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510(k) Data Aggregation

    K Number
    K190269
    Device Name
    PureLift
    Manufacturer
    Date Cleared
    2019-08-28

    (201 days)

    Product Code
    Regulation Number
    882.5890
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    PureLift is intended for facial stimulation and indicated for over-the-counter cosmetic use.

    Device Description

    The PureLift is a hand-held device intended to apply electrical impulses to strategic locations on the face. The PureLift probes are designed for optimal contact with the face. The device continually alternates between the positive and negative probes and allows the user to adjust the settings for personalized comfort level by pressing the up/down button. The intensity starts at (1) and continues to (10). The device measures 13.4″ L x 4.8″ W x 4.3″ D. Its outer case is injection molded of thermoplastic resin and the probes consist of chrome-plated spheres. The device, powered by a 3.7-volt battery, produces low-level current that is transmitted through the two fixed, smooth spherical probes. To turn the device on, the power button is pushed. Then LCD screen will be displayed, indicating the unit is ready for use. Users then follow the instructions for use. The two probes gently glide over the skin to deliver low-level electrical impulses to strategic locations on the face. PureLift is intended to be used with a legally marketed electroconductive media. The PureLift unit contains a power supply and rechargeable battery. The enclosure is made of medical grade biocompatible plastics and the output contacts (Probes) consist of chrome-plated spheres.

    AI/ML Overview

    The provided document is a 510(k) summary for the PureLift device, a transcutaneous electrical nerve stimulator for aesthetic purposes. However, it does not contain a study that directly proves the device meets specific acceptance criteria for its intended cosmetic use (facial stimulation for over-the-counter cosmetic use).

    Instead, the document focuses on demonstrating substantial equivalence to a predicate device (NuFace K072260 and reference device Rejuvenique K011935) by comparing technological characteristics and presenting results of various safety and performance tests. These tests are primarily designed to ensure the device is safe and functions as intended from an engineering and biocompatibility standpoint, rather than proving its cosmetic efficacy against specific clinical acceptance criteria.

    Therefore, many of the requested details, such as sample size for test sets directly assessing cosmetic efficacy, expert-established ground truth for cosmetic outcomes, MRMC studies, or standalone performance for cosmetic claims, are not present in this regulatory submission.

    Here's an attempt to answer the questions based only on the provided text, highlighting what is available and what is not:


    1. A table of acceptance criteria and the reported device performance

    The document does not explicitly state "acceptance criteria" for cosmetic efficacy experiments or performance directly related to its "facial stimulation" claim. Instead, it details various engineering and safety tests and states that the device "passed or met the requirements of all testing." The table below will reflect the tests conducted and their outcomes as reported.

    Acceptance Criteria (Stated as "Requirements")Reported Device Performance
    Biocompatibility
    - Cytotoxicity (passed)Not cytotoxic
    - Sensitization (passed)Not sensitizing
    - Irritation (passed)Not irritating
    Electrical Safety
    - Compliance with IEC 60601-1Complied
    - Compliance with IEC 60601-1-11Complied
    - Compliance with IEC 60601-2-10Complied
    Electromagnetic Compatibility (EMC)
    - Compliance with IEC 60601-1-2Complied
    Software Verification & Validation
    - Per FDA Guidance (moderate level of concern)Testing conducted and documentation provided as recommended.
    Additional Physical/Mechanical Tests
    - Oscilloscope tracingsPassed/Met requirements
    - VibrationPassed/Met requirements
    - TemperaturePassed/Met requirements
    - PushPassed/Met requirements
    - Mold StressPassed/Met requirements
    - MarkingsPassed/Met requirements
    - Mechanical StrengthPassed/Met requirements
    - DropPassed/Met requirements
    - BallPassed/Met requirements
    - AcousticPassed/Met requirements
    - Accessible PartsPassed/Met requirements

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    The document mentions various tests (biocompatibility, electrical safety, EMC, software V&V, and other physical/mechanical tests) but does not specify the sample size for these tests. For biocompatibility, it states "The subject device is considered tissue contacting for a duration of less than 24 hours," which refers to the classification of contact, not a sample size.

    The data provenance (country of origin, retrospective/prospective) is not provided. These are typically laboratory tests performed on device units.


    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 provided as the regulatory submission focuses on engineering, safety, and performance standards rather than clinical efficacy studies requiring expert evaluation of "ground truth" for cosmetic outcomes. The "ground truth" for the tests mentioned (e.g., biocompatibility or electrical safety) would be established by the testing standards themselves and laboratory measurements.


    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    This information is not provided. Adjudication methods are typically relevant for clinical studies with subjective endpoints, which are not detailed in this 510(k) summary for engineering and safety tests.


    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 and therefore no effect size for human improvement with AI assistance is reported. This device is a direct-to-consumer electrical stimulator, not an AI-powered diagnostic or interpretive tool that would involve human readers.


    6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done

    This question is not applicable as the PureLift device is a physical electromedical device for facial stimulation, not an AI algorithm. Software verification and validation were performed for the device's control software, but this is distinct from AI algorithm performance.


    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    For the reported performance data:

    • Biocompatibility: The ground truth is established by adherence to ISO 10993 standards and the results of laboratory tests (cytotoxicity, sensitization, irritation) which provide objective measures against established biological criteria.
    • Electrical safety and EMC: The ground truth is established by compliance with IEC 60601 series standards, using objective measurements against specified electrical and electromagnetic limits.
    • Software Verification and Validation: The ground truth is established by adherence to FDA guidance for software in medical devices, typically involving testing against software requirements and design specifications.
    • Other physical/mechanical tests: The ground truth is established by meeting engineering specifications and performance limits for durability, function, etc.

    For the cosmetic use indication, the document does not describe any studies that would establish a specific "ground truth" for cosmetic outcomes like facial toning or appearance improvement. The 510(k) process focuses on substantial equivalence based on technical characteristics and safety, assuming the predicate's indications are well-established.


    8. The sample size for the training set

    This information is not applicable/not provided. The device is a physical electrical stimulator, not a machine learning model that requires a training set for an algorithm.


    9. How the ground truth for the training set was established

    This question is not applicable for the reasons stated in point 8.

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    K Number
    K173483
    Manufacturer
    Date Cleared
    2018-05-30

    (198 days)

    Product Code
    Regulation Number
    870.5225
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Pure Flow External Counter-Pulsation device is intended for the treatment of chronic stable angina that is refractory to optimal anti-anginal medical therapy and without options for revascularization. In addition, it is intended for use in healthy patients to provide improvement in vasodilation, increased blood flow. It is intended for use under the oversight of a healthcare professional.

    Device Description

    The Pure Flow External Counter-Pulsa-tion device is a mechanical device used to increase aortic pressure during early native heart diastole to augment myocardial perfusion, and to decrease aortic pressure during early native heart systole to reduce ventricular workload and vascular afterload.

    The PureFlow consists of a main unit, and applied parts (computer monitor, keyboard, flexible tubes which connect to fabric cuffs, inside each cuff is an inflatable plastic balloon), EKG wires, and SpO2 sensors.

    PureFlow works on the basis of external counter pulsation. The pressure is created by inflating a series of cuffs (similar to blood-pressure cuffs) that squeeze the extremities (calf's, thighs, buttocks) forcing blood back up to the heart on each heart cycle. This process ultimately restores (by force) sufficient blood flow to parts of the heart that is lacking oxygen. The treatment process generally spans for a period of 1 hour each day for a period of 35 total treatments. ECP Treatment is proven to develop existing pathways of oxygenated blood back to the heart muscle. In other words, External Counterpulsation Therapy restores pathways for adequate & necessary blood flow back to heart through vessels that already exist.

    The device also utilizes the following cleared components: Cable/Lead wire (ECG/EKG, SpO2, and Invasive Blood Pressure): K120010 LNCS/M-LNCS Oximetry Sensor: K101896

    AI/ML Overview

    This document, a 510(k) Summary for the Pure Flow External Counter-Pulsation Device (K173483), describes non-clinical testing performed to demonstrate substantial equivalence to a predicate device, not a study designed to prove the device meets acceptance criteria for a new clinical application or algorithm performance. Therefore, many of the requested categories are not applicable.

    Here's an analysis of the provided text in relation to your request:

    1. A table of acceptance criteria and the reported device performance

    TestAcceptance CriteriaReported Device Performance
    Pressure Control Timing Measurement TestTimer accuracy within +/- 5% of the set value (per JIS T0601-2-204)Three models tested, each met the pass criteria.
    Pressure Accuracy TestPressure within +/- 20% from the set pressure value (per JIS T 0601-2-204)Three models tested, each met the pass criteria.
    Electrical safety and electromagnetic compatibility (EMC)Compliance with IEC 60601-1 and 60601-1-2Found to comply with IEC 60601-1 and 60601-1-2.
    Shelf-Life TestingNot explicitly stated as a pass/fail criterion, but a calculated shelf-life.Shelf-life calculated to be three years.

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    • Sample Size (Test Set): For the Pressure Control Timing Measurement Test and Pressure Accuracy Test, "Three models were tested."
    • Data Provenance: Not specified, but the tests are non-clinical, likely internal laboratory testing. Country of origin not mentioned. The tests are prospective in the sense that they were designed to evaluate the physical device's performance.

    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. This document describes non-clinical performance testing of a physical device, not an AI/algorithm-based diagnostic or prognostic tool that would require expert-established ground truth. The "ground truth" for these tests refers to the expected physical performance of the device as measured by calibrated equipment against established engineering standards.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    • Not applicable. See 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

    • Not applicable. This relates to an external counter-pulsation device, not an AI diagnostic/imaging system. No human reader studies are mentioned.

    6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done

    • Not applicable. This is a hardware medical device with some software control, not a standalone algorithm. Software verification and validation were done, but this refers to the robust operation of the device's control software, not a standalone algorithmic output.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    • Non-clinical-specific ground truth: For the Pressure Control Timing Measurement Test and Pressure Accuracy Test, the "ground truth" was established by reference standards (JIS T0601-2-204), which define acceptable ranges for device performance. These are engineering standards, not medical ground truths like pathology or expert consensus.

    8. The sample size for the training set

    • Not applicable. This document describes the testing of a physical device, and therefore does not involve a "training set" in the context of machine learning or AI models.

    9. How the ground truth for the training set was established

    • Not applicable. See point 8.
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