness. |
| Dosage Time Range | Subject Device: On spans 1 ms to 1000 ms, Off spans 1 ms to 2000 ms (Predicate: On spans 1 ms to 25 ms) - Analysis: This parameter has no impact on safety and effectiveness. Increasing the range allows the clinician to offer more flexibility to accommodate patient preferences. |
| All other parameters (Frequency, Current/Voltage Regulated, Output Voltage/Current, Waveform, Pulse Shape, Maximum Current Density, Net Charge, Average Phase Power/Density, Pulse Delivery Mode, Current Path Options, Program Cycle, Pulse Pattern, Daily Therapy Time, Transmit Frequency) | All "Same as predicate." or "Same as predicate/reference." indicating compliance with established safe and effective parameters. |
2. Sample Size Used for the Test Set and Data Provenance
The document does not describe a clinical performance study with a "test set" from real patient data in the context of an AI/diagnostic device. Instead, it refers to "testing" performed to support the safety and performance of the device. This testing appears to be primarily non-clinical (bench/laboratory) testing of electrical and software parameters.
Therefore, there is no mention of a sample size for a test set of patient data, nor data provenance (country of origin, retrospective/prospective).
3. Number of Experts Used to Establish Ground Truth and Qualifications
This information is not applicable and not provided. The study focuses on evaluating technical parameters against established medical device safety standards and comparison to predicate devices, not on a ground truth established by medical experts for diagnostic accuracy.
4. Adjudication Method
This information is not applicable and not provided, as the submission does not involve expert review or adjudication of clinical cases for diagnostic or performance accuracy.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done
No, an MRMC comparative effectiveness study was not done. This device is a neurostimulation system for pain relief, not a diagnostic imaging or AI-assisted diagnostic tool that would typically undergo MRMC studies to assess human reader improvement. The submission focuses on demonstrating substantial equivalence in technical characteristics and safety.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done
This concept is not directly applicable. The "device" itself (Nalu Neurostimulation System) is a therapeutic electrical stimulator. The "software" changes described are modifications to its operational parameters. The performance testing referenced is likely to evaluate the hardware and software functionality as an integrated system, ensuring it operates within safe and effective limits. There isn't an "algorithm only" component in the sense of an AI interpreting inputs to provide diagnostic outputs.
7. The type of ground truth used
The "ground truth" for this submission appears to be regulatory and engineering standards, and the specifications and performance characteristics of legally marketed predicate and reference devices. The evaluation focuses on whether the subject device's technical specifications and functionality (particularly the updated software parameters) fall within the established safe and effective ranges of these comparable devices.
8. The sample size for the training set
This information is not applicable and not provided. The device is not an AI/ML model that would train on a dataset. The software changes are operational programming changes for the neurostimulator.
9. How the ground truth for the training set was established
This information is not applicable and not provided, as there is no "training set" for an AI/ML model.
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(90 days)
For Spinal Cord Stimulation
This system is indicated as the sole mitigating agent, or as an adjunct to other modes of therapy used in a multidisciplinary approach for chronic, intractable pain of the trunk and/or limbs, including unilateral pain. The trial devices are solely used for trial stimulation (no longer than 30 days) to determine efficacy before recommendation for a permanent (long term) device.
The Nalu Neurostimulation system is consisted of five components. The implantable pulse generator (IPG) provides electrical stimulation pulses that are transmitted through the leads, through the dura, to the desired location of the spinal cord site. The leads are implantable and designed to deliver electrical pulses to the spinal cord in the epidural space via an array of eight cylindrical electrodes at the distal end. The leads may be secured in place with the Nalu Lead Anchor. The Trial Therapy Disc or the Therapy Disc houses the battery and electronics for RF power and controls the IPG for therapy delivery via the remote programmer. Implantation of the Nalu IPG and lead components for Spinal Cord Stimulation (SCS) is performed via standard SCS surgical tools and techniques, as described in (K183047).
The provided text is a 510(k) Summary for the Nalu Neurostimulation System, which is an implanted spinal cord stimulator for pain relief. The document focuses on demonstrating substantial equivalence to a previously cleared device (K183047) and specifically addresses updated magnetic resonance imaging (MRI) conditional labeling for full-body scans.
Here's an analysis of the acceptance criteria and the study information based on the provided text:
1. Table of acceptance criteria and the reported device performance
The document does not explicitly state numerical acceptance criteria for performance metrics (e.g., sensitivity, specificity, accuracy) because it is a submission for a spinal cord stimulator, not an AI/imaging device with such metrics. Instead, the "acceptance criteria" here relate to demonstrating safety and effectiveness for a broader indication (full-body MRI scans) and substantial equivalence to the predicate device.
The reported device performance primarily focuses on the Magnetic Resonance (MR) Conditional Labeling. The previous predicate device (K183047) had MR Conditional Labeling only for local RF coils (head, foot/ankle, knee, or wrist). The current submission proposes an update to include full-body MR Conditional Labeling.
The acceptance criteria implicitly derive from the standards and guidance documents listed, ensuring that the device's behavior in an MRI environment (e.g., displacement force, magnetically induced torque, image artifacts) is safe and within established limits for full-body scans.
| Acceptance Criteria Category | Reported Device Performance (Summary from text) |
|---|---|
| Intended Use & Indications | Substantially equivalent to predicate: "stimulation of the spinal cord for treatment of chronic, intractable pain" including full body pain. |
| Technological Characteristics | "All of the physical and therapeutic attributes... share the same technological characteristics and has no differences that would impact safety or effectiveness." |
| MRI Safety for Full Body | Nalu performed MRI testing on the standard horizontal MR bore system to support the safety of the RF body coil. Proposed an update to the MR Conditional Labeling with the full body scan. |
| Compliance with Standards | Device meets applicable standards and guidance documents, including ISO/TS 10974, ISO 14708, ASTM F2052-15, ASTM F2213-17, ASTM F2129-2013 (related to MRI safety). |
| Clinical Performance | Bench and non-clinical testing are sufficient; device is safe and effective as the predicate. Clinical performance data explicitly stated as not required. |
2. Sample size used for the test set and the data provenance
The document does not specify a "test set" in the context of an imaging AI device with a dataset of patient images. The testing conducted was primarily nonclinical performance testing (bench testing) related to MRI safety and device functionality.
- Sample Size: Not applicable in the typical sense of patient samples for an AI model. The testing involved physical devices or components. The number of hardware units tested for MRI compatibility is not specified.
- Data Provenance: Not applicable in the geopolitical or retrospective/prospective sense. The data is generated from laboratory (bench) testing.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This information is not applicable to this 510(k) submission. Ground truth, in the context of expert consensus, is typically established for diagnostic or screening devices evaluating medical images. This submission is for an implanted neurostimulation system, and the primary focus of the new data is on MRI compatibility for the physical device, not an interpretation of clinical findings by experts.
4. Adjudication method for the test set
This information is not applicable for the same reasons as point 3. Adjudication methods are used to resolve discrepancies in expert ground truth labeling.
5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done
No, an MRMC comparative effectiveness study was not done. This type of study is relevant for diagnostic or screening devices where human readers provide interpretations, and the AI's impact on their performance is evaluated. This 510(k) is for a physical implantable device, and the new data concerns its safety in an MRI environment.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This concept is not applicable to this device. A spinal cord stimulator does not have an "algorithm-only" performance in the sense of an AI diagnostic tool. Its performance is its ability to deliver stimulation and its safety profile, which was assessed through bench testing.
7. The type of ground truth used
The "ground truth" for the nonclinical testing primarily refers to established engineering and medical device safety standards for:
- MRI Compatibility: Defined by standards like ISO/TS 10974, ASTM F2052-15 (magnetically induced displacement force), ASTM F2213-17 (magnetically induced torque), and ASTM F2129-2013 (MR image artifacts). The "ground truth" is that the device must meet the safety limits defined by these standards when exposed to full-body MRI conditions.
- Biocompatibility: Assessed to ensure the materials are safe for implantation.
- Sterilization Validation: Ensures the device can be adequately sterilized.
- Functional Specifications: The device must meet its intended operational parameters (e.g., stimulation delivery).
8. The sample size for the training set
This information is not applicable. The device is an implanted hardware system, not an AI model trained on a dataset.
9. How the ground truth for the training set was established
This information is not applicable for the same reasons as point 8.
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(99 days)
This system is indicated for pain management in adults who have severe intractable chronic pain of peripheral nerve origin, as the sole mitigating agent, or as an adjunct to other modes of therapy used in a multidisciplinary approach. The system is not intended to treat pain in the craniofacial region.
The trial devices are solely used for trial stimulation (no longer than 30 days) to determine efficacy before recommendation for a permanent (long term) device.
This submission will add 4 stimulation contact options to the predicate Nalu Neurostimulation System (also referred to as the "Nalu PNS System"). The Nalu PNS System is used for peripheral nerve stimulation to provide therapeutic relief for chronic, intractable pain of peripheral nerve origin. The Nalu PNS System incorporates a miniature implanted neurostimulator, powered by an externally worn Therapy Disc device. The Nalu Neurostimulation therapy utilizes pulsed electrical current to create an energy field that acts on the peripheral nerves to inhibit the transmission of pain signals to the brain. The Nalu PNS System may be implanted following a successful trial period using the Nalu PNS trial system.
The leads that were cleared with the Nalu PNS System featured 8 stimulation contacts. This submission will provide an optional use of leads with 4 stimulation contacts.
This document is a 510(k) premarket notification for a medical device called the "Nalu Neurostimulation System for PNS" (specifically, the 4-contact version). The purpose of a 510(k) is to demonstrate that a new device is "substantially equivalent" to a legally marketed predicate device. This document does NOT present a study that proves the device meets specific acceptance criteria through clinical performance data. Instead, it argues for substantial equivalence based on non-clinical performance testing because the changes are considered minor.
Therefore, many of the requested items related to clinical studies, ground truth establishment, expert adjudication, and MRMC studies are not applicable to this submission. The "acceptance criteria" here are demonstrating substantial equivalence through non-clinical testing.
Here's the breakdown based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The core "acceptance criteria" for this 510(k) submission revolve around demonstrating substantial equivalence to a predicate device, primarily the Nalu Neurostimulation System (K183579). This is achieved by showing that the new device (4 Contact PNS System) has the same intended use, similar technological characteristics, and that any differences do not raise new questions of safety or effectiveness.
The document demonstrates this through comparative tables and statements rather than a traditional pass/fail clinical study.
| Acceptance Criterion (Implicit for Substantial Equivalence) | Reported Device Performance (4 Contact PNS System) |
|---|---|
| Intended Use: Same as predicate. | Same: Indicated for pain management in adults with severe intractable chronic pain of peripheral nerve origin. Not for craniofacial region. Trial devices for stimulation (max 30 days). |
| Technological Characteristics: Similar to predicate, with differences not affecting safety/effectiveness. | Differences: - Number of Electrodes: 4 (vs. 8 in primary predicate). - Lead Length: 25 cm, 40 cm (vs. 40 cm, 60 cm in primary predicate). - Electrode Array Length: 21 mm (vs. 52 mm in primary predicate). - Electrode Spacing: 3.0 mm (vs. 4.0 mm in primary predicate). - Cable Features: Coiled Wires (vs. Multilumen tube in primary predicate). - Lead Anchor: Integrated Lead Tines (vs. Separate molded silicone anchor with Ti locking mechanism in primary predicate). Performance: All differences are stated to "not affect safety and effectiveness of intended use" and are within parameters of other reference devices. Tested through non-clinical means. |
| Therapeutic Attributes: Same as predicate. | Same: All parameters like pulse frequency, pulse width, current/voltage regulation, output current/voltage, waveform, pulse shape, maximum phase charge/density, net charge, average phase power/density, pulse delivery mode, current path options, software level of concern, program cycle, pulse pattern, dosage time, transmit frequency are identical to the predicate (K183579). |
| Biocompatibility: Meet standards. | Met: Same biocompatibility reports as predicate supported this device. Materials and processes previously assessed. |
| Sterilization: Meet standards. | Met: Ethylene Oxide sterilization, same as predicate. |
| Electrical & Mechanical Performance: Meet specifications, safe, and effective. | Met: Verification testing included electrical and mechanical tests. Validation, performance, and usability testing demonstrated device meets user needs. Conforms to applicable standards (ISO 14708-1, ISO 14708-3, IEC 62366-1, EN ISO 14971, ISO 11607, ISO 11135-1, CISPR 11). |
| Software Level of Concern: Moderate. | Met: Same as predicate (moderate). |
| Human Factors and Usability: Tested and met. | Met: Testing performed. |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: Not applicable. This submission relies on non-clinical performance testing (bench testing, verification, validation, biocompatibility) and a comparative analysis to a predicate device, as opposed to a clinical test set with a specific sample size of patients/cases.
- Data Provenance: Not applicable. There is no clinical data from patients/cases mentioned. The testing is internal (Nalu Medical) and presumably took place in the U.S.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications
- Not applicable. As there is no clinical test set requiring ground truth establishment by experts (e.g., for disease diagnosis or outcome evaluation), this information is not provided nor needed for this type of submission.
4. Adjudication Method for the Test Set
- Not applicable. No clinical test set or human interpretation requiring adjudication.
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. This device is an implanted neurostimulator, not an AI-assisted diagnostic imaging device for human readers. No MRMC study was conducted or is relevant to this submission.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done
- Not applicable. This is a physical medical device, not a standalone algorithm.
7. The Type of Ground Truth Used
- For Non-Clinical Testing: The "ground truth" implicitly used for non-clinical testing (electrical, mechanical, biocompatibility, sterilization) is based on established engineering principles, international standards (e.g., ISO, IEC, CISPR), and pre-defined specifications/tolerances for the device's performance. For biocompatibility, it's compliance with ISO 10993-1. For substantial equivalence, the "ground truth" is the established safety and effectiveness of the legally marketed predicate device.
8. The Sample Size for the Training Set
- Not applicable. There is no "training set" as this is not a machine learning/AI device.
9. How the Ground Truth for the Training Set Was Established
- Not applicable.
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(90 days)
The Nalu Neurostimulation System is indicated as the sole mitigating agent or as an adjunct to other modes of therapy used in a multidisciplinary approach for chronic, intractable pain of the trunk and/or limbs, including unilateral or bilateral pain.
The trial devices are solely used for trial stimulation (no longer thank 30 days) to determine efficacy before recommendation for a permanent (long term) device.
The Nalu Lead Blank is an optional accessory intended to be used as a surgical aide to insert the Nalu Neurostimulation System Leads.
The Nalu Lead Blank is an optional accessory to the Nalu Neurostimulation System (also referred to as the "Nalu System"), which is used for spinal cord stimulation to provide therapeutic relief for chronic, intractable pain of the trunk and/or limbs including unilateral or bilateral pain. The Nalu Neurostimulation System incorporates a miniature implanted neurostimulator, powered by an externally worn device. The Nalu Lead Blank is an optional non-implantable surgical tool used during implant of the Nalu Neurostimulation System leads. The Nalu Lead Blank may be used to create a path for the lead in the epidural space.
This 510(k) submission is for the Nalu Lead Blank, an accessory to the Nalu Neurostimulation System, not an AI device. Therefore, the request for "acceptance criteria and the study that proves the device meets the acceptance criteria" in the context of an AI/ML device is not applicable to the provided text.
The document describes the device, its intended use, and establishes substantial equivalence to a predicate device (Nalu Neurostimulation System K183047) and a reference device (Stimwave Freedom 8 SCS System K170141).
The "studies" conducted are nonclinical performance tests, primarily bench testing, sterilization validation, and biocompatibility testing, along with human factors and usability testing (including a cadaver lab evaluation). Animal testing and clinical performance data were not considered necessary for this device's clearance.
Since this is not an AI/ML device, the following points of your request cannot be extracted from the provided text:
- Table of acceptance criteria and reported device performance (in the context of AI metrics like sensitivity, specificity, etc.): Not applicable for a surgical accessory. The acceptance criteria relate to mechanical and biological safety, not diagnostic performance.
- Sample size used for the test set and data provenance: While non-clinical tests were performed, the concept of a "test set" for AI evaluation isn't relevant here.
- Number of experts used to establish ground truth: Not applicable. Ground truth for a surgical tool is its physical and biological performance attributes.
- Adjudication method for the test set: Not applicable.
- Multi-reader multi-case (MRMC) comparative effectiveness study: Not applicable, as this is not a diagnostic AI device.
- Standalone (algorithm only without human-in-the-loop performance) was done: Not applicable.
- Type of ground truth used (expert consensus, pathology, outcomes data, etc.): Not applicable in the AI sense. Ground truth here relates to engineering specifications and biological compatibility.
- Sample size for the training set: Not applicable as there's no machine learning model.
- How the ground truth for the training set was established: Not applicable.
Summary of Device Acceptance / Performance Demonstration (based on provided text):
The Nalu Lead Blank underwent the following nonclinical performance testing to demonstrate its safety and effectiveness:
- Bench Testing: Mechanical tests to show the device met target specifications over a range of operating and storage conditions.
- Sterilization Validation: Ensures the device can be properly sterilized.
- Biocompatibility Testing: Followed ISO 10993-1:2009 standards.
- Categorization: Implant tool for tissue/bone contact for a limited duration (≤ 24 hours).
- Tests Included: Cytotoxicity, sensitization, intracutaneous reactivity, and systematic toxicity.
- Result: Biocompatibility was demonstrated.
- Human Factors and Usability Testing: Performed on the device, including evaluation in a Surgical Validation cadaver lab.
- Design Controls: Nalu followed 21 CFR 820.30, ISO 14971:2007, and ISO 13485:2016 for design control processes, ensuring proper planning, evaluation, and testing.
Conclusion stated by the sponsor: "The bench and non-clinical data support the safety of the device. The verification and validation demonstrated that the Nalu Lead Blank, which is part of the Nalu Neurostimulation System, performs as intended in the specified use conditions. The results do not raise new questions of safety and effectiveness."
The acceptance criteria for this device are implicitly tied to meeting the requirements of the standards and guidance documents listed (e.g., ISO 10993-1 for biocompatibility, mechanical test specifications, usability requirements), enabling the FDA to determine substantial equivalence to previously cleared predicate devices.
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