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510(k) Data Aggregation
(87 days)
The ActiTrac is a small wrist-worn activity monitor designed for documenting physical movements associated with applications in physiological monitoring. The device is intended to be used to analyze circadian rhythms, automatically collect and score data for sleep parameters. These parameters, representing the number and intensity of limb movements, are directly correlated to sleep efficiency. The unit can also be used to assess activity in any instance where quantifiable analysis of physical motion is desirable.
The ActiTrac is a compact, wrist-worn, battery-operated activity monitor whose physical characteristics are similar to a small wristwatch. The monitor consists of the activity monitor itself and a wrist band. The ActiTrac is intended for the measurement, storage, and analysis of body activity. The ActiTrac can be attached to the subject's limb and through the use of an accelerometer, motion of that limb is measured, the activity stored within the activity monitor. A computer program is used to set up the ActiTrac to collect data. This program runs on an IBM-compatible personal computer (PC). The major functions of the application software are to program the device to collect data, retrieve the data from the activity monitor, display the data, and to store the data for future reference and comparison. The ActiTrac uses a smart download cable to provide a communications link between the ActiTrac and the PC. The ActiTrac utilizes a motion sensor known as an "accelerometer" to monitor the occurrence and degree of motion. This type of sensor provides an analog signal where the amplitude and speed of motion produces a signal whose magnitude and duration depend on the amount of motion. The activity signals are amplified and digitized by the on-board circuit. This information is stored in memory on board the device as activity counts. Activity can alternatively be stored in units of milli-g.
Here's an analysis of the provided text, focusing on acceptance criteria and the study that proves the device meets them:
1. Table of Acceptance Criteria and Reported Device Performance
| Parameter | Acceptance Criteria (Implicit) | Reported Device Performance |
|---|---|---|
| Accelerometer sensitivity | <0.01 g-force (predicate) | <0.012 g-force |
| Vibration/Motion Detection | Sensitive to motion as low as 0.01g | Motion as low as 0.01 g can be measured |
| Accuracy (Device-to-Device) | "Meet output specifications at or better than ±1% as compared to our established laboratory standard." | ±1% variation from established lab standard |
| Motion Measurement Range | 0.1g to 1.0g (typical human subjects) | Smallest variation between devices in this range |
Explanation of Implicit Criteria:
The document doesn't explicitly state numerical "acceptance criteria" in the way a modern regulatory filing might. Instead, the performance is assessed primarily through substantial equivalence to a predicate device (ActiWatch) and through a specific calibration process. The acceptance criteria are largely implied by meeting or exceeding the performance characteristics of the predicate, and by demonstrating reliable measurement compared to a "gold standard."
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size for Test Set: Not explicitly mentioned for human subjects. For the technical calibration, it refers to "the device" (singular) being subjected to motion, implying testing of individual units.
- Data Provenance: The study described for "Counts vs. Motion" and "Variation between devices" appears to be prospective laboratory testing. No information is provided regarding the country of origin of the data as it's a technical performance test, not a clinical trial involving human subjects from a specific country.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Their Qualifications
- Experts: Not applicable. The "ground truth" for the technical performance tests described (sensitivity and accuracy) was established using a gold standard accelerometer and a controlled moving platform, not human experts.
4. Adjudication Method for the Test Set
- Adjudication Method: Not applicable. The "ground truth" was established objectively through instrumentation (gold standard accelerometer) and mechanical means (moving platform), not through human expert adjudication.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- MRMC Study: No. The provided text does not describe an MRMC comparative effectiveness study involving human readers. The device is a physical activity monitor, and its performance evaluation focuses on the accuracy and consistency of its physical measurements, not on human interpretation of data.
6. Standalone (Algorithm Only) Performance Study
- Standalone Study: Yes. The described performance assessment ("Counts vs. Motion" and "Variation between devices") is a standalone assessment of the device's ability to accurately measure and quantify motion. The device's output (activity counts) is directly compared to a known physical input (uniform harmonic motion and gold standard accelerometer data). There is no "human-in-the-loop" during this specific performance evaluation.
7. Type of Ground Truth Used
- Type of Ground Truth: The ground truth used for the performance evaluation is instrumentation-based and defined physical parameters. Specifically:
- For "Counts vs. Motion": A "gold standard accelerometer also placed on the moving platform" and the precisely controlled parameters of the moving platform (constant frequency of 3.968 Hz and an amplitude of 0.2 g).
- For "Variation between devices": An "established laboratory standard" used for calibration.
8. Sample Size for the Training Set
- Sample Size for Training Set: Not applicable. The ActiTrac is a hardware device with an accelerometer and internal processing logic; it does not appear to use a machine learning algorithm that requires a "training set" in the conventional sense. Its "training" or calibration is based on physical measurement against established laboratory standards.
9. How the Ground Truth for the Training Set Was Established
- Ground Truth for Training Set: Not applicable, as no machine learning training set is mentioned. The device's calibration and "training" (if loosely interpreted as initial setup or manufacturing verification) involve comparing manufactured units to "established laboratory standards" and calibrating them to meet output specifications, as described in "Variation between devices." This is a quality control/calibration process, not a machine learning training process.
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