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510(k) Data Aggregation
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CurrentBody Skin LED Light Therapy Mask Series 2 (MK-90H)
The CurrentBody Skin™ LED Light Therapy Mask Series 2 (Model: MK-90H) is an over-the-counter device that is intended for the use in the treatment of full-face wrinkles.
The CurrentBody Skin™ LED Light Therapy Mask Series 2 (Model: MK-90H) is a home use wearable LED phototherapy device whose purpose is to produce an even, cool, narrow band of light for aesthetic indication for treating facial wrinkles. It emits light energy in the red and near infrared (NIR) region of the light spectrum.
The device consists of a flexible silicone mask that contains light emitting diodes (LEDs) and a controller, multi-straps, a USB-C charging cord, a pair of eye inserts and a storage bag. The LEDs generate the light. The mask is worn on the face and is held in place by the adjustable strap. The controller contains a rechargeable Lithium ion polymer battery and controls power to the mask. The controller has only one key to switch the LEDs ON/OFF and it will automatically shut down after a 10-minute treatment is completed.
The provided FDA 510(k) clearance letter for the CurrentBody Skin™ LED Light Therapy Mask Series 2 (K250966) does not contain the detailed study information typically associated with acceptance criteria and clinical performance for an AI/ML device in the context of diagnostic performance (e.g., detecting a disease).
This device is an LED light therapy mask intended for treatment of full-face wrinkles, falling under the regulation 21 CFR 878.4810 (Laser Surgical Instrument For Use In General And Plastic Surgery And In Dermatology). The primary focus of the regulatory review for such a device is safety and effectiveness based on its physical properties and intended use for cosmetic purposes, rather than diagnostic accuracy or AI-driven image analysis.
Therefore, many of the requested elements are not applicable to the information provided in this document. The document explicitly states:
- "Clinical testing is not needed for this 510(k)."
- "The non-clinical performance testing described above is sufficient to demonstrate that the device can be used safely and effectively."
This indicates that the device's clearance was based on demonstrating substantial equivalence to a predicate device through non-clinical tests (electrical safety, EMC, photobiological safety, battery safety, biocompatibility, and software verification/validation) and not on clinical performance metrics like sensitivity, specificity, or reader studies for diagnostic accuracy.
Addressing the Request Based on the Provided Document:
Given the nature of the device and the clearance documentation, I will answer the applicable points and explain why others are not present.
Acceptance Criteria and Device Performance for CurrentBody Skin™ LED Light Therapy Mask Series 2 (K250966)
The CurrentBody Skin™ LED Light Therapy Mask Series 2 is an LED phototherapy device for the treatment of full-face wrinkles. The acceptance criteria and performance evaluation for this device, as detailed in the 510(k) summary, are primarily focused on safety, electrical performance, material compatibility, and functional equivalence to a predicate device, rather than diagnostic performance metrics (e.g., accuracy in identifying wrinkles).
1. Table of Acceptance Criteria and Reported Device Performance
The concept of "acceptance criteria" for this device is primarily based on compliance with specific international safety and performance standards, and demonstrating substantial equivalence to a predicate device for its intended use. "Device performance" is therefore reported in terms of compliance with these standards and matching key operational parameters with the predicate.
Criteria Category | Specific Acceptance Criteria (based on compliance) | Reported Device Performance |
---|---|---|
Intended Use | Treatment of full-face wrinkles (OTC). | Met: "The CurrentBody Skin™ LED Light Therapy Mask Series 2 (Model: MK-90H) is an over-the-counter device that is intended for the use in the treatment of full-face wrinkles." |
Device Classification | Class II, OHS Product Code. | Met: Class II, OHS. |
Energy Type | Light Emitting Diodes. | Met: Uses Light Emitting Diodes. |
Dose/per time | 18 J/cm². | Met: 18 J/cm². |
Total Intensity | 30 mW/cm². | Met: 30 mW/cm². |
Treatment Time | 10 minutes per treatment, 5x weekly for 6 weeks. | Met: 10 minutes per treatment, 5x weekly for 6 weeks. Device automatically shuts down after 10-minute treatment. |
Wavelength | Red: 630±5nm, NIR: 830nm. | Met: Red: 633nm, Infrared: 830nm. Considered compliant as slight difference (633nm vs 630±5nm) is within tolerance and does "not raise new questions of safety or effectiveness." |
Electrical Safety | Compliance with IEC 60601-1, -1-2, -1-11, -2-57. | Met: "Non-clinical testing was performed on the subject device to validate the design and ensure compliance with..." these standards. |
Photobiological Safety | Compliance with IEC 62471. | Met: "Non-clinical testing was performed on the subject device to validate the design and ensure compliance with..." IEC 62471. |
Battery Safety | Compliance with IEC 62133-2. | Met: "The lithium battery of the subject device has been tested under standard IEC 62133-2." |
Biocompatibility | Compliance with ISO 10993-1, -5, -10, -23. | Met: Demonstrated by material equivalence to previously cleared devices which were compliant with these ISO standards. No changes in formulation, processing, or sterilization of materials that would affect biocompatibility. |
Software V&V | Compliance with FDA guidance. | Met: "Software verification and validation testing was performed and documentation provided in accordance with the recommendations of the Guidance for Industry and FDA Staff 'Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices.'" The device uses a timer and software to control treatment duration, similar to the predicate. |
2. Sample size used for the test set and the data provenance
Not applicable for performance evaluation in the context of typical AI/ML diagnostic devices. The clearance is based on non-clinical engineering and safety testing, component material equivalence, and functional equivalence to a predicate device. There is no "test set" of patient data or images in the conventional sense for evaluating diagnostic accuracy or clinical outcomes directly in this 510(k) submission.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable. No ground truth established by experts for a test set of clinical data, as no clinical performance study was conducted or required for this 510(k). Approval is based on safety, hardware specifications, and substantial equivalence.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. No clinical test set requiring adjudication was used.
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 is not a diagnostic AI device. No MRMC study was conducted or is relevant for this product's intended use (treatment of wrinkles).
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This device is a hardware LED light therapy mask. While it has software for control (e.g., timer), it is not a standalone diagnostic algorithm.
7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)
The "ground truth" for this device's clearance is not related to clinical data or diagnostic accuracy. Instead, the "truth" is established by:
- Compliance with recognized international standards for electrical safety, electromagnetic compatibility, photobiological safety, battery safety, and biocompatibility.
- Demonstration of substantial equivalence (same intended use, similar technological characteristics, and no new questions of safety or effectiveness) to a legally marketed predicate device (K221946).
For the purpose of treatment effectiveness validation in general, the underlying scientific basis for LED light therapy's effect on wrinkles (which is outside the scope of this specific 510k submission's clearance process details) would typically stem from clinical trials and dermatological research. However, this 510(k) relies on the predicate's established performance without new clinical studies.
8. The sample size for the training set
Not applicable. This device is not an AI/ML algorithm that requires a training set of data for learning or inference.
9. How the ground truth for the training set was established
Not applicable. As above, no training set for an AI/ML algorithm.
In summary, the provided 510(k) clearance letter details an approval based on substantial equivalence and compliance with safety and performance standards for a hardware medical device, not on the clinical performance or diagnostic accuracy of an AI/ML driven system. Therefore, many of the requested details regarding AI/ML study methodologies are not present in this document.
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