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510(k) Data Aggregation

    K Number
    K171775
    Manufacturer
    Date Cleared
    2018-01-09

    (209 days)

    Product Code
    Regulation Number
    890.5500
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Theradome LH80 PRO is an over-the-counter (OTC) therapeutic device intended to treat Androgenetic Alopecia and promote hair growth in males who have Norwood-Hamilton Classifications of IIa to V patterns of hair loss and to treat Androgenetic Alopecia and promote hair growth in females who have Ludwig-Savin Scale I-1 to I-4, II-1, II-2; both with Fitzpatrick Skin Types I to IV.

    Device Description

    The Theradome LH80 PRO for men and women is a low level coherent light therapy (LLLT) device utilised to promote hair growth. The coherent lights are contained inside a lightweight, one-size fits all helmet. The Theradome LH80 PRO uses 80 coherent light diodes in the helmet to deliver coherent light stimulation to the entire scalp for hands-free operation during treatment. An audible timer automatically turns the coherent lights off after the 20 minutes treatment is completed. This coherent light helmet is not constructed to be a safety helmet.

    AI/ML Overview

    The provided text describes the Theradome LH80 PRO device and its FDA submission (K171775). While it states that "all acceptance criteria were met by the devices," and refers to compliance with IEC-60825-2007-03, it does not explicitly list specific acceptance criteria or present the full details of a study with performance metrics in a way that allows for a direct table comparing acceptance criteria to reported device performance.

    Instead, the document primarily focuses on establishing "substantial equivalence" to predicate devices based on similar technological characteristics and intended use. It explicitly states "Brief Description of Clinical Testing: Not applicable." This indicates that a clinical study designed to test efficacy against specific hair growth metrics was not performed for this 510(k) submission.

    Therefore, many sections of your request cannot be fully answered from the provided text. I will answer what is available and indicate when information is not provided.

    1. Table of Acceptance Criteria and Reported Device Performance

    The document states that "Performance testing was conducted to confirm compliance to design specifications; all functions have been verified to operate as designed. All acceptance criteria were met by the devices." It also notes compliance with standard IEC-60825-2007-03, which establishes the AEL (accessible emission limits) as 5 milliwatts maximum. However, specific, measurable "acceptance criteria" related to efficacy (e.g., percentage increase in hair count, reduction in hair loss rate) and corresponding reported performance from a specific study are not provided in this document. The focus is on safety and technical specifications, and substantial equivalence to a predicate.

    Acceptance CriterionReported Device PerformanceComments
    Compliance with design specificationsAll functions verified to operate as designed.General statement, specific metrics not detailed.
    Compliance with IEC-60825-2007-03 (Coherent Light Class 3R)AEL (accessible emission limits) meets 5 milliwatts maximum.This is a safety standard, not an efficacy criterion.
    Usability for self-selectionVerified.Details of "verification" are not provided.
    Comprehension of user instructionsVerified.Details of "verification" are not provided.
    Comprehension of warningsVerified.Details of "verification" are not provided.
    Comprehension of precautionsVerified.Details of "verification" are not provided.
    Efficacy-related metrics (e.g., hair count)Not provided in this document for the K171775 submission.The submission relies on substantial equivalence and does not report on clinical efficacy trials for this specific submission.

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

    • Sample size for the test set: Not applicable for clinical performance as "Clinical Testing: Not applicable" is stated. For the "self-selection and usability" tests, the sample size is not mentioned.
    • Data provenance: Not specified for the usability tests. For the technical compliance, it's typically internal testing by the manufacturer.

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

    • Not applicable as clinical efficacy studies with ground truth established by experts are explicitly stated as "Not applicable" for this submission (K171775). For usability, no information on experts is provided.

    4. Adjudication Method for the Test Set

    • Not applicable, as no clinical efficacy test set is described.

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

    • No, an MRMC comparative effectiveness study was not done. The document states "Brief Description of Clinical Testing: Not applicable."

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

    • Not applicable. The Theradome LH80 PRO is a low-level light therapy device, not an algorithm or AI system.

    7. The Type of Ground Truth Used

    • For the technical performance and safety aspects, the ground truth is established by adherence to recognized standards (e.g., IEC-60825-2007-03) and design specifications.
    • For usability and self-selection, the ground truth would typically be user feedback or observation, but specific details are not provided.
    • For clinical efficacy (e.g., hair growth), no ground truth data from a clinical study is included in this submission.

    8. The Sample Size for the Training Set

    • Not applicable, as this is a medical device for light therapy, not an AI/ML algorithm that requires a training set.

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

    • Not applicable, as this is not an AI/ML algorithm.
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    K Number
    K122950
    Device Name
    LASER HELMET
    Manufacturer
    Date Cleared
    2013-06-14

    (262 days)

    Product Code
    Regulation Number
    890.5500
    Reference & Predicate Devices
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Theradome Laser Helmet LH80 PRO is an over the counter (OTC)device indicated to treat androgenic alopecia, to Promote hair growth in females with female pattern hair loss (FPHL) on the Ludwig and Savin Hair Loss Scale I-II, Fitzpatrick Skin-Types I to IV:

    Device Description

    The Theradome Laser Helmet LH80 PRO is a low level laser therapy (LLLT) device used to promote hair growth via photobiostimulation. The lasers are contained inside a lightweight, one-size fits all helmet. The LH80 PRO utilizes 80 laser diodes in the helmet to deliver laser stimulation to the entire scalp for hands-free operation during treatment. The device is one-button operated, and has an audible timer that automatically turns the lasers off after the 20 minute treatment completes.

    AI/ML Overview

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

    1. Table of Acceptance Criteria and Reported Device Performance

    The provided document describes two studies related to over-the-counter use for the Theradome Laser Helmet LH80 PRO. These studies are designed to demonstrate the device's appropriateness for consumer use by lay persons, not its clinical effectiveness in treating androgenic alopecia.

    Acceptance Criteria CategorySpecific Acceptance CriteriaReported Device Performance
    Self-Assessment Capability95% of lay persons should be able to correctly self-assess their need for the LH80-PRO based on product labeling.97% of lay persons were able to correctly self-assess their need for the LH80-PRO. (30 out of 31 participants)
    Labeling ComprehensionAn average lay person should be able to read and comprehend the package labeling and instructions correctly.The study concluded that an average lay person can read and comprehend correctly the package labeling and instructions. (Specific percentage not provided, but implies 100% based on the conclusion statement)

    2. Sample Sizes and Data Provenance

    • Test Set Sample Size: For both the "Self-Selection Study" and the "Labeling Comprehension Study," the sample size was 31 participants.
    • Data Provenance: The participants were recruited from the downtown San Francisco commuter train station (Bay Area Rapid Transit - BART) in the USA. The studies appear to be prospective as participants were selected and surveyed specifically for these studies.

    3. Number and Qualifications of Experts for Ground Truth

    • Self-Selection Study:
      • Number of Experts: At least one physician. The text states: "...their hair condition was also examined by a physician who then decided if the person actually had Androgenic Alopecia or not."
      • Qualifications of Experts: A "physician" is mentioned. Specific qualifications (e.g., years of experience, specialization like dermatology) are not provided.
    • Labeling Comprehension Study:
      • Number of Experts: Not applicable, as the ground truth was based on participants' direct answers to questions about their comprehension, verified by study administrators.

    4. Adjudication Method for the Test Set

    • Self-Selection Study: The decision on whether a person actually had Androgenic Alopecia was made by a physician. This implies a single expert's judgment. There's no mention of multiple experts or specific adjudication methods (like 2+1).
    • Labeling Comprehension Study: This study involved participants answering questions, and study administrators evaluating their responses. There's no mention of external experts or adjudication beyond the administrators' assessment of correct comprehension.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    No. The document does not describe a multi-reader multi-case (MRMC) comparative effectiveness study. The studies mentioned are focused on user comprehension and self-assessment for OTC use, not clinical effectiveness or human-in-the-loop performance improvement with AI.

    6. Standalone (Algorithm Only) Performance Study

    No. The device is a physical laser helmet, not an algorithm. Therefore, a standalone (algorithm only) performance study as typically understood in the context of AI/software medical devices is not applicable and was not done. The studies focus on user interaction with the device's labeling and its intended OTC use.

    7. Type of Ground Truth Used

    • Self-Selection Study: The ground truth for whether a participant actually had Androgenic Alopecia was established by a physician's examination.
    • Labeling Comprehension Study: The ground truth for correct comprehension was based on participants' answers to specific questions about the labeling, assessed by the study administrators.

    8. Sample Size for the Training Set

    Not applicable. The provided studies are for evaluating consumer comprehension and self-assessment of an over-the-counter device, not for training a machine learning algorithm. Therefore, there is no training set mentioned or implied.

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

    Not applicable. As there is no training set for an algorithm, there is no ground truth established for it.

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    K Number
    K113097
    Device Name
    LASER HELMET
    Manufacturer
    Date Cleared
    2012-03-02

    (135 days)

    Product Code
    Regulation Number
    890.5500
    Reference & Predicate Devices
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Theradome Laser Helmet LH80 PRO is intended to treat androgenic alopecia by promoting hair growth.

    The Theradome Laser Helmet LH80 PRO is a prescription use therapeutic device indicated to promote hair growth in females, with androgenic alopedia, having Ludwig and Savin Hair Loss Scale classification I-II and Fitzpatrick Skin-Types I to IV.

    Device Description

    The Theradome Laser Helmet LH80 PRO is a low level laser therapy (LLT) device used to promote hair growth via photobiostimulation. The lasers are contained inside a lightweight, one-size fits all helmet. The LH80 PRO utilizes laser diodes in the heimet to deliver laser stimulation to the entire scalp for hands-free operation during treatment. The device is one-button operated, and has an audible timer that automatically turns the lasers off after the 20 minute treatment completes.

    AI/ML Overview

    The provided text is a 510(k) summary for the Theradome Laser Helmet LH80 PRO. It describes the device, its intended use, indications for use, and a comparison to a predicate device to establish substantial equivalence. However, it does not contain information about specific acceptance criteria or a study proving the device meets those criteria, especially in terms of clinical performance or a multi-reader multi-case study.

    Here's a breakdown of why the requested information cannot be fully provided from the given text:

    • Type of Device: The Theradome Laser Helmet LH80 PRO is a low-level laser therapy (LLT) device intended to promote hair growth. This type of device typically relies on clinical studies to demonstrate efficacy, but this document does not present such a study.
    • Focus of the Submission: The 510(k) summary primarily focuses on demonstrating substantial equivalence to a predicate device (RF Midwest LLC MEP-90 Hair Growth Stimulation System K091496) based on technological characteristics, intended use, and indications for use.
    • "Performance Characteristics" Section: This section mentions "Testing to IEC 60601-1 and 60601-1-2 confirm the device's safety and electrical compatibility" and "Testing to IEC 60825-1 certifies the laser system to classification 3R, same as predicate device." It also states, "Performance testing was conducted to confirm compliance to design specifications; all functions were verified to operate as designed." These are safety and engineering performance tests, not clinical efficacy studies with specific acceptance criteria as you've outlined.

    Given the limitations of the provided text, I can only address the questions where information is explicitly available or directly inferred.


    Acceptance Criteria and Study for Theradome Laser Helmet LH80 PRO

    The provided 510(k) summary does not disclose specific clinical acceptance criteria for hair growth efficacy or a study proving those criteria. The submission focuses on demonstrating substantial equivalence to a predicate device, primarily through safety, electrical compatibility, and laser classification testing, rather than an independent clinical efficacy trial with predefined performance metrics.

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria CategorySpecific MetricAcceptance CriterionReported Device Performance
    Clinical Efficacy(Not Specified)(Not Specified)(Not specified in this document)
    Safety (Electrical)Adherence to IEC StandardIEC 60601-1Confirmed to comply
    Safety (Electromagnetic Compatibility)Adherence to IEC StandardIEC 60601-1-2Confirmed to comply
    Safety (Laser Classification)Adherence to IEC StandardIEC 60825-1 Classification 3RCertified to Classification 3R (same as predicate)
    Design SpecificationsFunctional OperationAll functions operate as designedConfirmed to comply

    Note: The 510(k) summary explicitly states "Performance testing was conducted to confirm compliance to design specifications; all functions were verified to operate as designed." This refers to engineering and functional performance, not clinical outcome performance.

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

    • Sample Size for Test Set: Not applicable / Not mentioned for clinical efficacy. The performance tests mentioned (IEC standards, design specifications) are typically conducted on a limited number of device units for engineering verification, not a clinical "test set" in the context of patient data.
    • Data Provenance: Not applicable for clinical data. The mentioned tests are engineering/safety in nature and would be conducted in a lab environment.

    3. Number of Experts Used to Establish Ground Truth and Qualifications

    • Number of Experts: Not applicable. The document does not describe a clinical study requiring expert assessment for ground truth.
    • Qualifications of Experts: Not applicable.

    4. Adjudication Method for the Test Set

    • Adjudication Method: Not applicable. The document does not describe a clinical study or expert review process that would require an adjudication method.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    • Was an MRMC study done? No, an MRMC study was not described or conducted, as this device does not involve image interpretation or diagnostic performance that would necessitate such a study.

    6. Standalone Performance Study (Algorithm Only Without Human-in-the-Loop)

    • Was a standalone study done? Not applicable. This device is a therapeutic (LLT) device, not an AI algorithm. Its performance is directly tied to its physical operation and biological effect, not an algorithmic interpretation task.

    7. Type of Ground Truth Used

    • Type of Ground Truth: Not applicable for clinical efficacy. For the safety and performance tests mentioned (IEC standards, design specifications), the "ground truth" would be the engineering specifications and compliance requirements of the respective standards.

    8. Sample Size for the Training Set

    • Sample Size for Training Set: Not applicable. The device does not involve machine learning or AI that would require a training set.

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

    • How Ground Truth for Training Set Was Established: Not applicable, as there is no training set for this type of device.
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