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510(k) Data Aggregation
Psoria-Shield, Inc.
The Enhanced AURORA™ Medical Diode system and related accessories is indicated for use in targeted PUVA photochemistry and UVB phototherapy for the treatment of skin conditions including psoriasis, vitiligo, atopic dermatitis, eczema, and seborrheic dermatitis. In addition, the system UVB channel is indicated for the treatment of leukoderma.
The Enhanced AURORA™ Medical Diode system and related accessories is designed to allow a clinician to easily apply UVA or UVB light to the patient's affected skin. The clinician selects the desired treatment type (UVA or UVB light) and applies the light through the appropriate handpiece by pointing the exit aperture towards the affected skin area.
The device is comprised of four main components:
- A base station
- A touchscreen where the user can enter system commands
- Two handpieces connected to the base by power cables. One handpiece contains diode emitters that, when activated, emit UVA light. The other handpiece emits UVB light. Either handpiece will only operate if the appropriate wavelength is selected, so a user cannot accidentally activate the incorrect handpiece. Activation of energy occurs on depression of a trigger in the handpiece.
- A printer accessory that can print out verification of treatment parameters for hard copy records.
The document describes the acceptance criteria and study for the Enhanced AURORA™ Medical Diode system.
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria | Reported Device Performance |
---|---|
UVA energy dosage output within 10% of user-selected power settings | Confirmed within 10% of user-selected power settings |
UVB energy dosage output within 10% of user-selected power settings | Confirmed within 10% of user-selected power settings |
2. Sample size used for the test set and the data provenance
The document does not explicitly state a 'test set' in the context of clinical data or patient samples. The performance data is based on bench testing only. Therefore, there is no sample size for a test set of patient data, nor is there information about data provenance (country of origin, retrospective/prospective).
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable. The performance data is derived from bench testing of the device's output, not from expert interpretation of medical images or patient data requiring ground truth establishment by experts.
4. Adjudication method for the test set
Not applicable, as a test set requiring adjudication by experts (e.g., for diagnostic accuracy) was not conducted. The assessment was based on physical measurements during bench testing.
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 a phototherapy system, not an AI-powered diagnostic tool, and therefore, an MRMC comparative effectiveness study involving human readers and AI assistance was not performed.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
Not applicable. This device is a medical phototherapy system, not an algorithm. Its performance is assessed by its physical output characteristics during bench testing, not by an algorithm's standalone performance.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
The "ground truth" for this device's performance was the user-selected power settings, against which the actual UVA and UVB energy dosage output was measured. This is a technical performance measurement, not a clinical ground truth.
8. The sample size for the training set
Not applicable. This document describes a medical device for phototherapy, not a machine learning model requiring a training set.
9. How the ground truth for the training set was established
Not applicable, for the same reason as above.
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(302 days)
Psoria-Shield
The AURORA system is indicated for use in targeted PUVA photochemistry and UVB phototherapy for the treatment of skin conditions including psoriasis, vitiligo, atopic dermatitis (eczema), and seborrheic dermatitis. In addition, the system UVB channel is indicated for the treatment of leukoderma.
The Psoria-Shield AURORA system delivers UVA or UVB phototherapy to target skin areas through one of two handpieces. The handpieces are connected to a base unit which uses an air cooling system to maintain system temperature, and has a built-in touchscreen to operate the device.
This document is a 510(k) summary for the Psoria-Shield AURORA system, a medical device for phototherapy. It asserts substantial equivalence to a predicate device (Psoria-Shield PS1000). The information provided focuses on the device's design, intended use, and safety compliance, rather than comprehensive performance studies with acceptance criteria in the context of clinical efficacy or diagnostic accuracy that would typically involve statistical metrics.
Here's an analysis based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly state "acceptance criteria" in the format of predefined thresholds for clinical or diagnostic performance metrics. Instead, it describes compliance with safety and electrical standards and consistency of energy output.
Acceptance Criterion (Implicit) | Reported Device Performance |
---|---|
Energy Output Consistency | Performance testing using pre-production AURORA systems demonstrated that the energy levels output from each handpiece are consistent with user-defined energy levels. |
Electrical Safety (IEC 60601-1:2005+A1:2012) | Successfully performed on production devices. |
Electromagnetic Disturbances (IEC 60601-1-2:2014) | Successfully performed on production devices. |
Basic Safety and Essential Performance (IEC 60601-2-57) | Successfully performed on production devices. |
Photobiological Safety (IEC 62471:2009) | Successfully performed. |
Software Development & Testing (IEC 62304) | Executed in compliance. |
Risk Management (ISO 14971) | Executed in compliance. |
Substantial Equivalence to Predicate | The AURORA system has the same intended use and similar indications, principles of operation, and technological characteristics as the predicate PS1000 system. Performance data demonstrates that the AURORA system is as safe and effective as the predicate PS1000 system. |
New Questions of Safety or Effectiveness (Design Changes) | Minor differences (air cooling, operating system, separate handpieces) do not raise any new questions of safety or effectiveness. |
2. Sample Size Used for the Test Set and Data Provenance
The document mentions "pre-production AURORA systems" and "production devices" for performance and safety testing. However, it does not specify the sample size (e.g., number of devices or test cycles) used for these tests. There is no information regarding the data provenance (e.g., country of origin, retrospective/prospective). This device is a phototherapy device, not a diagnostic one, so traditional "test sets" for diagnostic accuracy are not applicable here.
3. Number of Experts Used to Establish Ground Truth and Qualifications
This information is not applicable to this submission. The device is a phototherapy system, not an AI/diagnostic device that requires expert-established ground truth for performance evaluation in the context of a 510(k) submission. Its safety and operational characteristics are evaluated against engineering and medical device standards.
4. Adjudication Method for the Test Set
This information is not applicable for the same reasons as #3. There is no "test set" in the diagnostic context requiring adjudication.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done, and its effect size
This information is not applicable. The AURORA system is a phototherapy device, not a diagnostic AI system where MRMC studies comparing human readers with and without AI assistance would be relevant. The submission focuses on device safety and operational equivalence to a predicate.
6. If a Standalone (algorithm only without human-in-the-loop performance) was done
This information is not applicable. The AURORA is a physical phototherapy device, not an algorithm. Its operation involves a human user selecting settings and applying treatment.
7. The Type of Ground Truth Used
The concept of "ground truth" (expert consensus, pathology, outcomes data) typically applies to diagnostic or prognostic AI devices. For this phototherapy device, the "truth" is established by:
- Compliance with recognized electrical and safety standards (IEC 60601 series, IEC 62471).
- Measurement of physical outputs (energy levels) against defined specifications.
- Substantial equivalence to a legally marketed predicate device, implying its safety and effectiveness have been previously established.
8. The Sample Size for the Training Set
This information is not applicable. The AURORA system is a hardware device; there is no "training set" in the context of machine learning.
9. How the Ground Truth for the Training Set was Established
This information is not applicable for the same reasons as #8.
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(70 days)
PSORIA-SHIELD INC.
The Psoria-Light Model PS1000 is indicated for use in targeted PUVA photochemistry and UVB phototherapy for the treatment of skin conditions including psoriasis, vitiligo, atopic dermatitis (eczema), and seborrheic dermatitis. In addition, the system UVB channel is indicated for the treatment of leukoderma.
Psoria-Light™ Model PS1000 delivers targeted ultraviolet (UV) light to small regions of affected skin (2.88 cm), sparring healthy skin. The system is capable of delivering either UVB light (300 to 320nm) or UVA light (350 to 395nm). Psoria-Light™ Model PS1000 generates both UVA and UVB light via LED technology, avoiding environmental concerns associated with disposal and exchange of mercury gas lamps, Xenon, and Chlorine gases commonly associated with targeted UV phototherapy devices. Psoria-Light's™ UVB LEDs emit light between 300 and 320 nm, avoiding light emissions below 300nm. Psoria-Light™ Model PS1000 incorporates a unique safety feature, a non-contact sensor located about the aperture of the handpiece that detects human skin. The trigger mechanism for UV dosage administration (located on the handpiece) is disabled until a suitable surface is detected by this sensor.
The Psoria-Light Model PS1000 is a targeted UVA/UVB phototherapy system for dermatologic disorders. The provided document is a 510(k) summary for the device, focusing on its substantial equivalence to previously cleared predicate devices rather than new clinical effectiveness studies.
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria | Reported Device Performance |
---|---|
Clinical Performance: | |
New Indications for Use | No new indications for use introduced by Psoria-Light Model PS1000. All indications (psoriasis, vitiligo, atopic dermatitis (eczema), seborrheic dermatitis, and leukoderma for UVB) have been previously cleared for predicate devices. |
Product Performance (Non-Clinical): | |
Conformance to IEC 60601 series of standards | The Psoria-Light Model PS1000 shall have completed all testing to these standards prior to sale. |
Conformance to 21 CFR Part 1040.10 (Performance Standard for Light-Emitting Products) | The Psoria-Light Model PS1000 shall have completed all testing to these standards prior to sale. |
Certification to UL 60601-1 Medical Electrical Equipment classification standard | The Psoria-Light Model PS1000 shall have completed all testing to these standards prior to sale. |
Compliance with EMC requirements (FCC rules part 15, IEC 60601-1-2, EN55011) | The Psoria-Light Model PS1000 shall have completed all testing to these standards prior to sale. |
Application of risk management per ISO 14971 | The Psoria-Light Model PS1000 has been reviewed for risk management utilizing ISO 14971, ensuring all aspects are reviewed for potential hazards. |
Manufacturing in an FDA-registered facility | Products shall be produced and distributed by a facility that has been registered with the FDA to manufacture medical devices. |
Substantial Equivalence: | |
Equivalent design, composition, and function to predicate devices | The characteristics of the Psoria-Shield Psoria-Light Model PS1000 are substantially equivalent to those of the predicate devices (TheraLight Inc. DuaLight UV120-2, PhotoMedex, Inc. XTRAC Ultra2 Excimer Laser System). |
Equivalent output wavelengths, power, and light sources to predicate devices | Operation of the predicate devices, including output wavelengths, power, and light sources, received 510(k) clearance previously. The Psoria-Light Model PS1000 performs in a substantially equivalent manner. |
2. Sample Size Used for the Test Set and Data Provenance
No clinical performance test set (i.e., patient data) was used for this 510(k) submission. The submission explicitly states that "duplicative clinical data is not required as a condition of granting market clearance" because the device does not introduce new indications for use and performs in a substantially equivalent manner to predicate devices. The "study" for acceptance criteria was based on demonstrating substantial equivalence to these previously cleared devices through non-clinical performance testing and comparison of device specifications.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
Not applicable. No clinical test set requiring expert ground truth was employed for this 510(k) submission. The device's safety and effectiveness were argued based on substantial equivalence to predicate devices, which had presumably undergone such evaluations during their own clearance processes.
4. Adjudication Method for the Test Set
Not applicable. No clinical test set requiring adjudication was employed.
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 a phototherapy system, not an AI-assisted diagnostic or interpretive tool. Therefore, an MRMC study related to human reader performance with or without AI assistance is not relevant.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
Not applicable. This device is a hardware phototherapy system, not an algorithm. Its performance is evaluated based on its physical characteristics, light output, and compliance with safety and electrical standards.
7. The Type of Ground Truth Used
For the non-clinical product performance testing, the "ground truth" would be established by the specifications and requirements of the referenced international and national standards (e.g., IEC 60601, 21 CFR Part 1040.10, UL 60601-1, ISO 14971, FCC rules). The device's performance is measured against these established engineering and safety benchmarks. For the clinical indications, the "ground truth" was established by the previous 510(k) clearances of the predicate devices, which had demonstrated clinical effectiveness for the stated indications.
8. The Sample Size for the Training Set
Not applicable. This device is a hardware phototherapy system and does not involve AI or machine learning that would require a 'training set.'
9. How the Ground Truth for the Training Set Was Established
Not applicable. No training set was used.
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