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510(k) Data Aggregation
(194 days)
Soterix Medical, Inc.
The Milieve is indicated for
- The acute treatment of migraine with or without aura in patients 18 years of age or older.
- The prophylactic treatment of episodic migraine in patients 18 years of age or older.
The Milieve device is a transcutaneous electrical nerve stimulator (TENS) developed for the acute treatment of migraine and the prophylactic treatment of episodic migraine. The device is placed on the patient's forehead to stimulate the upper branch of the trigeminal nerve. It is harmless to the human body. The Milieve device is indicated for OTC use.
There are two treatment programs: ACUTE and PREVENT. The ACUTE treatment program is intended for treatment during migraine attack at the onset of a migraine. The PREVENT treatment program is meant for daily preventative treatment.
The Mileve device comprises a plastic external casing and electrical components. It is operated by an internal rechargeable battery.
The provided text is a 510(k) summary for the Milieve (YPS-301BD) device, a transcutaneous electrical nerve stimulator for migraine treatment. The summary demonstrates substantial equivalence to a predicate device (Cefaly Dual).
The document does not describe a study involving an AI/algorithm where acceptance criteria are set for the performance of the AI model itself. Instead, it focuses on demonstrating the Milieve device's substantial equivalence to a predicate device through bench testing and comparison of technical specifications. The acceptance criteria and "device performance" in this context refer to the physical and electrical characteristics of the Milieve device and how they compare to those of the predicate device.
Therefore, many of the requested points from your prompt (e.g., sample size for test/training sets, number of experts for ground truth, MRMC studies, standalone AI performance) are not applicable to this type of submission, as the Milieve device is a hardware medical device, not an AI/algorithm-based diagnostic or therapeutic system.
However, I can extract and present the relevant information regarding the device's "performance" and how its "acceptance criteria" (understood as equivalency to the predicate) are met based on the provided text.
Acceptance Criteria and Device Performance (Demonstration of Substantial Equivalence)
The acceptance criteria for the Milieve device are implicitly based on demonstrating substantial equivalence to the predicate device, Cefaly Dual. This is achieved by showing that the technological characteristics and performance parameters are either identical or substantially equivalent, and that any differences do not raise new questions of safety and effectiveness.
1. Table of Acceptance Criteria and Reported Device Performance:
The provided table directly compares the Milieve device to the Cefaly Dual (Predicate Device). The "Comparison" column indicates whether the parameters are "Identical" or "Substantially Equivalent (SE)" with notes explaining the implications of the differences.
Parameter | Acceptance Criteria (Predicate Device - Cefaly Dual) | Reported Device Performance (Milieve) | Comparison |
---|---|---|---|
Indications For Use | Acute treatment of migraine with or without aura in patients 18 years or older; Prophylactic treatment of episodic migraine in patients 18 years or older. | Identical to predicate. | Identical |
Classification Name | Stimulator, Nerve, Electrical, Transcutaneous, For Migraine | Identical to predicate. | Identical |
Product Code | PCC | Identical to predicate. | Identical |
Regulatory Class | Class II | Identical to predicate. | Identical |
Classification Number | Sec 882.5891 | Identical to predicate. | Identical |
Contraindications For Use | Subjects with implanted metallic or electronic devices in the head; suffering from pain of unknown origin; who have a cardiac pacemaker or implanted/wearable defibrillator. | Identical to predicate. | Identical |
Power Source | Rechargeable 3.7V LiPo Battery | Identical to predicate. | Identical |
Software provided (Programs) | 2 fixed programs (Acute, Prophylactic) | Identical to predicate. | Identical |
Program 1 (Acute Migraine) | |||
Max. output current | ≤ 16 mA | 16 mA | Identical |
Pulse width | 250 µs | 250 µs | Identical |
Pulse frequency | fixed 100 Hz | fixed 100 Hz | Identical |
Session duration | fixed 60 minutes | fixed 60 minutes | Identical |
Program 2 (Prophylactic) | |||
Max. output current | ≤ 16 mA | 16 mA | Identical |
Pulse width | 250 µs | 250 µs | Identical |
Pulse frequency | fixed 60 Hz | fixed 60 Hz | Identical |
Session duration | fixed 20 minutes | fixed 20 minutes | Identical |
Waveform | Biphasic, symmetric, rectangular current impulses with zero electrical mean | Identical to predicate. | Identical |
Phase Duration (Pulse width) | 250 µs | 250 µs | Identical |
Inter Phase Interval | 5 µs | 5 µs | Identical |
Maximum Current Intensity | @500 Ω: 16 mA; @2000 Ω: 16 mA; @10000 Ω: 6 mA | @500 Ω: 16 mA; @2000 Ω: 16 mA; @10000 Ω: 6 mA | Identical |
Maximum average current @500 Ω | 0.48 mA | 0.48 mA | Identical |
Maximum output voltage | @500Ω: 8 V; @2000Ω: 32 V; @10000Ω: 60 V | @500Ω: 8 V; @2000Ω: 32 V; @10000Ω: 60 V | Identical |
Ramp up Time | 14 min | 14 min | Identical |
Steady Time | 6 min | 6 min | Identical |
Ramp down Time | 45 s | 60 s | SE (Note 1) |
Maximum Phase Charge @500 Ω | 4 µC | 4 µC | Identical |
Net Charge per Pulse | 0 | 0 | Identical |
Maximum Current Density @500 Ω | 2.37 mA/cm2 | 2.37 mA/cm2 | Identical |
Maximum Average Power Dens @500 Ω | 0.000047 W/cm2 | 0.000047 W/cm2 | Identical |
Dimensions | 55 mm x 40 mm x 15 mm | 44.05 mm x 38.98 mm x 14.5 mm | SE (Note 2) |
Weight | 12 g | 21 g | SE (Note 3) |
Electrode | Self-adhesive with 2 conductive zones | Identical to predicate. | Identical |
Device output ports | 2 magnets for connection with electrode | Identical to predicate. | Identical |
Notes on Substantial Equivalence:
- Note 1 (Ramp down Time): "The subject device has a slightly longer ramp down time. This longer ramp time helps with subject comfort. This difference will not raise new questions of efficacy as the therapeutic session times (20 min and 60 min) are identical."
- Note 2 (Dimensions): "The dimension of the subject device is slightly different from the predicate device. This minor difference will however not raise any new safety and effectiveness issues."
- Note 3 (Weight): "The weight of the subject device is slightly more than the predicate device. This minor weight increase has not impacted the ability to hold device and electrode reliably on the forehead in the in-house tests conducted and the human factors validation study. It is therefore expected to not raise any new safety and effectiveness issues."
Regarding the AI/Algorithm-specific questions (which are not applicable to this submission):
- 2. Sample size used for the test set and the data provenance: Not applicable. The study was bench testing of a hardware device.
- 3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. Ground truth was established by direct measurement against engineering specifications and comparison to the predicate device.
- 4. Adjudication method for the test set: Not applicable. Performance was assessed via 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 is a hardware medical device, not an AI-assisted diagnostic tool.
- 6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done: Not applicable. The device is a TENS unit, not an algorithm, and its use is intended for direct patient application (OTC).
- 7. The type of ground truth used: For the technical specifications, the ground truth is the performance parameters of the predicate device and established engineering standards. For the human factors validation (mentioned for weight), the ground truth is likely defined by user feedback and ability to use the device as intended.
- 8. The sample size for the training set: Not applicable. No AI model was trained.
- 9. How the ground truth for the training set was established: Not applicable. No AI model was trained.
Summary of the Study Proving Acceptance Criteria:
The study involved bench testing to demonstrate that the Milieve device's performance parameters are "substantially equivalent" to those of the predicate device (Cefaly Dual). Additionally, software verification and validation and risk management were conducted to support this equivalence. A human factors validation study was also mentioned regarding the device's weight, indicating that the slightly increased weight did not negatively impact usability.
The overarching "acceptance criteria" here is the demonstration of substantial equivalence to a legally marketed predicate device, as per 510(k) requirements. The study successfully met these criteria by showing identical or non-concerning, explained differences in all critical parameters.
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(94 days)
Soterix Medical, Inc.
MEGA-IOM system with Neuro-IOM.NET software is a medical device intended for intraoperative neurophysiologic monitoring: the device provides information to assess a patient's neurophysiological status.
The system allows to monitor the functional integrity and/or mapping of central and peripheral nervous system including motor and sensory pathways.
It is provided in three different configurations:
I. 32/B
II. 32/S
III. 16/S
The system ensures the following IOM modalities: free-run EMG (electromyography), direct nerve stimulation including pedicle screw test, SSEP (somatosensory evoked potential), MEP (motor evoked potential), EEG (electroencephalography), AEP (auditory evoked potential), VEP (visual evoked potentials), direct cortical stimulation. Also the train-of-four (TOF) stimulation is performed.
The system is not intended to measure vital signs. It records the data to be interpreted by the neuromonitoring specialist.
MEGA-IOM system is intended for use in adults age 18 years and older.
The MEGA-IOM system with Neuro-IOM.NET software is intended for intraoperative neurophysiological monitoring (IOM).
The system is intended for monitoring the functional integrity and/ or mapping of central and peripheral nervous system including motor and sensory pathways.
Soterix Medical is assuming manufacturing of the predicate product cleared in K190703. This 510(k) submission includes the same hardware cleared with the predicate device system (no changes) and an updated version of the software compared to the predicate device.
Below, a high-level summary of the changes from the predicate are provided:
Software: The primary changes in this 510(k) submission are related to the software. The changes are troubleshooting updates for greater usability such as user interfaces and bug fixes. Detailed descriptions of these software changes per version are provided below:
Version 1.1.52.7: Fixes related to the stimulation stop after a few hours, adding a stimuli limit for double train stimulation, allowing pulse duration (200 microseconds) entry, masking noise limitation per IEC 60601-2-40 (Particular requirements for the basic safety and essential performance of electromyographs and evoked response equipment), reporting correct status of multichannel operation, prevent skipping of traces, and check for incompatible stimulation parameter entry.
Version 1.1.52.8: Fixes related to facilitating quick turning off stimulation, real-time stimulus change control, scrolling in spectral setup window, constraining window within pattern printout to screen, ensuring modality window description is unchanged, incorrect Ch 17 display in emulation mode, video filters error during installation, ensuring all text is displayed within visibility area, incorrect auditory evoked potentials (EPs) average calculation in emulation mode.
Version 1.1.52.9: Fixes related to exam saved message, flexibility to change test template sequence, sleep mode prevention, rendering speed, interpulse interval display correction, allowing comments in the event window, automatic creation of user template, template list update, impedance measurement window rendering, parameter display correction in EMG trigger window and Group mode, ensuring non-disappearance of red line around patient's birth date, enabling stimulation via local menu in Scoliosis test template, frame switching error during video recording, displaying correct device status.
Version 1.1.53.7: Fixes related to addition of video clip creation button, accidental stimulation activation protection, display of preliminary train in double train mode, voltage and charge value display in stimulation panel, allowing repetitive stimulation in Double Train and Train+Pulse modes, option to view amplitude values up to 10 microA, option to select scales in X axis, option to delay auto saving if stimulation in progress, option to titrate stimulation amplitude using mouse wheel, option to select grid type, confirmation on layout uninstallation, addition of the Pause button in Stimulation programs, option to select motor response search interval and displaying the motor response search interval, addition of measured impedance visualization, offering first the windows already available when adding a new window, preventing closure of window if input row is active in derivation test, enable display of additional TOF parameters, option to playback trace fragments, addition of Take a screenshot command, parameter trend export, pulse duration interval display in TES train, option to enter multiple-line comments, option to re-name layout, option to hide command list, ability to save only responses beyond a certain level, stimulator list scrolling, RMS noise value display, test template cloning, motor response onset marker, previous recorded traces display, layouts during new test reset, stimulator reminder mod, video file duration based on frame rate, saving of the number of traces, test template rewriting, group trace visualization display, layout switching, stimulation resumption post coagulator off, video playback if another program is run.
Version 1.1.53.8: Fixes related to allowing multiple image view within the image window, allowing EEG artifact recording, showing baseline in the Overlay mode, option to disable program, option to save screen shots to a specific folder, stimulation program panel addition, correction of autoincrement window bug, correction of DSA rendering.
Version 1.1.53.9: Fixes related to custom scale adjustment in Freerun window, randomly changing pulse intervals in multichannel mode, event trace copy to report, layout panel updating post deletion, sound, threshold, and color parameter display during new site addition, EMG channels in template during long-term monitoring, site visibility during stimulation in presence of temporary markers, auto sweep resets, temporary markers display, trace export to EDF, layout non-save post video window opening, type conversion in trace window.
Version 1.53.10: Fixes related to video window copying over to report, trace scale reset, appearance of average trace display in case of no averages due to artifacts, site name display in TOF window, saving of initial study state in autosave mode, incomplete installation of video components, volume increment of auditory stimulator signal volume.
Version 1.1.53.11: Fixes related to active probe switch-off during monitoring, limiting maximum increment adjustment of electrical stimulation amplitude to 1 mA and 5V, stimulus duration set-up when stimulation amplitude is increased, stimulation disablement after power supply resume, stimulus sound notification, text visualization in dialogue box, non-active stimulator panel, maximum stimulus artifact width display, minimum and maximum MEP trace markers.
Version 1.1.53.12: Fixes related to pulse width change during stimulation in multichannel mode, MS Office word report, TeamViewer, logo, and translation corrections.
Version 1.1.53.13: Fixes related to removal of sites containing TOF and logo change.
Version 1.1.53.14: Fixes related to start monitoring during video camera switch off, video recording in some interface languages, sound disablement during impedance measurement, printing test template, USB driver-related Windows 10 OS bugs.
In summary, the aforementioned software changes are related to resolving software bugs and increasing user convenience, but the changes do not impact the intended use, indications for use statement, contraindications, or warnings. They also don't increase the likelihood that the device will be used by a broader or different group of users and do not raise any new risks.
Labeling: Modifications have been made to labeling and these changes are related to the new device trade name and change in manufacturer. Instances of "Neuro-IOM" were changed to "MEGA-IOM" in the user manual and on the device labels. Soterix Medical is named the manufacturer and point of contact in the labeling including for all complaints and service requests.
Waveforms: The MEGA-IOM system has the same waveforms as the predicate device. No change to the waveforms.
The provided text is a 510(k) Premarket Notification from the FDA for the "MEGA-IOM system with Neuro-IOM.NET software". This document primarily focuses on demonstrating substantial equivalence to a predicate device (K190703 Neuro-IOM system with Neuro-IOM.NET software) rather than detailing extensive clinical studies with acceptance criteria for new device performance.
The submission is for a device that has primarily undergone software updates and a change in manufacturer. Therefore, the "study that proves the device meets the acceptance criteria" is in the form of software verification and validation, and comparison to the predicate device's established performance.
Here's an analysis based on the provided text:
1. A table of acceptance criteria and the reported device performance:
The document doesn't provide explicit "acceptance criteria" in the traditional sense of a clinical trial (e.g., target sensitivity/specificity for a diagnostic AI). Instead, the acceptance criteria are implicitly demonstrating that the updated software, in conjunction with the unchanged hardware, performs identically or equivalently to the predicate device. The performance is assessed by confirming that all functional and technical specifications remain the same.
Parameter | Acceptance Criteria (Implicit - Identical to Predicate) | Reported Device Performance (MEGA-IOM) | Comment |
---|---|---|---|
Device Name and Model | Neuro-IOM 16S, 32S, 32B with Neuro-IOM.NET software | MEGA-IOM 16S, 32S, 32B with Neuro-IOM.NET software | New trade name for the subject device. Functionally identical. |
Classification Name | Stimulator, Electrical, Evoked Response | Stimulator, Electrical, Evoked Response | Identical |
Product Codes | GWF (primary), GWE, GWJ, OLT, PDQ | GWF (primary), GWE, GWJ, OLT, PDQ | Identical |
Regulatory Class | Class II | Class II | Identical |
Classification Number | 21 CFR 882.1870 | 21 CFR 882.1870 | Identical |
Indications for Use (IFU) | Matches predicate (detailed in document) | Matches predicate (detailed in document) | Similar; new IFU includes new device name. All other wording identical. |
Intended User | Trained personnel only | Trained personnel only | Identical |
Device Hardware Setup | Connected to PC, not standalone | Connected to PC, not standalone | Identical (hardware is unchanged) |
Electrical Safety Standards | Conforms to specified standards (older versions acceptable for predicate) | Conforms to updated versions of same standards | Subject device conforms to updated versions of standards. |
Workflow, Menu | PC-controlled | PC-controlled | Identical |
Interface to Computer | USB | USB | Identical |
Channels | 16/32 | 16/32 | Identical |
1.5 mm touch-proof input jacks | Same | Same | Identical |
Cable Length | 5m | 5m | Identical |
Input Impedance | >1000 MOhm | >1000 MOhm | Identical |
Common Mode Rejection (CMRR) | >90 dB | >90 dB | Identical |
Low Frequency Filters | 0.2 Hz - 2000 Hz | 0.2 Hz - 2000 Hz | Identical |
High Frequency Filters | 10 Hz - 4 kHz | 10 Hz - 4 kHz | Identical |
Notch Filter | 50/60 Hz | 50/60 Hz | Identical |
Sample Rate | 50 kHz | 50 kHz | Identical |
Sensitivity | 0.05 µV/division to 20 mV/division | 0.05 µV/division to 20 mV/division | Identical |
Noise Level |
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(681 days)
Soterix Medical, Inc.
Stimulation of peripheral nerves for diagnostic purposes.
The MEGA-TMS is intended for stimulation of peripheral nerves for diagnostic purposes. The device introduces electrical stimulation to tissue through magnetic induction generated from the coil. The obtained responses of stimulated structures is recorded with an EMG system for further diagnostic evaluation. The MEGA-TMS device is intended to be paired with a Focus EMG device cleared under FDA 510(k): K102610. Magnetic stimulation is used for peripheral nerve conduction studies and to evaluate peripheral nervous system.
The provided text is a 510(k) summary for the MEGA-TMS device, which is an evoked response electrical stimulator used for diagnostic purposes. It primarily focuses on demonstrating substantial equivalence to predicate devices and does not describe a study to establish acceptance criteria for an AI/CADe device's performance.
Therefore, I cannot extract the requested information regarding AI/CADe acceptance criteria or the study proving a device meets them. The document mentions performance testing, but this refers to safety, EMC, design verification, and risk management for the electrical stimulator, not an AI or CADe system.
The closest relevant information, though not directly applicable to an AI device's performance, is under "Electric and Magnetic Field Characteristics," where measurements and simulations were performed for electric and magnetic fields. However, this pertains to the physical and electrical characteristics of the stimulator itself, not the diagnostic performance of an AI.
To directly answer your request based on the provided text, the document does not contain the specific information you are looking for regarding acceptance criteria and a study proving an AI/CADe device meets those criteria.
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(313 days)
Soterix Medical, Inc.
The Neural Navigator is a neuronavigation system indicated for accurate positioning of the treatment coil of the CloudTMS Therapy System with respect to target brain regions based on data obtained from MRI measurements. Specifically, the Neural Navigator is indicated for use with the following CloudTMS Therapy System coils manufactured by Neurosoft Ltd: AFEC-02-100 and AFEC-02-100-C.
The Neural Navigator combines MRI-based, 3-D localization of cortical motor areas of the brain with non-invasive TMS and simultaneous EMG measurement to locate areas of the brain that are capable of evoking muscle responses when stimulated, and to locate the target area for depression therapy. The Neural Navigator software is used to import a patient's MR image slices through standard DICOM communication protocols, and automatically generates an accurate 3-D model of the patient's head, and a custom automatic tissue segmentation routine to reveal anatomical structures of the brain surface in 3D.
The provided text describes the 510(k) premarket notification for the Neural Navigator device. While it asserts substantial equivalence based on performance testing, it does not explicitly define "acceptance criteria" in a quantitative table with specific thresholds as would be typical for a detailed study report. However, it implicitly presents performance metrics and their comparison to predicate devices, which serve as the basis for acceptance.
Here's an attempt to extract and rephrase the information to fit the requested format, acknowledging the limitations of the provided document:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not present explicit acceptance criteria with defined pass/fail thresholds. Instead, it compares the Neural Navigator's performance to its predicate devices, implying that performance comparable to or better than the predicate is considered acceptable.
Parameter | Implicit Acceptance Criterion (Compared to Predicate) | Reported Neural Navigator Performance |
---|---|---|
Tracking System Accuracy |
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(90 days)
SOTERIX MEDICAL,INC.
IontoDC is intended to use a direct current to introduce ions of soluble salts or other drugs into the body.
IontoDC is a bench-top, battery powered, microcontrollercontrolled iontophoresis device that delivers direct current to a drug delivery electrode placed on the patient's skin. This current expedites the migration of ionic drug solutions through the skin into localized tissue.
This 510(k) premarket notification describes the IontoDC, an iontophoresis device. The review of the provided document indicates that the submission focuses on demonstrating substantial equivalence based on technological characteristics and performance testing against predicate devices, rather than a clinical study evaluating the device's efficacy in treating a specific condition or detecting a disease. Therefore, many of the requested items related to clinical studies, such as sample sizes for test and training sets, expert qualifications, and comparative effectiveness studies, are not applicable in this context.
Here's a breakdown of the available information:
1. Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria for the IontoDC device are implicitly the electrical output parameters and safety standards of the predicate devices and relevant IEC standards. The document outlines a comparison of the IontoDC's parameters with two predicate devices: Dynatron® ibox (primary) and ActivaDose II (reference).
Parameter | Acceptance Criteria (Predicate Devices - IBox & ActivaDose II) | IontoDC Reported Performance | Comparison Outcome |
---|---|---|---|
Indications For Use | Introduce ions of soluble salts or other drugs into the body. | Identical to primary predicate (Dynatron® ibox). | Identical to Primary Predicate |
Power source | Battery Powered. | Battery Powered. | Identical |
Number, Size, and Type of Batteries | One 9V (ActivaDose II), Two 1.5V AA (Dynatron® ibox). | Two 9 Volt Alkaline batteries. | Not identical, but complies with IEC 60601-1; difference does not raise safety issues (Note 1). |
Output Jacks | 1 (ActivaDose II), 2 (Dynatron® ibox). | 2. | Identical to Primary Predicate |
Current Intensity | 0.0 - 4.0 mA DC (ActivaDose II), 0.5 - 4.0 mA DC (Dynatron® ibox). | 1.0 - 2.0 mA DC. | Lower maximum current (2 mA vs 4 mA) but all devices comply with IEC 60601-1; difference does not raise new safety or effectiveness issues (Note 2). |
Current Accuracy | +/- 10% (Dynatron® ibox). | +/- 1%. | Better accuracy (1% vs 10%) but both comply with IEC 60601-1; difference does not raise new safety or effectiveness issues (Note 3). |
Current Precision | 0.1 mA (ActivaDose II, Dynatron® ibox). | 0.1 mA. | Identical |
Voltage at Electrodes | 80 Volts (ActivaDose II), +/- 0-46 Volts (Dynatron® ibox). | +/- 0-40 Volts. | Slightly different/lowest, but all comply with IEC 60601-1; difference does not raise new safety or effectiveness issues (Note 4). |
Electrode Cable Jacks | -- (ActivaDose II), Custom 2-pin polarized (Dynatron® ibox). | Shielded banana. | Different type, but both ensure reliable connection; difference does not raise new questions of safety and effectiveness (Note 5). |
Maximum Total Deliverable Dose | 80 mA-min (ActivaDose II), 3360 mA-min (Dynatron® ibox). | 80 mA-min. | Identical to Reference Device (ActivaDose II). |
Single Treatment Deliverable Dose | 0 - 80 mA-min (ActivaDose II), 1 - 160 mA-min (Dynatron® ibox). | 10mA - 80 mA-min. | Slightly different range, but upper limit does not exceed predicate devices; difference does not raise new safety or effectiveness issues (Note 6). |
Number of 40 mA-min. Treatments | 2 (ActivaDose II), 89 (Dynatron® ibox). | 2. | Identical to Reference Device (ActivaDose II). |
Minimum Treatment Time | 1.5 seconds (ActivaDose II), 15 seconds (Dynatron® ibox). | 10 min. | Longer, but can be manually adjusted; difference does not raise new safety or effectiveness issues (Note 7). |
Maximum Treatment Time | 20 minutes (ActivaDose II), 100 minutes (Dynatron® ibox). | 40 min. | More than one predicate, less than another, but can be manually adjusted; difference does not raise new safety or effectiveness issues (Note 8). |
Timing Accuracy | +/- 1 second (ActivaDose II, Dynatron® ibox). | +/- 3 second. | Different, but does not raise new safety or effectiveness issues for iontophoretic use (Note 9). |
Polarity Options | Positive (+), Negative (-), Dual Polarity (NO) (ActivaDose II, Dynatron® ibox). | Positive (+), Negative (-), Dual Polarity (YES). | Identical (for Positive/Negative) and identical to reference device for Dual Polarity (meaning both IontoDC and ActivaDose II do not have it, or it aligns with whichever predicate is being compared for that feature). |
Low Battery Warning | YES (During Treatment and At Power-On for both). | YES (During Treatment and At Power-On). | Identical |
Overcurrent Warning | YES, if >2.2 mA (ActivaDose II), YES, at 4 mA (Dynatron® ibox). | YES, if >2.2 mA. | Different threshold due to lower maximum current (2mA); difference does not raise safety or effectiveness issues (Note 10). |
Certificates | IEC 60601-1, CSA/NRTL (both predicates). | IEC 60601-1, CSA/NRTL. | Identical |
Dimensions (in.) | Varied (7.91"x5.9"x2.83" for ActivaDose II, 6.1"x3.5"x1.9" for Dynatron® ibox). | Not provided, but stated as "different". | Different, but does not raise safety or effectiveness issues (Note 11). |
Weight (lbs., oz.) | Varied (1 lb 3oz for ActivaDose II, 0.4 lbs for Dynatron® ibox). | Not provided, but stated as "different". | Different, but does not raise safety or effectiveness issues (Note 12). |
Display | Digital Display (ActivaDose II, Dynatron® ibox). | Organic Light Emitting Diodes (OLED). | Identical to Reference Device (ActivaDose II) (likely referring to the function of displaying digital information). |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Not Applicable. The submission relies on bench testing and compliance with international standards (IEC 60601-1, IEC 60601-1-2) for electrical output parameters and EMC, and software verification and validation. There is no clinical test set mentioned.
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. There was no clinical test set requiring expert consensus for ground truth. The "ground truth" for this device's performance is compliance with established electrical and safety standards, as measured by engineering tests.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not Applicable. No clinical test set.
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 hardware device (iontophoresis device), not an AI/imaging diagnostic tool. No MRMC study was performed.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
- Not Applicable. This device is not an algorithm. Bench testing evaluated the device's performance in isolation.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
- The "ground truth" for demonstrating substantial equivalence for this device is based on:
- Compliance with recognized electrical safety and EMC standards: IEC 60601-1 (medical electrical equipment general requirements for basic safety and essential performance) and IEC 60601-1-2 (medical electrical equipment electromagnetic compatibility).
- Bench testing measurements: Direct comparison of the electrical output parameters of the IontoDC device against those of the predicate devices.
- Software verification and validation: As per FDA guidance for a "Moderate" level of concern software.
8. The sample size for the training set
- Not Applicable. There is no "training set" in the context of an AI/imaging device. The device's design and manufacturing processes are likely informed by engineering principles and iterations, but not a data-driven training set in the typical AI sense.
9. How the ground truth for the training set was established
- Not Applicable. See point 8.
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