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510(k) Data Aggregation

    K Number
    K233364
    Device Name
    Axon Therapy
    Date Cleared
    2024-01-10

    (100 days)

    Product Code
    Regulation Number
    882.5890
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    NeuraLace Medical Inc.

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

    The Axon Therapy is intended to stimulate peripheral nerves for relief of chronic intractable pain, post-surgical pain and/or for relief of chronic painful diabetic peripheral neuropathy in the lower extremities. The Axon Therapy is for use on patients 18 and older.

    Device Description

    The Axon Therapy is a magnetic stimulator system that provides brief and focused magnetic pulses in order to non-invasively stimulate peripheral nerves and provide chronic nerve pain relief. The subject device is intended to be used in clinics such as pain management clinics and physical therapy clinics. The device consists of Magnetic Stimulation Coil, Liquid Cool Unit, and a Cart. The Axon Therapy includes a thermal shutdown feature which is activated once the inside temperature of the stimulation coil either: (A) reaches 45°C or (B) exceeds 41°C for a total of nine minutes during a 20-minute session.

    AI/ML Overview

    The provided document is a 510(k) summary for the Axon Therapy device, which is a magnetic stimulator system intended for pain relief. The submission seeks to establish substantial equivalence to a previously cleared device (K210021, also Axon Therapy by NeuraLace). This document does not contain information about acceptance criteria and a study proving the device meets those criteria in the typical format of an AI/ML medical device submission.

    Instead, it focuses on demonstrating substantial equivalence by highlighting that the subject device has identical design, dimensions, materials, intended use, and technological characteristics to the predicate device. The primary change is an expansion of the Indications for Use to include "chronic painful diabetic peripheral neuropathy in the lower extremities."

    Therefore, the information regarding acceptance criteria, test set details, expert ground truth establishment, MRMC studies, and standalone performance for an AI/ML device is not present in this document. The document describes a clinical study done to support the expanded indication, which is different from a performance study for an AI/ML algorithm.

    Here's a breakdown of what can be extracted and what is missing/not applicable based on the provided text, assuming the request is looking for AI/ML device study details:

    Information Present or Inferable:

    • 1. A table of acceptance criteria and the reported device performance:
      • Acceptance Criteria (Inferable for Clinical Study): The primary efficacy objective for the clinical study was to compare the proportion of "responders" (>=50% reduction from baseline in neuropathic pain intensity as measured by an in-clinic visual analog score (VAS) for the primary area of pain at Day 30, with no increase over baseline pain medications within four weeks of the Day 30 visit) between the Axon Therapy plus CMM group and the Sham plus CMM group. While not a formal "acceptance criteria" table for AI/ML, this is the clinical endpoint criteria.
      • Reported Device Performance:
        • Axon Therapy group: -57.6% reduction in VAS pain scores.
        • Sham group: -12.5% reduction in VAS pain scores.
        • p-value:
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    K Number
    K210021
    Device Name
    Axon Therapy
    Date Cleared
    2021-06-11

    (158 days)

    Product Code
    Regulation Number
    882.5890
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    NeuraLace Medical, Inc.

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

    The Axon Therapy is intended to stimulate peripheral nerves for relief of chronic intractable, post-traumatic and postsurgical pain for patients 18 and older.

    Device Description

    The Axon Therapy is a magnetic stimulator system that provides brief and focused magnetic pulses in order to non-invasively stimulate peripheral nerves and provide chronic nerve pain relief. The subject device is intended to be used in clinics such as pain management clinics and physical therapy clinics. The device consists of Magnetic Stimulation Coil, Liquid Cool Unit, and a Cart. The Axon Therapy includes a thermal shutdown feature which is activated once the inside temperature of the stimulation coil either: (A) reaches 45°C or (B) exceeds 41°C for a total of nine minutes during a 20-minute session.

    AI/ML Overview

    The provided text describes the 510(k) premarket notification for Axon Therapy by NeuraLace Medical, Inc. This document focuses on demonstrating substantial equivalence to a predicate device, as opposed to proving novel acceptance criteria in the traditional sense of a clinical trial for a new drug or high-risk device. Therefore, the "acceptance criteria" here largely refer to meeting the requirements for substantial equivalence to a legally marketed predicate device, primarily through non-clinical and clinical testing designed to show that the new device is as safe and effective as the predicate.

    Given this context, I will interpret "acceptance criteria" as the performance and safety benchmarks established by the predicate device and the relevant FDA standards, which the Axon Therapy must meet or surpass. The "study that proves the device meets the acceptance criteria" refers to the set of tests and clinical data provided to demonstrate this substantial equivalence.

    Here's a breakdown of the requested information based on the provided text:


    Acceptance Criteria and Reported Device Performance

    The "acceptance criteria" are implicitly defined by the characteristics of the predicate device (Shenzhen Roundwhale Technology Co., Ltd. R-C1 TENS and EMS Stimulator; K181688) and other reference devices, along with relevant industry standards (IEC, etc.). The reported device performance demonstrates how the Axon Therapy aligns with or improves upon these.

    Table of (Implicit) Acceptance Criteria and Reported Device Performance:

    Feature/Criterion (Implicit)Predicate Device/Standard Baseline (Implied Acceptance)Reported Axon Therapy PerformanceStatement of Equivalence/Met Criteria
    Indications for UseSymptomatic relief of chronic intractable pain, post-traumatic pain, and post-surgical pain (for patients 18+)Stimulate peripheral nerves for relief of chronic intractable, post-traumatic and post-surgical pain for patients 18 and older.Identical to the predicate device.
    Magnetic Stimulation Type (vs. Electrical)Electrical nerve stimulation (TENS/EMS)Magnetic stimulator system providing brief and focused magnetic pulses.This is a difference from the predicate but demonstrated to be substantially equivalent through testing. The document states: "Performance and clinical data demonstrate that there is no impact on safety and effectiveness when compared to the predicate device." "Axon Therapy does not result in burn marks, skin irritation, or analgesic tolerance, highlighting the safety benefit."
    Safety - Electrical SafetyIEC 60601-1 (general), IEC 60601-1-11 (home use)Tested compliance to IEC 60601-1:2005+AMD1:2012 CSV.Substantially equivalent; no new questions of safety.
    Safety - EMCIEC 60601-1-2Tested compliance to IEC 60601-1-2 Edition 4.0 2014-02.Substantially equivalent; no new questions of safety.
    Safety - SoftwareIEC 62304Software development and testing in compliance to IEC 62304:2006.Identical to predicate device; no new questions of safety.
    Safety - UsabilityIEC 62366Tested compliance to IEC 60601-1-6 Edition 3.1 2013-10 and IEC 62366:2007+AMD1:2014 CSV.Substantially equivalent.
    Safety - BiocompatibilityImplicitly met by predicate device materials and general standards.Housing materials: Stimulator: AL sheet EN AW 5754 H111, Coil: ABS. Biocompatibility testing performed.Substantially equivalent; no new questions of safety.
    Safety - Adverse EventsAdverse events associated with predicate TENS devices (e.g., burn marks, skin irritation, analgesic tolerance)Two non-serious adverse events related to device use: hypersensitivity (n=3) and muscle soreness (n=5). Does not result in burn marks, skin irritation, or analgesic tolerance.AE profile is similar or better than predicate device. Demonstrates safety benefit.
    Performance - Pain Relief EffectivenessEffectiveness in relieving chronic pain (as per predicate's intended use).Statistically significant decrease in pain scores (NRS/MVAS) after sessions. All subjects had a decreased MVAS score after 12 weeks.Demonstrated clinical effectiveness; performance testing for substantial equivalence.
    Performance - Clinical Use Case (Clinic/Home)Predicate likely for home/clinic use (given TENS/EMS).Intended for use in clinics (e.g., pain management, physical therapy clinics).Consistent with expected use environment for such devices.
    Performance - Stimulation Protocol AccuracyImplicitly accurate for predicate.Validated.Performance testing for substantial equivalence.
    Performance - Thermal ManagementImplicitly managed by predicate or standard requirements.Thermal shutdown feature activated at 45°C or >41°C for 9 mins during 20-min session. Temperature on surface at maximum output validated.Addresses user safety and device longevity.
    Technical - WaveformBiphasic square (predicate); Biphasic wave (reference device K160280)Biphasic wave.Identical to reference device; no new safety/effectiveness questions compared to predicate.
    Technical - Pulse FrequencyUnknown (predicate); 1-55 Hz (reference K973929); 0-22 Hz (reference K160280)0-2 Hz.Similar to reference devices; no new safety/effectiveness questions.
    Technical - Pulse AmplitudeUnknown (predicate); 0-100% (reference K973929, K160280)0 to 100% (max 80% recommended).Identical to reference devices; no new safety/effectiveness questions.
    Technical - Pulse WidthUnknown (predicate); Biphasic (280 µsec) (reference K160280)Biphasic (290 µsec).Identical to reference device; no new safety/effectiveness questions.
    Technical - Maximum Repetition RateUnknown (predicate); 20 pps (reference K160280)2 pulses per second (pps).Similar to reference device; no new safety/effectiveness questions.
    Technical - Applied Part Area25 cm2 (predicate).16 cm2.Substantially equivalent; no new safety/effectiveness questions.

    Study Details:

    1. Sample Size Used for the Test Set and Data Provenance:

      • Clinical Studies:
        • Total subjects: n=105.
        • Subgroup 1: 25 subjects.
        • Subgroup 2: 80 subjects (105 - 25).
      • Data Provenance: The document does not explicitly state the country of origin or whether the data was retrospective or prospective. It states "NeuraLace conducted multiple clinical studies," implying prospective studies conducted by the company.
    2. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications:

      • This information is not explicitly provided. For a pain relief device, "ground truth" is typically subjective patient-reported pain scores (NRS/MVAS) rather than readings established by experts.
    3. Adjudication Method for the Test Set:

      • Not applicable/Not mentioned, as the primary outcome (pain scores) is patient-reported.
    4. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done:

      • No, an MRMC study was not done. The clinical studies focused on the effectiveness and safety of the device itself (with or without a human in the loop, but the device is user-applied in a clinical setting). It was not a comparative study of human readers assisted by AI vs. unassisted human readers.
    5. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done:

      • This question is generally relevant for AI/software-based diagnostic devices. For a physical medical device like Axon Therapy, a "standalone algorithm" is not applicable in the same way. The device functions to stimulate nerves, and its performance is measured by its physical output (magnetic pulses) and clinical outcomes (pain relief), not by an algorithm making a diagnosis or interpretation. The software validation mentioned (IEC 62304) ensures the software controlling the device operates correctly, which is part of the integrated device performance.
    6. The Type of Ground Truth Used:

      • Clinical Efficacy: Patient-reported outcome measures (PROMs) using the Numeric Rating Scale (NRS) or Mechanical Visual Analog Scale (MVAS) for pain. This is a subjective patient outcome as ground truth for pain relief.
      • Safety: Occurrence of adverse events, evaluated by clinicians and reported.
      • Technical Performance: Quantitative measurements from performance testing (e.g., magnetic field characteristics, stimulation protocol accuracy, temperature). Compliance with electrical safety, EMC, and usability standards are also part of the "ground truth" for device safety and functionality.
    7. The Sample Size for the Training Set:

      • This document describes a premarket notification for a physical medical device, not an AI/ML algorithm that requires a "training set" in the context of machine learning. The term "training set" is not applicable here. The clinical studies described (n=105 total subjects) are the testing/validation set for the device's clinical performance and safety.
    8. How the Ground Truth for the Training Set was Established:

      • See point 7; "training set" in the AI/ML sense is not relevant. The device's "training" refers to its design, engineering, and manufacturing process, optimized through non-clinical and preclinical testing to ensure it meets its intended function prior to clinical evaluation.
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