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510(k) Data Aggregation
(153 days)
The Magstim Company Limited
Rapid2 Magnetic Stimulators (Magstim Rapid2, Magstim Super Rapid2, Magstim Super Rapid2 Plus1) are intended to stimulate peripheral nerves for relief of chronic intractable, post-traumatic and post-surgical pain for patients 18 years or older.
The Magstim Rapid2, Magstim Super Rapid2, Magstim Super Rapid2 Plus1 (herein collectively referred to as "Rapid2 Magnetic Stimulators") are computerized, electromechanical medical devices that provide brief and focused magnetic pulses in order to non-invasively stimulate peripheral nerves for relief of chronic intractable, post-traumatic and post-surgical pain for patients 18 years or older. The subject device is intended to be used in hospitals and clinics such as pain management clinics.
Rapid2 Magnetic Stimulators are integrated systems consisting of a combination of hardware, software, and accessories. Rapid2 Magnetic Stimulators are offered in multiple configurations:
- Rapid2
- Super Rapid2
- Super Rapid2 Plus1
All three configurations have identical intended use/indications for use, common specifications, equivalent performance characteristics and equivalent composition to each other. Specifically, Rapid2 and Super Rapid2 have received prior clearance under K051864 for Peripheral Nerve Stimulation (Product Code: GWF, Regulation 21 CFR 882.1870). All Rapid2 Magnetic Stimulators are made up of components that have received prior clearance under K051864 (e.g., the 3190-00, 3192-00 and 3193-00 coils) and components which have received prior clearance under K051864 but have received modifications due to aspects like obsolescence (Mainframe, Power Supply etc.).
All Rapid2 Magnetic Stimulators are composed from the following main components:
- Stimulating Unit & Power Supply
- User Interface
- Stimulating Coil
- System and Stimulating Coil Cart and Holding Arm
Rapid2 Magnetic Stimulators include temperature monitoring via two independent temperature sensors to ensure surfaces of the coils do not reach unacceptable levels. The cut-off is set to act at 40°C at which point the system will automatically be disabled. Over-temperature conditions are also communicated on the User Interface (UI) via a temperature gauge and alarm system. Rapid2 Magnetic Stimulators also includes the 3910-00 air-cooled coil to further mitigate any temperature conditions. The 3910-00 air-cooled coil comes with all 3 configurations (Rapid2, Super Rapid2 and Super Rapid2 Plus1) as standard.
The provided document is an FDA 510(k) Clearance Letter for the Rapid2 Magnetic Stimulators. It does NOT contain information about a study proving the device meets acceptance criteria related to its performance in pain relief. Instead, it focuses on demonstrating substantial equivalence to a predicate device through non-clinical testing of technical characteristics, safety standards compliance, and physical properties.
The document does not describe an AI/ML-driven device, nor does it present results from a clinical study with patients or human readers using AI. The acceptance criteria and performance metrics described are related to physical and electrical characteristics of the magnetic stimulator, not diagnostic accuracy or clinical effectiveness in a traditional sense of "performance" as one might expect for an AI diagnostic device.
Therefore, many of the requested items (e.g., sample size for test/training sets, data provenance, number of experts for ground truth, MRMC study, standalone performance, ground truth type) cannot be answered based on the provided text, as they pertain to clinical or AI/ML performance evaluation, which is not the subject of this 510(k) summary.
However, I can extract information related to the technical acceptance criteria and how they align with the device's measured performance as described in the summary:
Acceptance Criteria and Device Performance (Based on Technical and Safety Equivalence)
The acceptance criteria for the Rapid2 Magnetic Stimulators are primarily based on demonstrating substantial equivalence to the predicate device (MagVenture Pain Therapy) in terms of technical characteristics, safety, and effectiveness for the stated indications for use. The "performance" reported is adherence to these characteristics and safety standards.
Acceptance Criteria Category/Characteristic | Subject Device Performance (Rapid2 Magnetic Stimulators) | Predicate Device Performance (MagVenture Pain Therapy) | Evaluation / Proof of Meeting Criteria |
---|---|---|---|
Indications for Use | Stimulate peripheral nerves for relief of chronic intractable, post-traumatic and post-surgical pain for patients 18 years or older. | Stimulate peripheral nerves for relief of chronic intractable, post-traumatic and post-surgical pain for patients 18 years or older. | Identical. Meets criteria by having the same intended use. |
Anatomical Sites | Any area, such as hand, arm, waist, buttock, thigh, calf, back and lower back etc. | Any area, such as hand, arm, waist, buttock, thigh, calf, back and lower back etc. | Identical. |
Treatment Facilities | Hospitals & Clinics | Hospitals & Clinics | Identical. |
Treatment Time | 13 minutes per session (800 seconds) | 13 minutes per session (800 seconds) | Identical. |
Pulse Frequency | Rapid2: 0.1 – 50 Hz (pps); Super Rapid2 and Super Rapid2 Plus1: 0.1 – 100 Hz (pps) | MagPro R30 & MagPro R30 with MagOption: 0.1 – 30 Hz (pps); MagPro X100 & MagPro X100 with MagOption: 0.1 – 100 Hz (pps) | Similar range. Subject device's range covers or extends slightly beyond predicate, but the recommended protocol (0.5Hz) is well within both. |
Pulse Amplitude | 0 – 100% | 0 – 100% | Identical. |
On-cycle duty period | 2-800 Seconds (0.5 Hz and up to 400 pulses) | 2-800 Seconds (0.5 Hz and up to 400 pulses) | Identical. |
Off-cycle rest period | N/A | N/A | Identical. |
Maximum Repetition Rate | Rapid2: 50Hz; Super Rapid2: 100Hz; Super Rapid2 Plus1: 100Hz | MagPro R30 & MagPro R30 with MagOption: 30 pulses per second; MagPro X100 & MagPro X100 with MagOption: 100 pulses per second | Upper limit identical compared to predicate. Substantial equivalence demonstrated despite differences in how maximum output is achieved (explained in "SE Note 1"). |
Pulse Width | Biphasic (300-425 µs) | Biphasic (280-320 µs) | Similar range. Differences deemed not to raise new safety/effectiveness questions due to compensating factors (see "SE Note 2"). |
Pulse Mode | Standard | Standard | Same. |
Temperature Control | Automatic disable at 40°C; includes air-cooled coil; UI communication of over-temperature. | Automatic disable at 43°C. | Comparable/Better. Subject device has a lower cutoff and additional cooling/reporting features. |
Peak Magnetic Field at Coil Surface | 1.0-1.5T | 1.15-2.6T | Substantially equivalent. Subject device is a subset of the predicate's range. Differences explained in "SE Note 2" as not raising new safety/effectiveness concerns. |
Peak Magnetic Field Gradient (dB/dt) at 20mm from Coil Center | 9-12kT/s | 9-24kT/s | Substantially equivalent. Subject device is a subset of the predicate's range. Differences explained in "SE Note 2" as not raising new safety/effectiveness concerns. |
Waveform | Biphasic, Biphasic Burst | Biphasic, Monophasic, Biphasic Burst, Halfsine (combinations vary by predicate configuration) | Substantially equivalent. Subject device's waveform is within the range available in the predicate. |
Software/Firmware Control | Yes | Yes | Identical. Verified per IEC 62304. |
Power Supply Type | Power Supply via dedicated power supply modules each using a separate input mains line cord. | Power Supply via Isolation Transformer. | Similar. |
Power Consumption | 230/240V Systems – 3000VA peak per input; 115V Systems – 2300VA peak per input | Maximum 2700VA | Similar. |
User Interface | LCD Capacitive Touchscreen | LED Display | Similar. A difference in display technology, but performs the same function. |
Housing Material Construction | Stimulator: PUR, Stainless/Galvanized Steel; Coils: PC, PUR | Stimulator: Aluminum, Aluzinc; Coils: PVC, ABS, PA, POM | Similar. Different specific materials but serve the same function. |
Applied Parts (Coils) | Various, including previously cleared (K051864, K080499, K130403) and new coils (4150-00, 4170-00, 4189-00, 4190-00, 4510-00). | Various, all previously cleared. | Substantially equivalent coil range. New coils are evaluated for safety and function to be equivalent (see "SE Note 2"). |
Applied Part Area | Butterfly Coils: 152mm – 191mm; Circular Coils: 124.5mm | Butterfly Coils: 150mm; Circular Coils: 110-126mm; Special Coils: 160x80 mm | Substantially equivalent. (see "SE Note 2"). |
Sterilization | Non-sterile when used. | Non-sterile when used. | Identical. |
Electrical Safety | Complies with IEC 60601-1 Ed. 3.2 | Complies with IEC 60601-1 Ed. 3.1 | Meets/Exceeds. Complies with a newer edition of the standard. |
Mechanical Safety | Complies with IEC 60601-1 Ed. 3.2 | Complies with IEC 60601-1 Ed. 3.1 | Meets/Exceeds. Complies with a newer edition of the standard. |
Thermal Safety | Complies with IEC 60601-1 Ed. 3.2 | Complies with IEC 60601-1 Ed. 3.1 | Meets/Exceeds. Complies with a newer edition of the standard. |
Radiation Safety | No radiation generated. | No radiation generated. | Same. |
Biocompatibility | Complies with ISO 10993-1, -5, -10; materials tested for Skin Irritation, Cytotoxicity, Skin Sensitization. | Complies with ISO 10993. | Same/Exceeds. Detailed compliance with relevant parts of the standard. |
Standards Compliance | ISO 13485 (company); IEC 60601-1-2, IEC 60601-1-6, IEC 60601-1-8, IEC 62366-1 (device). | EN ISO 13485 (company). | Same/Equivalent. Device-specific standards compliance indicated. |
Acoustics | Tested per 60601-1 type testing and in-house, demonstrating substantially equivalent acoustic output. Labeling requires earplugs (30dB noise reduction). | (Not specified beyond "similar") | Comparable. Demonstrated and mitigated with user instructions. |
E-Field Decay & Linearity of Output | Performance data showed "very similar" E-Field decay, linearity, and electric/magnetic field spatial distributions. | (Not explicitly detailed, but implied to be baseline for comparison) | Comparable. Results demonstrate equivalent effects at 0-2cm from coil surface. |
Regarding the specific questions that cannot be answered from the provided text:
- Sample sizes used for the test set and the data provenance: Not applicable or provided. The "test set" here refers to non-clinical testing of device characteristics, not a clinical study on patients or data.
- Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable or provided. Ground truth in this context would implicitly be engineering specifications, laboratory measurements, and standard compliance testing, not expert clinical assessment of patient data.
- Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable or provided. No adjudication process detailed for establishing technical specifications.
- 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 not an AI/ML device, nor is it a diagnostic device being evaluated for reader performance.
- If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable. Not an AI/ML algorithm.
- The type of ground truth used (expert consensus, pathology, outcomes data, etc.): The "ground truth" for this device's performance evaluation is based on engineering specifications, direct physical measurements (e.g., of magnetic fields, temperatures, electrical properties), and compliance with international safety and performance standards (e.g., IEC 60601 series, ISO 10993).
- The sample size for the training set: Not applicable or provided. This device does not use a "training set" in the machine learning sense.
- How the ground truth for the training set was established: Not applicable or provided.
In summary, the provided document details the 510(k) clearance process for a non-AI/ML magnetic stimulator for pain relief. The "acceptance criteria" and "performance" are framed around demonstrating substantial technical and safety equivalence to a legally marketed predicate device, rather than clinical efficacy data from patient studies or AI algorithm performance metrics.
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(90 days)
The Magstim Company Limited
For Adults: Horizon 3.0 TMS Therapy Systems are indicated for the treatment of Major Depressive Disorder (MDD) in adult patients who have failed to achieve satisfactory improvement from prior antidepressant medication in the current episode, as well as an adjunct for the treatment of adult patients suffering from Obsessive-Compulsive Disorder (OCD).
For Adolescents: Horizon 3.0 TMS Therapy Systems are indicated as an adjunct for the treatment of MDD in adolescent patients (age 15-21).
The Horizon® 3.0 TMS Therapy System is a computerized, electromechanical medical device that produces and delivers non-invasive, magnetic stimulation rapidly alternating, or pulsed, magnetic fields to induce electrical currents directed at spatially discrete regions of the cerebral cortex. This method of cortical stimulation by application of brief magnetic pulses to the head is known as Transcranial Magnetic Stimulation. ("TMS").
The Horizon® 3.0 TMS Therapy System is a non-invasive tool for the stimulation of cortical neurons for the treatment of
- Major Depressive Disorder in adult patients who have failed to achieve satisfactory improvement from prior antidepressant medication in the current episode
- as an adjunct for the treatment of adult patients suffering from Obsessive-Compulsive Disorder (OCD).
- as an adjunct for the treatment of Major Depressive Disorder in adolescent patients (age 15--21)
The Horizon® 3.0 TMS Therapy System is used for patient treatment by prescription only under the supervision of a licensed physician. It can be used in both inpatient settings, including physicians' offices, clinics, and hospitals.
The Horizon® 3.0 TMS Therapy System configurations are an integrated system consisting of a combination of hardware, software, and accessories.
The Horizon® 3.0 TMS Therapy System is offered in three configurations:
- Horizon 3.0 Inspire (Cleared under K241518). -
- Horizon 3.0 (Cleared under K232235, K223154, K222171 and K211389), -
- Horizon 3.0 with StimGuide Pro (Cleared under K232235).
The three tiers of system offer equivalent safety and effectiveness with the main purpose allowing for physician offices, clinics and hospitals to choose a configuration that suits the organizational needs and provide different entry levels to promote the accessibility of TMS Therapy Treatments to health delivery organizations.
All three configurations have identical intended use/indications for use, common specifications, equivalent performance and equivalent composition. All three devices share equivalent technological characteristics and principles of operation.
All configurations are composed from the following main components:
- Stimulating Unit & Power Supply -
- User Interface
- Applicating Coil for Motor Threshold -
- -Applicating Coil for Treatment Delivery
- -System and Applicating Coil Cart and Holding Arm
The Horizon 3.0 with StimGuide Pro specifically includes a stereotactic infrared tracking system for aiding coil positioning.
Below is a summary of the acceptance criteria and the study that proves the device meets the criteria.
1. Table of Acceptance Criteria and Reported Device Performance
Test Category | Acceptance Criteria (Implied) | Reported Device Performance |
---|---|---|
Electromagnetic Compatibility (EMC) | Compliance with IEC 60601-1-2. Demonstrated equivalent EMC level to the primary predicate device. | The Horizon 3.0 TMS Therapy System was tested and found compliant with IEC 60601-1-2, demonstrating an equivalent level of EMC as the primary predicate device. |
Electrical & Mechanical Safety | Compliance with IEC 60601-1 (including IEC 60601-1-6 and IEC 60601-1-8). Demonstrated equivalent electrical and mechanical safety level to the primary predicate device. | The Horizon 3.0 TMS Therapy System was tested and found compliant with IEC 60601-1 standards, demonstrating an equivalent level of electrical and mechanical safety as the primary predicate device. |
Thermal Safety | Compliance with IEC 60601-1 (including IEC 60601-1-6 and IEC 60601-1-8). Ability of Horizon Air Film Coil and Horizon 3.0 Ez Cool Coil to execute OCD, iTBS, and rTMS protocols at worst-case ambient conditions without excessive temperatures. | The system was compliant with IEC 60601-1. Additional testing confirmed the Horizon Air Film Coil and Horizon 3.0 Ez Cool Coil could perform protocols safely and effectively, even at worst-case ambient conditions (80%-100% output, 30°C), comparable to the predicate. |
Software Verification & Validation | Appropriate function of software, demonstrating it cannot contribute to any unacceptable risk (following IEC 62304 and FDA Software Guidance). Software behavior is consistent and compatible across all configurations and fulfills its intended use, with cybersecurity tested to ensure security equivalent to the primary predicate. | Software development followed IEC 62304. Lifecycle documentation demonstrated appropriate function and no unacceptable risk. Software behavior was consistent, compatible, and passed cybersecurity testing, ensuring security equivalent to the primary predicate. |
Usability/Human Factors Engineering | Appropriate human factors and usability for intended use, free from unacceptable use-related risks (following IEC 60601-1-6, IEC 62366-1, ANSI/AAMI HE75). Consistency of workflows, UIs, and components promoting a healthy usability profile. | Human factors evaluation demonstrated appropriate usability and freedom from unacceptable use-related risks. Consistency across configurations promotes a healthy usability profile. |
Magnetic Pulse Output & Field Testing | Equivalence of electric field distribution, power outputs, magnetic fields, field spatial distribution, E-field decay, output waveforms, magnetic field strength, and rate of change between subject coils (Ez Cool Coil, Air Film Coil) and predicate coil (Neuronetics Coil) at clinically relevant depths (2-3cm). Compliance with Special Controls: 21 C.F.R. § 882.5802, 21 C.F.R. § 882.5805, and FDA Guidance "Repetitive Transcranial Magnetic Stimulation (rTMS) Systems." | Measurements in a phantom head model showed equivalent power outputs, electric and magnetic fields, and key field characteristics between the subject and predicate coils at clinically relevant depths (2-3cm). |
Safety Feature Testing | Maintenance of appropriate safety features, exercising many fault scenarios, and ensuring interlocks with respect to safety features (following IEC 60601-1). Testing includes introducing failure modes to test multiple fault conditions (e.g., disabling software check and ensuring hardware backup interlock is active). | All fault scenarios and safety features were tested and complied with IEC 60601-1, demonstrating substantial equivalence of safety features among all device configurations. |
Acoustic Testing | System does not reach excessive/unacceptable noise levels under simulated use scenarios with Horizon Air Film Coil and Horizon 3.0 Ez Cool Coil (following IEC 60601-1). | Acoustic testing under simulated use scenarios (maximum machine output for recommended protocols) demonstrated the system with the specified coils does not reach excessive/unacceptable noise levels. |
2. Sample Size Used for the Test Set and Data Provenance
The summary details a series of non-clinical tests. These tests primarily involve physical measurements and simulations, rather than collecting data from human subjects.
- Sample Size for Test Set: Not applicable in the traditional sense of human subjects. For the magnetic and electrical field testing, the "test set" was the physical setup involving a phantom head model and specific coils. No numerical sample size for patients is provided.
- Data Provenance: The data comes from in-house engineering and laboratory testing performed by The Magstim Company Limited, in accordance with international standards. This is not retrospective or prospective clinical data from human patients, but rather performance data generated from the device itself and its components. The country of origin for the testing is implicitly the United Kingdom, where the applicant is located.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Their Qualifications
Given the nature of the non-clinical tests described, the concept of "experts establishing ground truth" for a test set in a human clinical context is not directly applicable.
- Magnetic and Electrical Field Testing: This testing involved physical measurements using a phantom head model and measuring probes. The "ground truth" here is the physical output of the device under controlled conditions, measured against established scientific principles and comparison to a legally marketed predicate device. The expertise involved would be in engineering, physics, and medical device testing, ensuring the test setup, execution, and interpretation of results are scientifically sound and comply with regulatory guidance.
- Other Non-Clinical Tests: For areas like Electrical, Mechanical, Thermal Safety, EMC, Software V&V, Usability, Safety Features, and Acoustic Testing, compliance is determined by adherence to specific international standards (e.g., IEC 60601 series, IEC 62304, ISO 10993, AAMI/ANSI HE75) and FDA guidance documents. The "ground truth" is defined by these standards and the expertise lies with the engineers and quality assurance personnel who conduct these tests and verify compliance.
No specific number or qualifications of "experts" are provided in the summary, as this is typically inherent in the regulatory-compliant testing process conducted by the manufacturer.
4. Adjudication Method for the Test Set
Not applicable. Adjudication methods like 2+1 or 3+1 are typically used in clinical studies involving interpretation of medical images or patient outcomes, where ambiguous cases require expert consensus. The tests described here are non-clinical, objective measurements and compliance checks against established standards.
5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study Was Done
No, an MRMC comparative effectiveness study was not done. The summary explicitly states: "Clinical Testing - Not Applicable." The submission relies solely on non-clinical testing to demonstrate substantial equivalence.
6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done
This question is not entirely applicable as the device in question (Horizon 3.0 TMS Therapy System) is a hardware-based medical device that delivers magnetic stimulation. While it contains software, it is not an AI algorithm that generates diagnostic outputs or interpretations that would typically have a "standalone" performance metric in the absence of human input or a human-in-the-loop. The software functions to control the hardware and deliver therapy protocols, and its performance is validated as part of the overall device system.
7. The Type of Ground Truth Used
The ground truth used for these non-clinical tests is primarily based on:
- Compliance with International Standards: The device's performance is measured against established safety, EMC, thermal, electrical, mechanical, and software standards (e.g., IEC 60601 series, IEC 62304).
- Scientific Principles and Physical Measurements: For magnetic and electrical field testing, the ground truth is derived from quantitative physical measurements conducted in a controlled phantom head model according to scientific principles.
- Comparison to a Legally Marketed Predicate Device: Substantial equivalence is established by demonstrating that the subject device's performance characteristics (e.g., magnetic field output, treatment protocols) are equivalent to those of the predicate device (NeuroStar Advanced Therapy System) and previously cleared Magstim devices.
There is no pathology, expert consensus (in a diagnostic sense), or outcomes data from human patients used as ground truth in this submission, as it focuses on non-clinical performance.
8. The Sample Size for the Training Set
Not applicable. This device is a medical device for therapy, not a machine learning model that requires a distinct "training set" of data in the AI sense. The software embedded in the device is developed and validated through traditional software engineering practices (IEC 62304), not through machine learning training on a dataset.
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there is no machine learning "training set" for this device. The software development and validation followed established engineering principles and regulatory standards (IEC 62304), which ensure the software functions as intended and meets safety requirements.
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(93 days)
The Magstim Company Limited
Horizon® 3.0 TMS Therapy System is indicated for the treatment of Major Depressive Disorder in adult patients who have failed to achieve satisfactory improvement from prior antidepressant medication in the current episode, as well as an adjunct for the treatment of adult patients suffering from Obsessive-Compulsive Disorder (OCD).
The Horizon® 3.0 TMS Therapy System is a computerized, electromechanical medical device that produces and delivers non-invasive, magnetic stimulation using brief duration rapidly alternating, or pulsed, magnetic fields to induce electrical currents directed at spatially discrete regions of the cerebral cortex. This method of cortical stimulation by application of brief magnetic pulses to the head is known as Transcranial Magnetic Stimulation. ("TMS").
The Horizon® 3.0 TMS Therapy System is a non-invasive tool for the stimulation of cortical neurons for the treatment of Major Depressive Disorder in adult patients who have failed to achieve satisfactory improvement from prior antidepressant medication in the current episode, as well as an adjunct for the treatment of adult patients suffering from Obsessive-Compulsive Disorder (OCD).
The Horizon® 3.0 TMS Therapy System is used for patient treatment by prescription only under the supervision of a licensed physician. It can be used in both inpatient and outpatient settings, including physicians' offices, clinics, and hospitals.
The Horizon® 3.0 TMS Therapy System configurations are an integrated system consisting of a combination of hardware, software, and configurations:
- Horizon 3.0 Inspire (Subject of this submission).
- Horizon 3.0 (Previously cleared under K232235, K223154, K222171 and K211389).
- Horizon 3.0 with StimGuide Pro (Cleared under K232235).
All three configurations, including the subject Horizon 3.0 Inspire configuration, have identical intended use/indications for use, common specifications, equivalent performance and equivalent composition. All three devices share equivalent technological characteristics and principles of operation.
All configurations are composed from the following main components:
- Stimulating Unit & Power Supply
- User Interface
- Applicating Coil for Motor Threshold
- Applicating Coil for Treatment Delivery
- System and Applicating Coil Cart and Holding Arm
The Horizon 3.0 with StimGuide Pro specifically includes a stereotactic infrared tracking system for aiding coil positioning.
The provided text is a 510(k) summary for the Horizon 3.0 TMS Therapy System, specifically introducing the "Horizon 3.0 Inspire" configuration. This document primarily focuses on demonstrating substantial equivalence to a legally marketed predicate device (K232235, Horizon 3.0 TMS Therapy System) rather than presenting a standalone study with defined acceptance criteria and performance metrics against a specific clinical outcome.
Therefore, the requested information, particularly regarding acceptance criteria for clinical performance, sample sizes for test sets where ground truth was established by experts, and effect sizes for MRMC studies, is not present in this document. The document describes non-clinical testing to demonstrate that the new configuration is as safe and effective as the predicate device.
Here's a breakdown of the available information based on your request:
1. Table of Acceptance Criteria and Reported Device Performance:
The document describes compliance with various safety and performance standards, but does not present a table of acceptance criteria with corresponding performance results in a way that would typically be seen for a new clinical efficacy study. Instead, it refers to demonstrating equivalence to a predicate device through non-clinical testing.
Acceptance Criteria Category | Description of Compliance/Performance |
---|---|
Electromagnetic Compatibility (EMC) | Compliant "to the requirements of IEC 60601-1-2 to demonstrate an equivalent level of Electromagnetic Compatibility as the primary predicate device." Test plan utilized the same performance criteria as the primary predicate. |
Electrical & Mechanical Safety | Compliant "to the requirements of IEC 60601-1 (including IEC 60601-1-8) to demonstrate an equivalent level of Electrical and Mechanical safety as the primary predicate device." |
Thermal Safety | Compliant "to the requirements of IEC 60601-1 (including IEC 60601-1-6 and IEC 60601-1-8) to demonstrate an equivalent level of Thermal safety as the primary predicate device." Additional testing ensured the Horizon Air Film Coil could execute OCD, iTBS, and rTMS protocols at worst-case ambient conditions without excessive temperatures. The system can perform recommended protocols safely and effectively under worst-case simulated ambient conditions (80%-100% machine output, 30°C ambient). |
Software Verification & Validation | Software developed following IEC 62304. Documentation demonstrates appropriate function and that software cannot contribute to unacceptable risk. Changes for "Inspire" configuration verified for correctness and no negative impact on predicate configurations. Cybersecurity testing performed to ensure "Inspire" configuration is as secure as the primary predicate. |
Usability/Human Factors Engineering | Evaluation demonstrates appropriate human factors and usability for intended use, free from unacceptable use-related risks (IEC 60601-1-6, IEC 62366-1, ANSI/AAMI HE75). Consistency of workflows, UIs, and components from predicate contribute to a healthy usability profile. |
Magnetic Pulse Output Testing and Magnetic & Electrical Field Testing | Electric field distribution measured in a human head phantom filled with physiologic saline solution. Values of Magnetic and Electric field obtained by measuring induced voltage. Results demonstrated "equivalent Power Outputs, Electric Fields between the subject device configuration applicating coil and the primary predicate device configuration applicating coil." Key characteristics (stimulator output, field spatial distribution, E-Field decay, output waveforms, rate of change) were equivalent, especially at clinically relevant depths. |
Safety Feature Testing | IEC 60601-1 testing of fault scenarios to ensure appropriate safety features. System-level testing (software verification) exercised various interlocks. Testing introduced failure modes to confirm hardware backup interlocks. Demonstrates substantial equivalence of safety features. |
Acoustic Testing | In simulated use scenarios (OCD Protocol at maximum machine output), the Horizon 3.0 "Inspire" configuration demonstrated equivalent acoustic properties to the predicate and fell below safe exposure limits. |
2. Sample size used for the test set and the data provenance:
- Test Set: No patient-specific test set for clinical performance is mentioned. The testing described is non-clinical/bench testing.
- Data Provenance: The data provenance is from laboratory testing performed by the manufacturer, comparing the new configuration's performance to the primary predicate device and relevant standards. This is retrospective in the sense that it relies on existing standards and predicate device data, but the tests themselves were conducted on the new device configuration.
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 information is not applicable as the document describes non-clinical testing against engineering standards and comparison to a predicate device, not a human reader study where experts establish ground truth for a clinical dataset.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
This information is not applicable for the same reasons as point 3.
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 MRMC comparative effectiveness study was done or described. This is a device for Transcranial Magnetic Stimulation, not typically an imaging AI device that aids human readers in interpretation.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
The device itself is a standalone medical device for delivering TMS therapy. The described testing is of the device's technical specifications and safety profile, not of an "algorithm only" in the context of an AI diagnostic. The software components were verified and validated as part of the overall device system.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc):
For the non-clinical tests described, the "ground truth" (or reference) used were:
- International standards: (e.g., IEC 60601-1, IEC 60601-1-2, IEC 60601-1-8, IEC 62366-1, ANSI/AAMI HE75, ISO 10993-1, ISO 10993-10, ISO 14971, IEC 62304, AAMI TRS7, AAMI TIR97).
- Performance of the legally marketed predicate device (K232235): The goal was to demonstrate "equivalent" safety and effectiveness.
- Phantom head model: For Magnetic and Electrical Field Testing, a human head phantom model filled with physiologic saline solution was used to measure induced voltage.
8. The sample size for the training set:
This information is not applicable. This document does not describe the development or training of a machine learning algorithm; it describes a hardware and software system for TMS therapy.
9. How the ground truth for the training set was established:
This information is not applicable for the same reason as point 8.
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