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510(k) Data Aggregation

    K Number
    K182720
    Date Cleared
    2019-03-29

    (182 days)

    Product Code
    Regulation Number
    882.5880
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Stimwave Technologies Incorporated

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

    The Freedom Spinal Cord Stimulator (SCS) System is intended 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 lower limbs, including unilateral or bilateral pain.

    The Freedom-8A Trial Lead Kit is only used in conjunction with the Freedom-8A Stimulator Receiver Kit, and the Freedom-4A Trial Lead Kit is used for either the Receiver Kit Freedom-4A or the Receiver Kit Freedom-8A Stimulator. 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.

    Device Description

    The Stimwave Technologies Incorporated (Stimwave) Freedom Spinal Cord SCS System (System) is used for spinal column stimulation to provide therapeutic relief for chronic. intractable pain of the trunk and and/or lower limbs including unilateral or bilateral pain. The therapy utilizes pulsed electrical current to create an energy field that acts on nerves near the spinal column. The System is comprised of an implantable stimulator (Freedom-8A/4A Stimulator), receiver component (Receiver), and an externally worn transmitter (Wearable Antenna Assembly (WAA)) to power the device. The System is implanted only following a successful trial period with the Freedom-8A/4A Trial Lead.

    AI/ML Overview

    This document describes the Stimwave Freedom Spinal Cord Stimulator (SCS) System, which is intended for chronic, intractable pain of the trunk and/or lower limbs. The submission (K182720) is identical to K180981 but includes updates to widen the available range of stimulation parameters for repetition rate (5 Hz to 10 kHz) and pulse width (30 us to 1000 us). No design modifications were made. The document leverages performance testing from prior submissions (K180981 and others) to demonstrate substantial equivalence to the predicate device.

    Here's an analysis of the acceptance criteria and study information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document doesn't present a specific table of "acceptance criteria" for performance that the device must meet in terms of a benchmark metric (e.g., Sensitivity, Specificity, Accuracy for a diagnostic device). Instead, it implicitly defines acceptance criteria through compliance with design requirements and various international standards. The "device performance" is primarily demonstrated through passing these tests and showing substantial equivalence to a predicate device.

    The two key parameters that were updated in this submission are:

    • Repetition Rate: Increased from 5 to 1500 Hz (predicate) to 5 to 10,000 Hz (subject device).
    • Pulse Width: Increased from 50 to 500 microseconds (predicate) to 30 to 1000 microseconds (subject device).

    The "performance" of the device is described in terms of its ability to pass a series of non-clinical tests and, to some extent, a clinical non-inferiority study for efficacy.

    Acceptance Criteria (Implicit)Reported Device Performance
    Non-Clinical Performance:
    Compliance with AAMI ANSI ISO 14708-3:2008 (protection from temperature change, atmospheric pressure change, external defibrillation exposure)Freedom-8A/4A Stimulator was functional and safe, passing all tests. Design unchanged by widened stimulation parameters, demonstrating continued safety and efficacy.
    Thermal shock resistanceFreedom-8A/4A Stimulator had "no irreversible damage" and was fully functional. Outcome not affected by widened stimulation parameters.
    Leakage current (Freedom-8A/4A Stimulator)Freedom-8A/4A Stimulator produced zero leakage current on all tested paths/samples. Outcome not affected by widened stimulation parameters.
    Stylet insertion and withdrawal forceRequired less than 2.5N (stylet) or 2.2N (Receiver/RF Stylet) force for all samples. No damage observed. Outcome not affected by widened stimulation parameters.
    Mechanical testing (tensile, flex, torsion)Freedom-8A/4A Stimulator passed all criteria, showing no visible damage or functional damage. Outcome not affected by widened stimulation parameters.
    MRI RF induced heating (1.5T and 3T) per ASTM F2182-11aFreedom-8A Stimulator produced maximum temperature increase lower than allowable limits, passed both 1.5T and 3T. Outcome not affected by widened stimulation parameters.
    MRI image artifacts per ASTM F2119-07Freedom-8A Stimulator showed it does not produce image artifacts in 1.5T or 3T MRI. Outcome not affected by widened stimulation parameters.
    MRI magnetically induced displacement force per ASTM F2052-06Freedom-8A Stimulator does not harm patient due to displacement by forces induced by 1.5T or 3T MRI exposure, passes deflection angle criteria. Outcome not affected by widened stimulation parameters.
    MRI magnetically induced torque per ASTM F2213-06Freedom-8A/4A Stimulator does not harm patient due to torque by forces induced by MRI exposure (1.5T or 3T). Outcome not affected by widened stimulation parameters.
    WAA compliance with IEC 60601-1 (protection from temperature change, atmospheric pressure change, push/drop/impact/mold stress relief, identification/marking, means of protection, creepage/air clearances)WAA met passing criteria for visual and functional inspections, no physical damage, fully operational for all tests. Outcome not affected by widened stimulation parameters.
    WAA compliance with IEC 60529 (ingress of water, particulate matter)WAA met passing criteria for visual and functional inspections, no physical damage, fully operational for all tests. Outcome not affected by widened stimulation parameters.
    WAA compliance with IEC 60601-1-2 (electromagnetic compatibility including emissions, magnetic fields, immunity, ESD, radiated RF, fast transients)WAA met all acceptance criteria, operated within test limits, no physical damage, fully operational. Outcome not affected by widened stimulation parameters.
    Software VerificationSoftware passed all verification tests and met design requirements.
    Clinical Performance:
    Non-inferiority for primary endpoint (50% or more pain relief by VAS) (10,000 Hz vs 50-1500 Hz)p=0.0082, demonstrating non-inferiority.
    Non-inferiority for secondary endpoints (percent reduction in back/leg pain VAS, change in ODI scores, change in PGIC scores)All secondary endpoints also demonstrated non-inferiority.

    2. Sample size used for the test set and the data provenance

    Test Set Sample Size: The clinical study was a multicenter, prospective, randomized controlled study. The document does not explicitly state the sample size of subjects enrolled in this clinical study (test set). However, it does refer to "the percentage of subjects who responded" indicating a cohort of patients.

    Data Provenance:

    • Country of Origin: Not explicitly stated but implied to be US-based given the FDA submission.
    • Retrospective or Prospective: The clinical study was prospective.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    Not applicable. This device is a neurostimulator for pain relief, not a diagnostic device with "ground truth" established by experts in the typical sense for imaging algorithms. The clinical endpoints (pain relief as measured by VAS, ODI, PGIC scores) are patient-reported outcomes.

    4. Adjudication method for the test set

    Not applicable for establishing ground truth in the context of this device's function. The clinical study was a randomized controlled study comparing two stimulation frequency ranges. The primary and secondary endpoints were measured using established scales (VAS, ODI, PGIC).

    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 is a medical device (Spinal Cord Stimulator), not an AI-based diagnostic tool that assists human readers.

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

    The device itself is a standalone implantable stimulator, meaning it functions independently of ongoing human interpretation or algorithmic input for its stimulation delivery. The "algorithm" here refers to the stimulation parameters. The submission confirms the device's performance across an expanded range of these parameters.

    The non-clinical performance data (e.g., electrical safety, mechanical robustness, MRI compatibility) are standalone tests of the device's physical and electrical characteristics. The clinical trial compared the efficacy of the device with different stimulation parameter settings (10,000 Hz vs 50-1500 Hz) in patients.

    7. The type of ground truth used

    The "ground truth" in the clinical study was based on patient-reported outcomes (PROs):

    • Visual Analog Scale (VAS) for pain relief and severity.
    • Oswestry Disability Index (ODI) scores.
    • Patient Global Impression of Change (PGIC) scores.

    8. The sample size for the training set

    Not applicable. This device is not an AI/ML algorithm that requires a "training set" in the conventional sense. The "learning" aspect is not explicitly mentioned as part of the device's function or development process in this document. The device's operational parameters (repetition rate, pulse width) are pre-defined, although the software restricts them in prior versions. The current submission updates these software restrictions based on prior design and testing.

    9. How the ground truth for the training set was established

    Not applicable, as there is no "training set" for an AI/ML algorithm in this context.

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    K Number
    K180981
    Date Cleared
    2018-09-19

    (159 days)

    Product Code
    Regulation Number
    882.5880
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Stimwave Technologies Incorporated

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

    The Freedom Spinal Cord Stimulator (SCS) System is intended 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 lower limbs, including unilateral or bilateral pain. The Freedom-8A Trial Lead Kit is only used in conjunction with the Freedom-8A Stimulator Receiver Kit, and the Freedom-4A Trial Lead Kit is used for either the Receiver Kit Freedom-4A Stimulator or the Receiver Kit Freedom-8A Stimulator. 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.

    Device Description

    The Stimwave Technologies Incorporated (Stimwave) Freedom Spinal Cord SCS System (System) is used for spinal column stimulation to provide therapeutic relief for chronic, intractable pain of the trunk and/or lower limbs including unilateral pain. The therapy utilizes pulsed electrical current to create an energy field that acts on nerves near the spinal column. The System is comprised of an implantable stimulator (Freedom-8A/4A Stimulator), receiver component (Receiver), and an externally worn transmitter (Wearable Antenna Assembly (WAA)) to power the device. The System is implanted only following a successful trial period with the Freedom-8A/4A Trial Lead.

    AI/ML Overview

    Here's a summary of the acceptance criteria and study information for the Stimwave Freedom Spinal Cord Stimulator (SCS) System, based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    Category / TestAcceptance CriteriaReported Device Performance
    Biocompatibility (ISO 10993-1, Blue Book Memo G95-1)No negative impacts from materials for cytotoxicity, sensitization, irritation/intracutaneous reactivity, acute systemic toxicity, genotoxicity, implantation (4, 8, & 13 weeks), subchronic toxicity.The device materials met all biocompatibility requirements, demonstrating no negative impacts. Materials (Pellethane 55D, Pt-Ir 90:10) have an extensive record of chronic and carcinogenetic safety.
    Temperature Change (AAMI ANSI ISO 14708-3:2008)Functional, safe rating following post visual inspection. Passed temperature change testing.Freedom-8A/4A Stimulator was functional and received a safe rating after post visual inspection, passing the temperature change testing. WAA met passing criteria for visual and functional inspections.
    Atmospheric Pressure Change (AAMI ANSI ISO 14708-3:2008)Functional following post testing functionality inspection. Passed atmospheric pressure change testing.Freedom-8A/4A Stimulator was functional after post testing functionality inspection, passing the atmospheric pressure change testing. WAA met passing criteria for visual and functional inspections.
    External Defibrillation (AAMI ANSI ISO 14708-3:2008)Functional after exposure to external defibrillation.Freedom-8A/4A Stimulator and Receiver were verified as functional after exposure to external defibrillation.
    Thermal ShockNo irreversible damage, fully functional, no physical anomalies.Freedom-8A/4A Stimulator had "no irreversible damage" and was fully functional, with no physical anomalies.
    Leakage CurrentZero leakage current.Freedom-8A/4A Stimulator produced zero leakage current on all tested paths for all samples.
    Stylet Insertion/Withdrawal ForceLess than 2.5N for stylet, Less than 2.2N for Receiver/RF Stylet. No damage.Stylet required less than 2.5N. Receiver/RF Stylet required less than 2.2N. No damage was present in any stimulator samples.
    Mechanical Testing (Tensile, Torsion)Passed all criteria, no visible damage to stimulator body or functional damage to components.Freedom-8A/4A Stimulator passed all criteria, showing no visible damage or functional damage.
    MRI RF-Induced Heating (ASTM F2182-11a)Maximum temperature increase lower than allowable limit for 1.5T and 3T MRI.Freedom-8A Stimulator produced a maximum temperature increase lower than the allowable limit for both 1.5T and 3T MRI, passing the testing.
    MR Image Artifacts (ASTM F2119-07)Does not produce image artifacts in 1.5T or 3T MRI.Freedom-8A Stimulator showed it does not produce image artifacts in 1.5T or 3T MRI procedures.
    Magnetically Induced Displacement Force (ASTM F2052-06)Does not harm the patient due to displacement by forces induced by MRI. Passes ASTM acceptance criteria for deflection angle.Freedom-8A Stimulator passes the ASTM acceptance criteria for deflection angle in 1.5T and 3T MRI, indicating no harm to the patient.
    Magnetically Induced Torque (ASTM F2213-06)Does not harm the patient due to torque by forces induced by MRI.Freedom-8A Stimulator will not present an additional risk or hazard to a patient in 1.5T or 3T environments with regard to torque.
    Stimulation Waveforms Post-MR ExposureNo component damage; fully functional.No component damage observed; fully functional following 1.5T or 3T MR procedures.
    IEC 60601-1 (WAA: Temperature Change, Atmospheric Pressure, Push/Drop/Impact/Mold Stress, Identification/Marking, Means of Protection/Creepage/Air Clearances)WAA met passing criteria for visual and functional inspections. Robust to withstand expected damage. Complies with labeling and design requirements.WAA met all passing criteria for these tests, demonstrating compliance with IEC 60601-1.
    IEC 60529 (WAA: Ingress of Water, Particulate Matter)WAA met passing criteria for visual and functional inspections.WAA met all passing criteria for ingress of water and particulate matter, demonstrating compliance with IEC 60529.
    IEC 60601-1-2 (WAA: Electromagnetic Compatibility)Unit met all acceptance criteria for emissions, low-frequency magnetic fields, immunity, electrostatic discharge, radiated RF electromagnetic fields, electrical fast transients, magnetic fields. Operated within limits.WAA operated within all test limits and met all acceptance criteria for electromagnetic compatibility.
    Software VerificationAll verification tests outlined passed. Design requirements met.Software passed all verification tests, and design requirements for Software Verification were met.
    Overall Design, Sterilization, Electrical SafetyMeets all requirements, confirms output meets design inputs/specifications. Passed all tests.Freedom SCS System meets all requirements and passed all stated tests.
    Performance - Additional Tx AntennasNo change to device performance and specification.Performance testing for additional Tx Antennas demonstrated no change to device performance and specification.

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

    The document does not explicitly state a specific sample size for a "test set" in the traditional sense of a clinical trial or a specific number of devices tested for each non-clinical performance test. Instead, it refers to "all tested samples," "all tested stylets," etc. The studies were non-clinical performance tests conducted in a laboratory setting. There is no information about the country of origin or whether hypothetical "data" was retrospective or prospective, as these are engineering tests.

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

    N/A. This was a submission for a medical device where the "ground truth" for non-clinical performance is defined by compliance with established international and national standards (e.g., ISO, ASTM, IEC) and the device's own design specifications. It does not involve human experts establishing ground truth in the context of diagnostic interpretation.

    4. Adjudication Method for the Test Set

    N/A. Adjudication methods like 2+1 or 3+1 typically apply to clinical studies where expert consensus is needed to resolve discrepancies in diagnostic interpretations. These were engineering and performance tests against pre-defined criteria.

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

    No. The document explicitly states: "There was no clinical testing required to support the medical device, as the indications for use are equivalent to the legally marketed predicate devices." Therefore, no MRMC comparative effectiveness study was conducted.

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

    Yes, in the sense that the performance tests were conducted on the device components (Stimulator, WAA) in a standalone manner against technical specifications and standards. This is not "algorithm only" in the context of AI, but rather the device's engineering performance tests. The device itself is a spinal cord stimulator system, which implants a physical device and involves patient and clinician interaction.

    7. The Type of Ground Truth Used

    The "ground truth" for the performance tests was defined by:

    • International and national standards: AAMI ANSI ISO 14708-3:2008, ASTM F2182-11a, ASTM F2119-07, ASTM F2052-06, ASTM F2213-06, IEC 60601-1, IEC 60529, IEC 60601-1-2.
    • Device design requirements and specifications: e.g., leakage current = zero, specific force requirements for stylet insertion/withdrawal, requirements for no visible or functional damage.
    • Biocompatibility standards: ISO 10993-1:2009 and Blue Book Memorandum G95-1.

    8. The Sample Size for the Training Set

    N/A. This submission describes an electromechanical medical device, not an AI/machine learning algorithm that requires a training set.

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

    N/A. This is not applicable to the type of device and submission described.

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    K Number
    K172644
    Date Cleared
    2017-11-03

    (63 days)

    Product Code
    Regulation Number
    882.5880
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Stimwave Technologies Incorporated

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

    The SandShark Injectable Anchor (SIA) System is intended to be an accessory to the stimulator component of the Stimwave Freedom Spinal Cord Stimulator (SCS) System to secure the stimulator to the fascia or interspinous/supra-spinous ligament.

    Device Description

    The Stimwave Technologies Incorporated (Stimwave) SandShark Injectable Anchor (SIA) System is used to fixate the Stimwave Freedom Stimulator to surrounding tissue. The System is comprised of a carbothane anchor (SandShark Anchor) that is transferred onto the deployment handle (SandShark Injectroducer) with the Loading Rod and Loading Base. The SIA System is provided sterile. The SandShark Injectroducer is used to deploy the SandShark Anchor onto the Stimulator.

    AI/ML Overview

    The provided text describes the Stimwave SandShark Injectable Anchor (SIA) System and its substantial equivalence to predicate devices, but it does not contain information about specific acceptance criteria or a study proving that the device meets those criteria with numerical performance values relevant to AI/ML devices.

    The document is a 510(k) summary for a medical device (an anchor system for spinal cord stimulators), not an AI/ML device. Therefore, the questions related to AI/ML performance metrics, sample sizes for AI/ML models, expert ground truth adjudication, MRMC studies, and standalone AI performance are not applicable to the content of this document.

    The document focuses on demonstrating substantial equivalence to predicate devices through:

    • Intended Use and Technological Characteristics Comparison: Showing that the SIA System has the same intended use and similar technological characteristics as existing legally marketed devices.
    • Biocompatibility Data: Confirming that the materials meet biological safety and compatibility requirements (ISO 10993-1:2009).
    • Non-Clinical Performance Data: Verifying that the device meets system design requirements and applicable voluntary standards for physical performance (e.g., protection from temperature change, atmospheric pressure change as per AAMI ANSI ISO 14708-3:2008).

    Since the device is not an AI/ML system, the requested information in the prompt, which is tailored for AI/ML device evaluations (e.g., sensitivity, specificity, expert ground truth, training/test sets, etc.), cannot be extracted from this document.

    Therefore, I am unable to provide a table of acceptance criteria and reported device performance, or details about studies proving device performance with respect to AI/ML metrics, as this information is not present in the provided text.

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    Why did this record match?
    Applicant Name (Manufacturer) :

    Stimwave Technologies Incorporated

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

    The Freedom Spinal Cord Stimulator (SCS) System is intended 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 lower limbs, including unilateral or bilateral pain. The Freedom-8A Trial Lead Kit is only used in conjunction with the Freedom-8A Stimulator Receiver Kit, and the Freedom-4A Trial Lead Kit is used for either Kit Freedom-4A Stimulator or the Receiver Kit Freedom-8A Stimulator. 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.

    Device Description

    The Stimwave Technologies Incorporated (Stimwave) Freedom Spinal Cord SCS System (System) is used for spinal column stimulation to provide therapeutic relief for chronic, intractable pain of the trunk and/or lower limbs including unilateral or bilateral pain. The therapy utilizes pulsed electrical current to create an energy field that acts on nerves near the spinal column. The System is comprised of an implantable stimulator (Freedom-8A/4A Stimulator), receiver component (Receiver), and an externally worn transmitter (Wearable Antenna Assembly (WAA)) to power the device. The System is implanted only following a successful trial period with the Freedom-8A/4A Trial Lead.

    AI/ML Overview

    The provided text concerns a 510(k) premarket notification for the Freedom Spinal Cord Stimulator (SCS) System (K170141). This document primarily focuses on demonstrating substantial equivalence to a predicate device (K162161) rather than detailing a study that establishes acceptance criteria and proves the device meets those criteria from scratch.

    The submission states: "This submission is identical to K162161, but includes summaries of performance testing to support MR Conditional labeling of the Freedom-8A SCS System. No modifications to the Freedom SCS System of K162161 were made in support of this submission." This indicates that the device's fundamental performance was established in the prior K162161 submission, and K170141 specifically addresses MR Conditional labeling.

    Therefore, many of the requested details regarding acceptance criteria for a new study, sample sizes for test sets, expert involvement for ground truth, and adjudication methods are not present in this document as it relies on pre-existing data and a demonstration of substantial equivalence rather than a de novo clinical trial or performance study proving new criteria.

    However, based on the information provided, we can extract the types of performance tests conducted and the standards against which the device was evaluated, which serve implicitly as acceptance criteria for demonstrating equivalent performance to the predicate device and for MR Conditional labeling.

    Here's an attempt to answer the questions based on the provided text, highlighting where information is absent due to the nature of this 510(k) submission:


    Acceptance Criteria and Device Performance (Implicit from Compliance Statements)

    The document doesn't explicitly list "acceptance criteria" in a table form with numerical targets and then report performance against them for all aspects. Instead, it states compliance with various standards and successful completion of tests. The "acceptance criteria" are implied by the standards cited and the statement that the device "complies" or "passed" these tests.

    1. A table of acceptance criteria and the reported device performance

    Category / TestImplicit Acceptance CriteriaReported Device Performance
    BiocompatibilityCompliance with ISO 10993-1:2009 and G95-1 (cytotoxicity, sensitization, irritation/intracutaneous reactivity, acute systemic toxicity, genotoxicity, implantation, subchronic toxicity). No negative impacts from materials."The Freedom SCS System meets biological safety and compatibility requirements of ISO 10993-1:2009 and Blue Book Memorandum G95-1." No negative impacts demonstrated. Materials (Pellethane 55D, Pt-Ir 90:10) have extensive safety record.
    Temperature Change (AAMI ANSI ISO 14708-3:2008)Functional, safe rating, passed visual inspection and temperature change testing."Freedom-8A/4A Stimulator was functional, receiving a safe rating following post visual inspection and passed the change of temperature testing."
    Atmospheric Pressure Change (AAMI ANSI ISO 14708-3)Functional, passed visual inspection and atmospheric pressure change testing."Freedom-8A/4A Stimulator were functional following post testing functionality inspection and passed atmospheric pressure change testing."
    External Defibrillation Exposure (AAMI ANSI ISO 14708-3)Stimulator & Receiver functional after exposure."Freedom-8A/4A Stimulator and Receiver were verified as functional after exposure to external defibrillation."
    Thermal ShockNo irreversible damage, fully functional, no physical anomalies."Freedom-8A/4A Stimulator was found to have 'no irreversible damage' and fully functional... no physical anomalies present."
    Leakage CurrentZero leakage current on all tested paths/samples."Freedom-8A/4A Stimulator was produced zero leakage current on all tested paths for all tested samples."
    Stylet & Receiver Insertion/Withdrawal ForceStylet:
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    Why did this record match?
    Applicant Name (Manufacturer) :

    Stimwave Technologies Incorporated

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

    The Freedom Spinal Cord Stimulator (SCS) System is intended 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 lower limbs, including unilateral or bilateral pain. The Freedom-8A Trial Lead Kit is only used in conjunction with the Freedom-8A Stimulator Receiver Kit, and the Freedom-4A Trial Lead Kit is used for either the Receiver Kit Freedom-4A Stimulator or the Receiver Kit Freedom-8A Stimulator. 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.

    Device Description

    This submission is based upon the established Stimwave product family offering additional surgical kitting options (Spare Lead Kit and Sterile Revision Kit), updates to the surgical kits (Receiver Kit and Trial Lead Kit) to include new accessory components (Needle, and RF Stylet), a new Wearable Antenna Assembly (WAA) model utilizing a Low Energy (LE) Bluetooth module, a USB battery charger, and upgrades to the WaveCrest Application.

    The Stimwave Technologies Incorporated (Stimwave) Freedom Spinal Cord SCS System (System) is used for spinal column stimulation to provide therapeutic relief for chronic, intractable pain of the trunk and/or lower limbs including unilateral pain. The therapy utilizes pulsed electrical current to create an energy field that acts on nerves near the spinal column. The System is comprised of an implantable stimulator (Freedom-8A/4A Stimulator), receiver component (Receiver), and an externally worn transmitter (Wearable Antenna Assembly (WAA)) to power the device. The System is implanted only following a successful trial period with the Freedom-8A/4A Trial Lead.

    AI/ML Overview

    The Stimwave Freedom Spinal Cord Stimulator (SCS) System (K162161) sought clearance by demonstrating substantial equivalence to its predicate devices (K160600, K150517, and K141399). Therefore, the acceptance criteria and performance are primarily based on non-clinical testing verifying its components meet design requirements and applicable voluntary standards. There was no clinical testing required or performed for this submission as the device's indications for use and underlying technology were considered equivalent to the already legally marketed predicate devices with established safety and efficacy.

    Here's a breakdown of the requested information:

    1. A table of acceptance criteria and the reported device performance

    The document does not explicitly present a table of acceptance criteria with corresponding performance statistics in a pass/fail format typical for classification. Instead, it describes various performance tests and states that the device "complies" or "passed" the criteria of the respective standards. The acceptance criteria essentially align with the requirements of the listed voluntary standards and the device's design specifications for safety and functionality.

    Acceptance Criteria CategoryStandard / Test TypeReported Device Performance
    Material BiocompatibilityISO 10993-1:2009, Blue Book Memorandum G95-1- No negative impacts from materials for cytotoxicity, sensitization, irritation or intracutaneous reactivity, acute systemic toxicity, genotoxicity, implantation (4, 8, and 13 weeks), and subchronic toxicity.
    • Materials (Pellethane 55D, Pt-Ir) have extensive record of chronic and carcinogenetic safety.
    • WAA is "noncontacting device" and outside the scope of ISO 10993-1:2009 for body contact.
    • Conclusion: Meets biological safety and compatibility requirements. |
      | Protection from Temperature Change | AAMI ANSI ISO 14708-3:2008 | - Freedom-8A/4A Stimulator: Functional, safe rating, passed post visual inspection, and passed temperature change testing.
    • WAA: Met passing criteria of visual and functional inspections, no physical damage, fully operational. |
      | Atmospheric Pressure Change | AAMI ANSI ISO 14708-3:2008 | - Freedom-8A/4A Stimulator: Functional following post testing functionality inspection, passed atmospheric pressure change testing.
    • WAA: Met passing criteria of visual and functional inspections, no physical damage, fully operational. |
      | External Defibrillation Exposure | AAMI ANSI ISO 14708-3:2008 | - Freedom-8A/4A Stimulator and Receiver: Verified as functional after exposure.
    • Conclusion: Complies with testing requirements. |
      | Thermal Shock | Applicable Standard (not explicitly named, implies AAMI ANSI ISO 14708-3:2008 context) | - Freedom-8A/4A Stimulator: "No irreversible damage" and fully functional, no physical anomalies present.
    • Conclusion: Complies with thermal shock design requirements and applicable standard. |
      | Leakage Current | Applicable Standard (not explicitly named, implies AAMI ANSI ISO 14708-3:2008 context) | - Freedom-8A/4A Stimulator: Produced zero leakage current on all tested paths for all tested samples.
    • Conclusion: Complies with leakage design requirements and applicable standard. |
      | Stylet Insertion/Withdrawal Force | Design Specifications | - Stylet within Stimulator: Required less than 2.5N insertion/withdrawal force.
    • Receiver within Stimulator: Required less than 2.2N insertion/withdrawal force.
    • Visual inspection confirmed no damage to stimulator samples.
    • Conclusion: Complies with design specifications. |
      | Mechanical Testing | Design Requirements | - Freedom-8A/4A Stimulator: Passed all criteria of tensile and torsion testing, showing no visible damage to stimulator body or functional damage to components.
    • Conclusion: Complies with all stimulator mechanical design requirements. |
      | WAA Robustness (Push, Drop, Impact, Mold Stress Relief) | IEC 60601-1 | - Determined to be robust to withstand expected damage. Met passing criteria of visual and functional inspections, showed no physical damage, fully operational.
    • Conclusion: Satisifes design requirements and applicable standard. |
      | WAA Identification, Marking, Documents | IEC 60601-1 | - Analysis of labeling determined compliance with requirements. All requirements and markings clearly identified and viewable.
    • Conclusion: Complies with the requirements of the standard. |
      | WAA Means of Protection, Creepage Distances, Air Clearances | IEC 60601-1 | - Analysis of design determined system satisfies requirements.
    • Conclusion: Satisfies requirements of the applicable standard. |
      | Ingress of Water | IEC 60529 | - WAA: Met passing criteria of visual and functional inspections, showed no physical damage, fully operational.
    • Conclusion: Satisfies design requirements and applicable standard. |
      | Particulate Matter | IEC 60529 | - WAA: Met passing criteria of visual and functional inspections, showed no physical damage, fully operational.
    • Conclusion: Satisfies design requirements and applicable standard. |
      | Electromagnetic Compatibility (EMC) | IEC 60601-1-2 | - WAA: Met all acceptance criteria for emissions, low-frequency magnetic fields, immunity, electrostatic discharge, radiated RF electromagnetic fields, electrical fast transients and magnetic fields. Operated within all test limits, showed no physical damage, and fully operational.
    • Conclusion: Satisfies the standard. |
      | Software Verification | Design Requirements | - Passed all verification tests outlined.
    • Design requirements for Software Verification met. |
      | Overall Compliance | National and International Standards, Design Inputs/Specifications | - Complies with applicable standards for neurostimulators, electrical safety, electromagnetic interference and compatibility, packaging, and sterilization.
    • Output meets design inputs and specifications.
    • Passed all testing.
    • Conclusion: Substantially equivalent to legally marketed predicate devices, and differences do not raise questions of safety and effectiveness. |

    2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    The document primarily refers to "tested samples" for hardware components and "analysis of labeling" or "analysis of design" for other aspects. Specific sample sizes for each test are not provided. The data provenance is non-clinical, meaning it's from laboratory and engineering testing, not patient data. No country of origin is specified for the testing data itself, but the submission is from a US company (Fort Lauderdale, Florida). It is by nature retrospective since it refers to testing already completed.

    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)

    This is not applicable as the submission focuses on non-clinical performance data and engineering verification. The "ground truth" here is adherence to specified voluntary standards (e.g., AAMI ANSI ISO 14708-3:2008, IEC 60601-1, IEC 60529, IEC 60601-1-2) and internal design requirements, rather than expert clinical consensus or patient-derived ground truth.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    Not applicable. This concept (adjudication for ground truth establishment) is relevant for studies involving human interpretation or clinical data analysis where disagreements need resolution. The tests described are objective engineering and laboratory tests against predefined criteria.

    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

    No, a multi-reader multi-case comparative effectiveness study was not done. This device is a spinal cord stimulator, not an AI-assisted diagnostic or imaging system. The submission explicitly states: "There was no clinical testing required to support the medical device, as the indications for use are equivalent to the legally marketed predicate devices." and "There was no clinical testing performed on this device since performance testing demonstrated similar performance as the legally marketed predicate devices."

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

    Not applicable. The device is a medical implant system; it does not involve an algorithm performing a standalone diagnostic or interpretative task. The "software" mentioned (WaveCrest Application) is for controlling the stimulator parameters, not for standalone diagnostic performance.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    The "ground truth" in this context is the predefined requirements from voluntary international standards (e.g., ISO 10993 for biocompatibility, IEC 60601 series for electrical safety, AAMI ANSI ISO 14708-3 for active implantable medical devices) and the device's internal engineering design specifications. The compliance with these standards and specifications serves as the basis for demonstrating safety and effectiveness for substantial equivalence.

    8. The sample size for the training set

    Not applicable. This is a medical device, not a machine learning or AI model that requires a training set.

    9. How the ground truth for the training set was established

    Not applicable. As there is no AI/ML component requiring a training set, the concept of establishing ground truth for a training set does not apply.

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    K Number
    K160600
    Date Cleared
    2016-08-26

    (177 days)

    Product Code
    Regulation Number
    882.5880
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    STIMWAVE TECHNOLOGIES INCORPORATED

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

    The Freedom Spinal Cord Stimulator (SCS) System is intended 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 lower limbs, including unilateral or bilateral pain. The Freedom-8A Trial Lead Kit is only used in conjunction with the Freedom-8A Stimulator Receiver Kit, and the Freedom-4A Trial Lead Kit is used for either the Receiver Kit Freedom-4A Stimulator or the Receiver Kit Freedom-8A Stimulator. 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.

    Device Description

    The Stimwave Technologies Incorporated (Stimwave) Freedom Spinal Cord SCS System (System) is used for spinal column stimulation to provide therapeutic relief for chronic, intractable pain of the trunk and/or lower limbs including unilateral or bilateral pain. The therapy utilizes pulsed electrical current to create an energy field that acts on nerves near the spinal column. The System is comprised of an implantable stimulator (Freedom-8A/4A Stimulator), receiver (Receiver), and an externally worn transmitter (Wearable Antenna Assembly (WAA)) to power the device. The System is implanted only following a successful trial period with the Freedom-8A/4A Trial Lead.

    AI/ML Overview

    This document describes the Stimwave Freedom Spinal Cord Stimulator (SCS) System (K160600) and its acceptance criteria, relying heavily on substantial equivalence to previously cleared predicate devices (K150517, K141399). Therefore, the "study that proves the device meets the acceptance criteria" largely refers to non-clinical performance data and the demonstration of equivalence to existing devices, rather than a de novo clinical trial.

    Here's an analysis of the provided information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The submission does not present a formal table of "acceptance criteria" with explicit numerical targets and corresponding "reported device performance" in a quantitative way for each criterion. Instead, it describes compliance with design requirements and applicable voluntary standards. The "reported device performance" is generally stated as "passed all criteria," "complies with," or "met the passing criteria."

    However, we can infer some criteria and their met status from the non-clinical performance data section:

    Feature/Criterion Subjected to TestingAcceptance Criteria (Inferred from standard/design requirement)Reported Device Performance
    Environmental Performance (AAMI ANSI ISO 14708-3:2008)
    Temperature Change (Shipping & Storage)Device functional, safe rating, no visual/physical anomaliesPassed post visual inspection and change of temperature testing.
    Atmospheric Pressure ChangeDevice functional, no visual/physical anomaliesPassed atmospheric pressure change testing.
    External Defibrillation ExposureDevice functional after exposureVerified as functional after exposure.
    Thermal ShockNo irreversible damage, fully functional, no physical anomaliesPassed, 'no irreversible damage' and fully functional.
    Leakage CurrentZero leakage current on all pathsProduced zero leakage current.
    Mechanical Performance
    Stylet Insertion & Withdrawal ForceLess than 2.5N insertion/withdrawal forceRequired less than 2.5N of force.
    Receiver Insertion & Withdrawal ForceLess than 2.2N insertion/withdrawal forceRequired less than 2.2N of force.
    Visual Inspection (after insertion/withdrawal)No damage present in stimulator samplesConfirmed no damage.
    Tensile Testing (Stimulator)No visible or functional damage to stimulatorPassed all criteria, no visible/functional damage.
    Torsion Testing (Stimulator)No visible or functional damage to stimulatorPassed all criteria, no visible/functional damage.
    Wearable Antenna Assembly (WAA) Performance (IEC 60601-1)
    Temperature Change (Shipping & Storage)WAA functional, no physical damageMet passing criteria, no physical damage, fully operational.
    Atmospheric Pressure ChangeWAA functional, no physical damageMet passing criteria, no physical damage, fully operational.
    Push, Drop, Impact, Mold Stress ReliefWAA robust to withstand expected damage, functional, no physical damageDetermined robust, met passing criteria, no physical damage, fully operational.
    Identification, Marking, DocumentsComplies with standard requirements, clear identificationAnalysis of labeling determined compliance.
    Means of Protection, Creepage Distances, Air ClearancesSatisfies standard requirementsAnalysis of design determined satisfaction.
    WAA Ingress Protection (IEC 60529)
    Ingress of WaterWAA functional, no physical damageMet passing criteria, no physical damage, fully operational.
    Particulate MatterWAA functional, no physical damageMet passing criteria, no physical damage, fully operational.
    Electromagnetic Compatibility (IEC 60601-1-2)
    Radiated RF Electromagnetic FieldsMet all acceptance criteriaMet all acceptance criteria, operated within all limits.
    Radiated ImmunityMet all acceptance criteriaMet all acceptance criteria, operated within all limits.
    Wireless CoexistenceMet all acceptance criteriaMet all acceptance criteria, operated within all limits.
    Software VerificationMet design requirements, passed verification testsPassed all verification tests, design requirements met.
    Overall Safety and EffectivenessSubstantially equivalent to legally marketed predicate devicesDetermined substantially equivalent after all testing.

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

    • Sample Size: The document does not specify the exact number of units tested for each non-clinical performance test (e.g., how many stimulators for thermal shock, how many WAAs for drop tests). It uses general terms like "all tested samples," "representative subassemblies," and "all tested paths for all tested samples."
    • Data Provenance: The data is entirely non-clinical performance data, meaning it's derived from lab testing and analysis of the device itself.
      • It is not patient data from a specific country or collected retrospectively/prospectively.
      • A significant portion of the testing (e.g., for WAA, environmental performance, mechanical performance, biocompatibility) is "leveraged" from previous 510(k) submissions (K150517 and K141399) because the components or their relevant characteristics remained unchanged. New testing was performed where modifications or new components were introduced (e.g., specific tests for the Receiver).

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

    Not applicable. This device's safety and effectiveness were demonstrated through non-clinical performance testing and substantial equivalence, not through a study involving expert-established ground truth on patient data.

    4. Adjudication Method for the Test Set

    Not applicable. This was not a study requiring adjudication of expert opinions on patient data. The non-clinical tests have objective pass/fail criteria.

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

    No. An MRMC study is typically associated with diagnostic imaging devices where human readers interpret medical images. This is a medical implant (spinal cord stimulator) for pain relief, and its submission relies on non-clinical performance and equivalence to predicates, not a comparative effectiveness study with human readers interpreting imaging.

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

    In a sense, all the non-clinical performance testing described (environmental, mechanical, electrical safety, EMC, software verification) can be considered "standalone" in that it evaluates the device's inherent performance characteristics without human involvement in its operation/interpretation during the test, other than setting up and monitoring the test itself. There is no "algorithm" in the sense of AI being evaluated here, but rather the electro-mechanical and software functions of the device.

    7. The Type of Ground Truth Used

    The "ground truth" for the non-clinical performance studies is adherence to established engineering specifications, design requirements, and recognized voluntary standards (e.g., AAMI ANSI ISO 14708-3, IEC 60601-1, IEC 60529, IEC 60601-1-2, ISO 10993-1). For biocompatibility, it's the biological response demonstrating no negative impacts as per ISO 10993-1. For the overall submission, the "ground truth" of safety and effectiveness is tied to its substantial equivalence to previously cleared predicate devices for the same intended use.

    8. The Sample Size for the Training Set

    Not applicable. There is no mention of a "training set" as this is not an AI/machine learning device that would require such data for its development.

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

    Not applicable. No training set was used.

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    K Number
    K150517
    Date Cleared
    2015-06-05

    (95 days)

    Product Code
    Regulation Number
    882.5880
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    STIMWAVE TECHNOLOGIES INCORPORATED

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

    The Freedom Spinal Cord Stimulator (SCS) System is intended 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 lower limbs, including unilateral or bilateral pain. The Freedom-8A Trial Lead Kit is only used in conjunction with the Freedom-8A Stimulator Receiver Kit, and the Freedom-4A Trial Lead Kit is used for either the Receiver Kit Freedom-4A Stimulator or the Receiver Kit Freedom-8A Stimulator. 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.

    Device Description

    The Stimwave Technologies Incorporated (Stimwave) Freedom Spinal Cord SCS System (System) is used for spinal column neural stimulation to provide therapeutic relief for chronic, intractable pain of the trunk and/or lower limbs including unilateral or bilateral pain. The therapy utilizes pulsed electrical current to create an electrical energy field that acts on nerves near the dorsal column of the spine. The System is comprised of an implantable stimulator (Freedom-8A/4A Stimulator) and an externally worn transmitter (Wearable Antenna Assembly (WAA)) to power the device. The System is implanted only following a successful trial period with the Freedom-8A/4A Trial Lead.

    AI/ML Overview

    The provided text is a 510(k) summary for the Stimwave Freedom Spinal Cord Stimulator (SCS) System. It details the device, its intended use, and a comparison to predicate devices, but does not contain information about a clinical study with acceptance criteria and device performance results in the format requested.

    The document explicitly states in Section 10, "Clinical Performance Data":
    "There was no clinical testing required to support the medical device, as the indications for use are equivalent to the legally marketed predicate devices. These types of devices, including the legally marketed predicate devices, have been on the market for many years with a proven safety and efficacy for the use of the device. The non-clinical testing detailed in this submission supports the substantial equivalence of the device."

    And in Section 11, "Statement of Substantial Equivalence":
    "There was no clinical testing performed on this device since performance testing demonstrated similar performance as the legally marketed predicate devices, and materials for the implanted stimulator are the same as the legally marketed predicate devices."

    Therefore, I cannot provide the requested information regarding acceptance criteria and the study that proves the device meets them, as no clinical study with such data is presented in this document.

    The document primarily focuses on non-clinical performance data and substantial equivalence to predicate devices based on:

    • Intended Use: Stimulation of spinal cord for chronic, intractable pain of the trunk and/or lower limbs.
    • Technological Characteristics & Principles of Operation: Comparison of various parameters like electrode material, stimulator body material, pulse frequency, pulse width, current/voltage regulation, waveform, and power delivery to predicate devices.
    • Biocompatibility: Stating that materials remain unchanged from a previously cleared device (K141399) and meet ISO 10993-1:2009 standards.
    • Non-Clinical Performance Data: A series of tests demonstrating compliance with various standards (AAMI ANSI ISO 14708-3:2008, IEC 60601-1, IEC 60529, IEC 60601-1-2) for aspects like temperature change, atmospheric pressure, external defibrillation exposure, thermal shock, leakage current, mechanical testing, ingress of water, particulate matter, and electromagnetic compatibility.

    Without a clinical study, the acceptance criteria and performance tables, sample sizes, expert details, adjudication methods, MRMC studies, standalone performance, ground truth types, and training set information cannot be extracted from this document.

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    K Number
    K141399
    Date Cleared
    2014-10-10

    (135 days)

    Product Code
    Regulation Number
    882.5880
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    STIMWAVE TECHNOLOGIES INCORPORATED

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

    The Stimwave Technologies Incorporated Freedom Spinal Cord Stimulator (SCS) System is intended 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 lower limbs, including unilateral pain. The FRT4-A001 device is solely used for trial stimulation (no longer than 30 days) of the permanent FRE4-A001 device.

    Device Description

    The Stimwave Technologies Incorporated (Stimwave) Freedom Spinal Cord SCS System (System) is used for spinal column neural stimulation to provide therapeutic relief for chronic, intractable pain of the trunk and/or lower limbs including unilateral or bilateral pain. The therapy utilizes pulsed electrical current to create an electrical energy field that acts on nerves near the dorsal column of the spine. The System is comprised of an implantable stimulator (Freedom-4 Stimulator) and an externally worn transmitter (Wearable Antenna Assembly (WAA)) to power the device. The System is implanted only following a successful trial period with the Trial Freedom-4 Stimulator.

    AI/ML Overview

    The document describes the Stimwave Technologies Incorporated Freedom Spinal Cord Stimulator (SCS) System and provides information to support its substantial equivalence to legally marketed predicate devices.

    Here's an analysis of the acceptance criteria and supporting studies, formatted as requested:

    Acceptance Criteria and Reported Device Performance

    The document does not explicitly present a table of acceptance criteria with specific numerical targets and corresponding reported device performance values in a side-by-side format. Instead, it describes compliance with various national and international standards and design requirements through a series of non-clinical tests. The "reported device performance" is generally stated as having "passed," "met the criteria," or being "lower/higher than the allowable limit."

    However, a comparison table (Table 5A) is provided that compares the technological characteristics of the Stimwave Freedom SCS System with three predicate devices. This table implicitly defines "acceptance" as being similar to or within the range of these predicate devices for many parameters.

    Implicit Acceptance Criteria and Reported Performance (derived from Table 5A and non-clinical testing sections):

    Acceptance Criteria CategoryImplicit Acceptance Criteria / StandardReported Device Performance
    General Device CharacteristicsSame intended use, implant site, environmental use, intended clinician/user, electrode material, stimulator body material, method of introduction, tissue contact, sterilization, labeling, package.All "Same as Freedom" across predicate devices.
    Physical Dimensions
    - Stimulator LengthComparable to predicate devices (30-110 cm)45 centimeters (within range)
    - DiameterComparable to predicate devices (1.3-1.37 mm)1.35 millimeters (within range)
    - Electrode Array LengthComparable to predicate devices (24.0 mm)24.0 millimeters (same)
    - No. of ElectrodesComparable to predicate devices (4 or 8)4 (within range)
    - Electrode LengthComparable to predicate devices (3.0 mm)3.0 millimeters (same)
    - Electrode SpacingComparable to predicate devices (4.0 mm)4.0 millimeters (same)
    - Electrode Surface AreaComparable to predicate devices (12.25 mm² - ~13 mm²)12.72 mm² (comparable)
    Electrical Performance ParametersComparable to predicate devices within ranges/values.See Table 5A for detailed comparison across various parameters like Pulse Frequency, Pulse Width, Current/Voltage Regulation, Output Voltage/Current, Waveform, Pulse Shape, Current/Charge/Power Densities, Net Charge, Output Power. Generally comparable or within acceptable ranges.
    Material BiocompatibilityCompliance with ISO 10993-1:2009 and Blue Book Memorandum G95-1 for an implant device in contact with tissue/bone for cytotoxicity, sensitization, irritation, intracutaneous reactivity, acute systemic toxicity, implantation (4, 8, and 13 weeks), and subchronic toxicity."No negative impacts" from materials, meets biological safety and compatibility requirements.
    Temperature Change (Storage)Functional, safe rating following post visual inspection. Compliance with AAMI ANSI ISO 14708-3:2008.Stimulator was functional, received a safe rating, passed change of temperature testing. External unit met passing criteria.
    Atmospheric Pressure ChangeFunctional following post testing functionality inspection. Compliance with AAMI ANSI ISO 14708-3:2008.Stimulator was functional, passed atmospheric pressure change testing. External unit met passing criteria.
    MRI Safety - RF Induced HeatingMaximum temperature increase lower than allowable limit for 1.5T and 3T MRI. Compliance with ASTM F2182-11a.Produced a maximum temperature increase lower than the allowable limit for 1.5T and 3T MRI, thus passed.
    MRI Safety - Image ArtifactsMaximum measured artifact size lower than allowable limit for 3T MRI. Compliance with ASTM F2119-07.Produced a maximum measured artifact size lower than the allowable limit for 3T MRI, thus passed. No detrimental image artifacts.
    MRI Safety - Induced DisplacementSignificantly lower deflection value than allowable test limit. Compliance with ASTM F2052-06.Produced a significantly lower deflection value than the allowable test limit. Passed ASTM acceptance criteria for deflection angle.
    MRI Safety - Induced TorqueLowest score (no torque) according to qualitative scale. Compliance with ASTM F2213-06.Produced the lowest score, no torque. Will not present additional risk.
    Electrical Safety - Leakage CurrentZero leakage current on all tested paths for all samples.Produced zero leakage current.
    Stimulator Insertion/WithdrawalLess than 2.5N of insertion or withdrawal force. No damage.Required less than 2.5N; no damage.
    Stimulator Body FlexNo visible damage to stimulator body or components.Passed all criteria, no visible damage.
    Destructive Pull TestMaximum elongation of 0.5% (well below 5% limit).Maximum elongation 0.5% (well below test limit of 5%).
    External Defibrillation ExposureVerified to function as outlined.Verified to function as outlined.
    External Unit RobustnessWithstand expected damage (push, drop, impact, mold stress relief). Compliance with IEC 60601-1.Met passing criteria, no physical damage, fully operational.
    Electromagnetic Compatibility (EMC)Met all acceptance criteria for emissions, magnetic fields, immunity (electrostatic discharge, radiated RF fields, electrical fast transients/bursts). Compliance with IEC 60601-1-2.Met all acceptance criteria and operated within test limits.
    Ingress of Water/Particulate MatterMet passing criteria of visual and functional inspections. Compliance with IEC 60529.Met passing criteria, no physical damage, fully operational.
    Software VerificationPassed all verification tests outlined and design requirements met.Passed all verification tests.

    Study Details

    The document refers to a "submission" rather than a single specific study. The evidence for meeting acceptance criteria is predominantly based on non-clinical performance testing and a comparison to predicate devices.

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

      • Test Set Sample Size: Not explicitly stated as a separate "test set" in the context of device performance, but rather individual components were tested according to various standards. For example, "all tested samples" for leakage current and "all tested stylets in all tested stimulator samples" for insertion/withdrawal. The exact number of units/components tested for each non-clinical test is not specified.
      • Data Provenance: The testing was conducted by Stimwave Technologies Incorporated to verify compliance with national and international standards (AAMI ANSI ISO, ASTM, IEC). The data is prospective in the sense that the testing was performed on the Stimwave Freedom SCS System components specifically for this submission. The "data provenance" regarding the location of testing is not specified, but it's presumed to be within the manufacturer's testing facilities or accredited laboratories.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

      • This question is not applicable in the typical sense for this submission. The "ground truth" for the non-clinical tests is established by the specific requirements and acceptance criteria of the referenced national and international standards (e.g., ISO, ASTM, IEC). These standards are developed and recognized by expert bodies in their respective fields. No adjudication by specific medical experts for interpreting test results is described; rather, results are objectively compared against predefined numerical or qualitative criteria from the standards.
    3. Adjudication method (e.g., 2+1, 3+1, none) for the test set:

      • "None" in the context of human expert adjudication as this was non-clinical engineering and materials testing against established standards. The review process for the submission at the FDA would involve regulatory experts assessing the manufacturer's presented data against requirements.
    4. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:

      • No MRMC study was done. This document pertains to a Spinal Cord Stimulator, a medical device that delivers electrical impulses for pain relief, not an imaging or diagnostic AI device that would involve "human readers" or AI assistance in interpretation. The nature of this device does not fit the MRMC study paradigm.
    5. If a standalone (i.e. algorithm only without human-in-the loop performance) was done:

      • This question is not applicable. The device is a physical medical implant system, not a standalone algorithm. Its performance is inherent to its design and function, not an AI algorithm.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc):

      • The "ground truth" for demonstrating substantial equivalence against legally marketed predicate devices primarily relies on:
        • Standardized Test Methods and Acceptance Criteria: As set by numerous international and national standards (e.g., ISO 10993, AAMI ANSI ISO 14708-3, ASTM F2182-11a, IEC 60601-1) for biocompatibility, safety, and performance.
        • Direct Comparison to Predicate Devices: Explicitly measuring and comparing physical and electrical parameters against established values of legally marketed devices (Table 5A).
        • Design Requirements: Manufacturer-defined design specifications and requirements that the device must meet, often derived from industry best practices and safety considerations.
      • There is no mention of pathology or outcomes data as "ground truth" for this specific 510(k) submission, as it focuses on non-clinical substantial equivalence.
    7. The sample size for the training set:

      • This is not applicable. This is not an AI/ML device requiring a training set. The term "training set" is usually associated with machine learning models.
    8. How the ground truth for the training set was established:

      • This is not applicable as there is no training set for this device.
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