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510(k) Data Aggregation

    K Number
    K173571
    Date Cleared
    2018-03-21

    (121 days)

    Product Code
    Regulation Number
    882.1320
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Element System with IBT Electrodes

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Element system is intended to be used exclusively for myoelectric exoprosthetic fittings of the upper limb.

    Device Description

    The Element system is a surface electromyography (EMG) electrode system that is to be used with upper limb prosthetic devices. Element outputs standard envelop EMG signals detected from EMG electrodes (IBT Electrodes) placed on the user's skin. These signals are used as inputs by connected prosthetic devices, such as hands, wrists or elbows. The Element system is an alternative to standard suction socket myoelectrodes, with the advantages of a lower profile, digital signal processing, and wireless gain adjustment. Element does not replace or modify any functionality of connected prosthetic components.

    Element is compatible with most hands, wrists, and elbows that accept standard analog EMG electrode inputs. The Element system is typically sold with three-port kidney-style output connectors, however alternative connectors may be used to ensure compatibility with other terminal devices. The Element system accepts power from IBT's FlexCell Battery system and outputs control EMG signals to hands, wrists, or other prosthetic components. The Element system is installed in the prosthesis by a trained prosthetist and connected to prosthetic components selected to meet the needs of the individual user.

    System components:

    • IBT Electrodes (up to 2)
    • Signal Processing Box
    • Element Desktop Software
    AI/ML Overview

    The provided document is a 510(k) summary for the Infinite Biomedical Technologies (IBT) Element System with IBT Electrodes. It outlines the device's characteristics, comparison to a predicate device, and the testing conducted to demonstrate substantial equivalence.

    Here's an analysis of the acceptance criteria and study information, addressing your specific questions:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document doesn't explicitly present a table of acceptance criteria with corresponding pass/fail results for each criterion to demonstrate "device performance" in terms of clinical outcomes or specific quantitative metrics for the Element System's functionality as a myoelectric signal processor. Instead, it focuses on demonstrating safety and effectiveness through adherence to recognized standards and successful completion of various verification and validation tests.

    However, we can infer acceptance criteria from the "Performance Data" section. The acceptance criterion for each test is generally "Pass," indicating that the device met the requirements of the specified standard or test protocol.

    Here's a table based on the provided "Performance Data":

    CategoryTest/StandardAcceptance Criteria (Implied)Reported Device Performance
    SafetyIEC/EN 60601-1: Medical electrical equipment Part 1: General requirements for basic safety and essential performanceCompliance with standardEquivalent (to predicate)
    IEC 60601-1-11: General requirements for basic safety and essential performance - Collateral Standard: Requirements for medical electrical equipment and medical electrical systems used in the home healthcare environmentCompliance with standardPredicate was not tested to this standard, implying the Element system does comply.
    Electromagnetic CompatibilityIEC 60601-1-2: Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral standard: Electromagnetic compatibility - Requirements and testsCompliance with standardEquivalent
    BiocompatibilityISO 10993-1: Biological evaluation of medical devices Part 1: Evaluation and testing within a risk management processCompliance with standardEquivalent
    ISO 10993-5: Biological evaluation of medical devices Part 5: Test for in vitro cytotoxicityCompliance with standardEquivalent
    ISO 10993-10: Biological evaluation of medical devices Part 10: Test for irritation and skin sensitizationCompliance with standardEquivalent
    Design V&V/Usability (Element System)Compatibility with IBT ElectrodesDevice is compatiblePass
    Simulated installation of ElementSuccessful simulated installationPass
    Simulated Use of Element Software and Electrode PlacementSuccessful simulated usePass
    Simulated Use with Commonly used Prosthetic ComponentsSuccessful simulated usePass
    Lifetime and Reliability TestingDevice meets lifetime/reliability requirementsPass
    Testing Report SummaryReport deemed satisfactoryPass
    Signal Performance during Simulated UseAcceptable signal performancePass
    Simulated battery life with ElementAcceptable battery lifePass
    Simulated use with Region Specific NoiseAcceptable performance in noisePass
    Packaging Drop TestPackaging integrity maintainedPass
    Simulated Installation of IBT ElectrodesSuccessful simulated installationPass
    Simulated SealAcceptable seal performancePass
    Simulated CleaningDevice withstands cleaningPass
    FlexCell Battery TestingIEC 60601-1: Medical electrical equipment Part 1: General requirements for basic safety and essential performanceCompliance with standardComplies
    IEC 62133: Secondary cells and batteries containing alkaline or other non-acid electrolytes - Safety requirements for portable sealed secondary cells, and for batteries made from them, for use in portable applicationsCompliance with standardComplies
    UN38.3: Transportation Testing for Lithium BatteriesCompliance with standardComplies
    FlexCell Major Component TestMajor components perform as specifiedPass
    FlexCell V&V Test Specification PlansPlans are executed successfullyPass
    FlexCell Charger Update V&V Test PlanPlan is executed successfullyPass
    FlexCell Charger IC Update V&V Test PlanPlan is executed successfullyPass

    2. Sample Size Used for the Test Set and the Data Provenance

    The document does not specify the sample sizes used for the various verification and validation tests listed. It also does not provide details on data provenance (e.g., country of origin of the data, retrospective or prospective) for these tests. The tests mentioned are primarily laboratory-based simulations and regulatory standard adherence, not clinical trials with patient data.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts

    This information is not provided in the document. The tests described are engineering and regulatory compliance validations rather than diagnostic or interpretative studies requiring expert ground truth establishment. For example, "Signal Performance during Simulated Use" would likely involve objective measurements against predefined specifications, not expert consensus on an interpretation.

    4. Adjudication Method for the Test Set

    This information is not provided and is generally not applicable to the types of engineering and regulatory compliance tests described. Adjudication methods (like 2+1, 3+1) are common in clinical studies where multiple human readers interpret data, and an agreed-upon truth is needed.

    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

    A Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done and is not applicable to this device. The Element System is a myoelectric signal processing unit for prosthetic control, not an AI-assisted diagnostic or interpretive tool that human readers would use. The document describes the system as an alternative to standard suction socket myoelectrodes, with advantages like a lower profile, digital signal processing, and wireless gain adjustment, but it doesn't involve "AI assistance" in the sense of improving human reader performance.

    6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) Was Done

    The Element System itself is a standalone algorithm/device for processing myoelectric signals. The performance tests ("Signal Performance during Simulated Use", "Simulated battery life with Element", "Simulated use with Region Specific Noise") would effectively be standalone performance evaluations of the device's electrical and signal processing capabilities, without human user interaction as part of the performance measurement. However, its intended use is with a human user providing the EMG signals and benefiting from its processing for prosthetic control.

    7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.)

    For the specific tests mentioned, the "ground truth" would be established by:

    • Regulatory Standards: For tests like IEC 60601-1, ISO 10993, and UN38.3, the ground truth is adherence to the requirements and specifications defined by these international standards.
    • Engineering Specifications: For tests like "Compatibility with IBT Electrodes," "Signal Performance during Simulated Use," and "Simulated Seal," the ground truth would be predefined engineering specifications, performance tolerances, or established benchmarks for electrical signals and mechanical functions.
    • Simulated Conditions: For tests involving "simulated use" or "simulated battery life," the ground truth is the controlled and measurable conditions established within the simulation.

    There is no mention of expert consensus, pathology, or outcomes data being used as ground truth in this submission, as it's not a diagnostic or treatment outcome-focused device.

    8. The Sample Size for the Training Set

    The document does not mention any training set size. As the Element System with IBT Electrodes is a device that processes myoelectric signals based on predefined algorithms and hardware, it is unlikely to involve "training" in the machine learning sense that would require a distinct training set. The "digital signal processing" and "signal smoothing" functionalities are described as inherent design features or adjustable parameters, rather than learned models.

    9. How the Ground Truth for the Training Set Was Established

    Since no training set is mentioned or implied, the question of how its ground truth was established is not applicable.

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