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510(k) Data Aggregation
(175 days)
TYRELL, INC.
Zeno is indicated for the treatment of individual actic pimples in persons with mild to moderate inflammatory acne.
Zeno is a portable hand-held device that produces accurately controlled low level sustained heat for use in treating dermatological disorders, specifically, mild to moderate acne. Individual acne blemishes are treated for a preset time of 2 ½ minutes at a preset temperature. The treatment tip is made from a biocompatible material and delivers the specific low-level heat to the individual acne blemish. The device is powered by rechargeable AAA nickel-metal hydride batteries.
The provided document is a 510(k) premarket notification for the Zeno™ Acne Device. It details the device's indications for use, summary of substantial equivalence, and some performance data. However, it does not explicitly state acceptance criteria or provide a detailed study report that proves the device meets specific performance criteria.
Here's an analysis of the information that can be extracted, and what is missing based on your request:
Information Extracted from the Document:
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Acceptance Criteria and Reported Device Performance:
- The document states: "Clinical testing was conducted in both a controlled practitioner office environment and a consumer home-use environment and submitted as part of the 510(k) application to confirm that Zeno is as safe and effective as the predicate device."
- It also mentions: "Preclinical testing demonstrated significant sensitivity of p. acnes bacterial cells to the effects of sustained low-level heat."
- However, specific quantitative acceptance criteria (e.g., a certain percentage reduction in acne lesions, a specific lesion resolution time) and the reported device performance against those criteria are not provided in this document. The document concludes that "the proposed device has been shown to be safe and effective for its intended use" based on testing, but the numerical results of that testing are absent.
Table of Acceptance Criteria and Reported Device Performance:
Performance Metric/Acceptance Criteria Reported Device Performance Not explicitly defined in the document Not explicitly defined in the document Safety and Effectiveness "as safe and effective as the predicate device" P. acnes sensitivity to heat "significant sensitivity... to the effects of sustained low-level heat" -
Sample Size Used for the Test Set and Data Provenance:
- The document states that "Clinical testing was conducted," but it does not specify the sample size for the test set (number of participants, number of lesions treated, etc.).
- Data Provenance: It indicates the study was "conducted in both a controlled practitioner office environment and a consumer home-use environment." The country of origin of the data is not specified, but given the US FDA submission, it's likely primarily US-based. It was likely a prospective clinical study.
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Number of Experts Used to Establish Ground Truth and Their Qualifications:
- The document makes no mention of experts used to establish a "ground truth" for the test set. Clinical studies for acne treatment often rely on dermatologists or trained clinicians for assessment, but their number and specific qualifications are not detailed.
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Adjudication Method for the Test Set:
- The document states that the controlled clinical study design was a "randomized, double-blinded study." This implies a methodical approach to blinding participants and assessors, but it does not specify an adjudication method (e.g., 2+1, 3+1 consensus).
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Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:
- No MRMC study is mentioned. The study referenced is a clinical trial to demonstrate safety and effectiveness compared to a predicate device, but not one involving multiple human readers assessing cases with and without AI assistance. The device itself is an acne treatment device, not an AI diagnostic tool that would typically involve an MRMC study.
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Standalone Performance (Algorithm Only Without Human-in-the-Loop Performance):
- The device is a physical treatment device (a "portable hand-held device that produces accurately controlled low level sustained heat"). It is not an AI algorithm in the context of diagnostic or interpretive tasks. Therefore, the concept of "standalone performance" for an algorithm without human-in-the-loop is not applicable in the way it would be for AI software. Its performance is inherent in its use by a human.
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Type of Ground Truth Used:
- For the clinical study, the "ground truth" would likely be the clinical assessment of acne lesions by trained clinicians or dermatologists (e.g., reduction in lesion count, improvement in severity scores). However, the specific methodology for establishing this clinical ground truth (e.g., specific grading scales, independent review) is not detailed. For preclinical p. acnes sensitivity, the ground truth would be lab results (e.g., bacterial colony counts).
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Sample Size for the Training Set:
- The document describes a clinical study and preclinical testing, but it does not mention a "training set" in the context of machine learning or AI, as the Zeno device itself is not presented as an AI/ML product. The clinical and preclinical data serve as evidence for its safety and effectiveness.
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How Ground Truth for the Training Set Was Established:
- As there is no mention of a "training set" for an AI/ML model, this question is not applicable.
In summary, while the document confirms clinical and preclinical testing were conducted to support the device's safety and effectiveness compared to predicate devices, it lacks the specific quantitative details regarding acceptance criteria, study sample sizes, expert involvement, and detailed outcome measures that would fully answer your request. This level of detail is often found in the full 510(k) submission, not typically in the summary.
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