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510(k) Data Aggregation
(113 days)
The KALA Therapy Wand (Model: KALA-03) is intended for the treatment of facial wrinkles, and mild to moderate inflammatory acne. The red light is intended for the treatment of wrinkles, and the blue light is intended for the treatment of mild to moderate inflammatory acne.
The KALA Therapy Wand (Model: KALA-03) is indicated for over-the-counter aesthetic use. The red light is intended for the treatment of wrinkles, and the blue light is intended for the treatment of mild to moderate inflammatory acne. The device is vibrating in red light model. The device is powered by a Lithium-Ion rechargeable battery, and it has a charging cable, USB charging stand, protective goggles, storage case and instruction manual.
The wand can be rotated 135 degrees in either direction.
There are two switches of the device: one function is red light to wrinkle removal and vibration for relax, the other function is blue light to treat mild to inflammatory acne.
The device will automatically shut down after 12 minutes of operation. The recommended treatment time is 3 minutes per area. After every three minutes of treatment, the device will vibrate to indicate the time. If you need to continue treatment, simply turn on the device again.
The provided FDA 510(k) clearance letter and summary for the KALA Therapy Wand (Model: KALA-03) primarily focus on demonstrating substantial equivalence to predicate devices through non-clinical testing. This type of clearance generally does not require extensive clinical performance studies with detailed acceptance criteria and human reader studies as would be seen for a new or complex AI/ML-driven diagnostic device.
Based on the provided information, the device is a light-based therapy device for over-the-counter use, intended for aesthetic purposes (facial wrinkles and mild to moderate inflammatory acne). The "study" proving the device meets acceptance criteria is a non-clinical performance testing approach demonstrating compliance with relevant electrical safety, electromagnetic compatibility, photobiological safety, battery safety, and biocompatibility standards. Software verification and validation, and usability validation were also performed.
Here's the breakdown of the information requested, as extractable from the provided document:
Acceptance Criteria and Device Performance
Since this is a non-clinical submission, the "acceptance criteria" are compliance with established safety and performance standards. There isn't a table of statistical performance metrics, but rather successful adherence to defined technical and safety requirements.
Table of Acceptance Criteria and Reported Device Performance (Non-Clinical Compliance)
Acceptance Criteria Category | Specific Standard/Requirement Met | Reported Device Performance |
---|---|---|
Electrical Safety | IEC 60601-1 (Edition 3.2, 2020-08) | Compliant |
IEC 60601-1-11 (Edition 2.1, 2020-07) | Compliant | |
IEC 60601-2-57 (Edition 1.0, 2011-01) | Compliant | |
Electromagnetic Compatibility | IEC 60601-1-2 (Edition 4.1, 2020-09) | Compliant |
Photobiological Safety | IEC 62471 (First edition, 2006-07) | Compliant |
Battery Safety | IEC 62133-2 (Edition 1.0, 2017-02) | Compliant |
Biocompatibility | ISO 10993-5 (Cytotoxicity) | Compliant (based on identical materials to cleared device) |
ISO 10993-10 (Sensitization) | Compliant (based on identical materials to cleared device) | |
ISO 10993-10 (Irritation) | Compliant (based on identical materials to cleared device) | |
Software | FDA Guidance: "Content of Premarket Submissions for Device Software Functions" | Software V&V conducted; classified as Basic Documentation Level. |
Usability | User testing for Usability Validation | Usability testing conducted. |
Study Details (as applicable for a non-clinical submission):
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Sample sizes used for the test set and the data provenance:
- Test Set (Device Testing): The "test set" here refers to the device prototypes/units that underwent the non-clinical tests. The document does not specify the number of units tested for electrical safety, EMC, etc., which is typical for such submissions.
- Data Provenance: The testing was conducted by or for the manufacturer (Shenzhen Kaiyan Medical Equipment Co., Ltd) in China, as indicated by the submitter's information. It's inherently "prospective" in the sense that the tests were performed on the device designed for submission.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- This is a non-clinical submission for a device used for aesthetic purposes. The concept of "ground truth" established by medical experts (like radiologists for image analysis) is not applicable here. The "ground truth" for these tests is defined by the passing criteria of the international standards themselves (e.g., specific thresholds for electrical leakage, EMC emissions, irradiance, etc.). Compliance is assessed by qualified test engineers and labs.
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Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- Not applicable. Adjudication methods are typically used in clinical studies, especially those involving subjective assessments or disagreements among human readers. Non-clinical testing against objective standards does not involve expert adjudication in this manner.
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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. An MRMC study is not relevant for this type of aesthetic, light-based therapy device where the claim is not for assisting human readers in diagnosis. The clearance is based on safety and functional equivalence.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. This device is not an algorithm for diagnosis or image analysis. It is a physical device providing light therapy. Its "standalone" performance refers to its ability to meet the specified technical parameters and safety standards.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- The "ground truth" for demonstrating substantial equivalence and safety in this context is compliance with recognized international consensus standards (e.g., IEC, ISO). The performance is measured against these technical specifications, not against clinical outcomes or expert consensus on medical conditions.
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The sample size for the training set:
- Not applicable. This device does not involve a machine learning algorithm that requires a "training set" in the traditional sense of AI/ML software. The software component, as described, is for controlling device functions ("Basic Documentation Level software"), not for learning from data.
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How the ground truth for the training set was established:
- Not applicable, as there is no training set for an AI/ML algorithm.
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(287 days)
Airpro-690 is intended for use by medical professionals and patients at home, who are under medical supervision, in treating many conditions, such as Primary lymphedema, Edema following trauma and sport injuries, Post immobilization edema, Venous insufficiencies, Lymphedema.
Air Compression System include the host, sleeves, and the air tube to connect them together. Through a multi-chamber inflatable sleeve orderly conducting of rhythmic squeezing inflation and deflation, it cyclic pressure on limb tissue, so as to promote venous blood return, enhance arterial infusion, improve blood circulation and lymphatic circulation. Two port on the back of the controller, labeling as Channel 1/2. And four air ways on each channel. The two channels can work independently, or simultaneously. The system can identify the channel and type of wearing sleeves automatically. If two channels were connected with sleeves, the system will inflate 1/2 channel simultaneously. Treatment Time, pressure, Channel and Treatment Mode are all can be adjusted on Parameter Settings Interface of the main unit.
This document does not describe a study that uses a test set, ground truth, or expert review for device performance related to a diagnostic or AI-driven system.
Instead, this is a 510(k) Premarket Notification from the FDA for a medical device called the "Air Compression Therapy System, Model: Airpro-690". This submission focuses on demonstrating substantial equivalence to a predicate device (LX7(V7)) through non-clinical testing for product safety and performance, rather than clinical performance based on diagnostic accuracy or AI model output.
Therefore, most of the requested information (acceptance criteria for diagnostic performance, sample size for test sets, data provenance, number of experts, adjudication methods, MRMC studies, standalone performance, type of ground truth, and training set information) is not applicable to this type of regulatory submission.
Here's what can be extracted and inferred based on the provided document:
1. A table of acceptance criteria and the reported device performance
The document lists various non-clinical tests and standards that the device met to demonstrate safety and performance, establishing substantial equivalence to the predicate device. These are not acceptance criteria in the sense of diagnostic accuracy metrics.
Characteristic / Test | Acceptance Criteria (Implied: Compliance with Standard) | Reported Device Performance |
---|---|---|
Biocompatibility | ISO 10993-1: 2009-10-15 | Met (Sleeve material demonstrated biocompatibility safety by passing ISO 10993-5 and ISO 10993-10 tests) |
Material (Patient Contact) | ISO 10993-5:2009 (in vitro cytotoxicity) | Passed |
ISO 10993-10:2010 (irritation and skin sensitization) | Passed | |
Electrical Safety | ANSI AAMI ES60601-1:2005/(R) 2012 and A1:2012 | Met (Demonstrated electrical safety) |
Electromagnetic Compatibility (EMC) | IEC 60601-1-2:2014 | Met |
Software Verification & Validation | Company's Design Control process | Met |
Basic Unit Characteristics | Design specifications | Met |
Output Specifications | Design specifications | Met |
Power Source | Safety and effectiveness (evaluated against predicate) | Similar to predicate, but passed ANSI/AAMI ES60601-1: 2005+ A1: 2012 test. |
Related Power | Safety and effectiveness (evaluated against predicate) | Similar to predicate, but passed ANSI/AAMI ES60601-1: 2005+ A1: 2012 test. |
Pressure Range | Safety and effectiveness (Implied: within acceptable therapeutic range) | 0~180mmHg (Smaller than predicate's maximum, but deemed not to raise additional risks) |
Operating Time/Therapy Time | Safety and effectiveness (Implied: comparable to predicate) | 10, 20, 30 minutes (Similar to predicate's 10~30 minutes) |
2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Not Applicable. This document pertains to the regulatory clearance of a physical medical device through substantial equivalence, not the clinical performance evaluation of an AI/diagnostic algorithm using a test set of data. The "tests" mentioned are non-clinical engineering and bench tests.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
- Not Applicable. See point 2.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not Applicable. See point 2.
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 physical therapy device, not an AI-driven diagnostic system involving human readers.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not Applicable. See point 5.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- Not Applicable. The "ground truth" for this device's clearance is its compliance with recognized safety and performance standards (e.g., ISO, ANSI/AAMI, IEC) and its functional similarity to a legally marketed predicate device.
8. The sample size for the training set
- Not Applicable. There is no AI model or "training set" in the context of this device's regulatory submission.
9. How the ground truth for the training set was established
- Not Applicable. See point 8.
Summary of the document's relevance to the prompt:
The provided document details a 510(k) submission for an Air Compression Therapy System. It focuses on demonstrating that the new device is "substantially equivalent" to a legally marketed predicate device by showing it meets the same safety and performance standards through non-clinical testing (electrical safety, EMC, biocompatibility, software verification, and validation, etc.). It does not contain information about studies related to diagnostic accuracy, AI performance, or human reader effectiveness with AI.
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