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510(k) Data Aggregation

    K Number
    K214090
    Device Name
    Back 3 COLOR
    Manufacturer
    Date Cleared
    2022-11-01

    (308 days)

    Product Code
    Regulation Number
    878.4400
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The BACK3 COLOR device is intended to provide topical heating for the purpose of elevating tissue temperature for the treatment of selected medical conditions such as relief of pain, muscle spasms, and increase in local circulation. The BACK3 COLOR massage device is intended to provide a temporary reduction in the appearance of cellulite.

    Device Description

    The BACK3 COLOR generates high frequency sinusoidal current with a monopolar mode of application using two electrodes. A fixed electrode is placed in contact with the patient and a handheld electrode is manipulated by a therapist. When both electrodes are in contact with a patient the electrical circuit is closed and RF therapy can be provided. The device can be operated in a capacitor resistive monopolar mode and a multipolar mode.

    The product consists of a power console on a moveable trolley, LCD monitor, and accessories including capacitive resistive electrodes and multipolar electrodes. The unit can be adjusted to provide various levels of treatment frequency ranging from 300kHz to 1MHz.

    AI/ML Overview

    The provided text describes the BACK3 COLOR device, which is an electrosurgical cutting and coagulation device. The 510(k) summary focuses on establishing substantial equivalence to a predicate device (Winback Back 3SE, K162828) rather than presenting specific performance criteria and a study to prove meeting those criteria in the traditional sense of a clinical trial for diagnostic devices.

    Instead, the acceptance criteria and study detailed here are focused on demonstrating that the new device (BACK3 COLOR) functions safely and effectively, and is technologically equivalent to the previously cleared predicate device, without introducing new questions of safety or effectiveness.

    Here's a breakdown of the information requested, based on the provided text:

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

    Since this is a substantial equivalence submission, the "acceptance criteria" are generally that the new device performs equivalently to the predicate device in terms of safety and technical specifications. The "reported device performance" is essentially the confirmation that these specifications are met for the new device.

    Acceptance Criteria (Equivalence to Predicate)Reported Device Performance (BACK3 COLOR)
    Regulation and Product Classification Code: 21 CFR 878.4400, PBXMeets (Identical)
    Indications for Use: Provides topical heating for pain relief, muscle spasms, increased local circulation, and temporary reduction in cellulite.Meets (Identical)
    Massaging Handpiece: YesMeets (Identical)
    Electrode Shapes: Square and circularMeets (Identical)
    Infrared Light: NoMeets (Identical)
    Vacuum (suction): NoMeets (Identical)
    Treatment Activation: Finger selection on consoleMeets (Identical)
    RF Type: Multipolar/UnipolarMeets (Identical)
    RF Frequency: 300kHz – 1MHzMeets (Identical)
    Max RF Power: 300WMeets (Identical)
    Intensity Adjustment: 0-100%Meets (Identical)
    Configuration: Cart mounted console with accessoriesMeets (Identical)
    Patient Safety Switch: YesMeets (Identical)
    Electrical Safety: Compliance with IEC 60601-1Satisfactory results reported
    Electromagnetic Compatibility: Compliance with IEC 60601-1-2Satisfactory results reported
    Biocompatibility: Tissue contacting probes tested for cytotoxicity, sensitization, intracutaneous reactivitySatisfactory results reported
    Software Assessment: Compliance with FDA software validation guidelines (Levels of Concern, User & System Requirements, Hazard Analysis, Software Requirements, Architectural Design, Software Validation & Testing)Satisfactory results reported
    Usability and Risk Management: Verification of user interface, safety features, and satisfactory performance using worse-case assumptionsSatisfactory results reported
    Ability to maintain therapeutic temperature on human skin surface: Demonstrated for all applicators, operation modes, and power settingsStudy conducted with satisfactory results

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

    • Sample Size: The "Human being testing" for tissue temperature elevation involved three different people.
    • Data Provenance: The document does not specify the country of origin or whether the study was retrospective or prospective. Given it's a testing requirement for the device's performance, it is highly likely to be a prospective study.

    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 type of information is not typically applicable or detailed in a substantial equivalence filing for an electrosurgical device like this. The specific "Human being testing" described focused on physical measurements (temperature) directly from the device's application, rather than subjective interpretation by experts to establish a "ground truth" for a diagnostic outcome. Therefore, no experts for "ground truth" establishment in this sense are mentioned.

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

    Not applicable. The human being testing involved direct measurement of physical parameters (skin and room temperature) rather than subjective assessments that would require adjudication.

    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 device is an electrosurgical and radiofrequency therapy device, not a diagnostic imaging device with AI assistance for human readers. No MRMC study was mentioned or required.

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

    Not applicable. This device delivers energy therapy; it is not an algorithm-based diagnostic tool. The "Software Assessment" done was for the device's operational software, not for a standalone diagnostic algorithm.

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

    For the "Human being testing," the "ground truth" was the direct measurement of skin and room temperatures to demonstrate the device's ability to maintain a therapeutic temperature. This is a direct physical measurement, not a clinical ground truth like pathology or expert consensus.

    8. The sample size for the training set

    Not applicable. This document describes a medical device for physical therapy, not a machine learning model that requires a training set in that context. The "Software Assessment" refers to validation testing of the device's operational software.

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

    Not applicable, as there is no mention of a training set for a machine learning model.

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