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510(k) Data Aggregation

    K Number
    K183284
    Date Cleared
    2020-01-15

    (415 days)

    Product Code
    Regulation Number
    878.4400
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    INTRAcel RF Microneedle System

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

    INTRAcel RF Microneedle System is indicated for use in dermatological and general surgical procedures for electrocoagulation, hemostasis and the percutaneous fractional treatment of the skin in monopolar and bipolar mode.

    Device Description

    The INTRAcel RF Microneedle System comprises of two primary components; an RF Generator with User Interface Software and a disposable Electrode Insertion Device with an integrated cable.

    AI/ML Overview

    Here's an analysis of the provided text regarding the acceptance criteria and supporting studies for the INTRAcel RF Microneedle System:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria CategorySpecific Criteria / Test DescriptionReported Device Performance
    Electrical Safety & EMCIEC 60601-1:2012 (Medical electrical equipment - General requirements for basic safety and essential performance)Met all acceptance criteria in accordance with IEC 60601-1:2012.
    IEC 60601-1-6:2010, AMD1:2013 (Medical electrical equipment - General requirements for basic safety and essential performance - Collateral standard: Usability)Met all acceptance criteria in accordance with IEC 60601-1-6:2010, AMD1:2013.
    IEC 60601-2-2:2009 (Medical electrical equipment - Part 2-2: Particular requirements for the basic safety and essential performance of high frequency surgical equipment and high frequency surgical accessories)Met all acceptance criteria in accordance with IEC 60601-2-2:2009.
    Performance TestingPerformance Test Report for ESU (Electrosurgical Unit)Met the acceptance criteria.
    INTRAcel Tip Count TestMet the acceptance criteria.
    Verification Performance of INTRAcel TipMet the acceptance criteria.
    Biocompatibility TestingCytotoxicityMicroneedle electrodes are biocompatible.
    SensitizationMicroneedle electrodes are biocompatible.
    Intracutaneous ReactivityMicroneedle electrodes are biocompatible.
    Sterilization & Shelf LifeEthylene Oxide Sterilization ResidualsMet the acceptance criteria.
    Accelerated aging testMet the acceptance criteria.
    Software Verification & ValidationSoftware tested against established Software Design Specifications to assure performance as intended; Device Hazard Analysis completed, risk control implemented; acceptance criteria of each module and interaction of processes met.The software for this device was considered a "moderate" level of concern. All acceptance criteria for software development, verification, and validation were met, and the device performs as intended, supporting substantial equivalence and safe operation.

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

    The document does not explicitly state a "test set" in the context of clinical images or patient data that would require sample sizes and data provenance like country of origin or retrospective/prospective nature. The studies described are primarily non-clinical, focusing on device performance, electrical safety, biocompatibility, and software validation.

    • Animal Performance Testing (Wound Healing): The "study was conducted to see the wound healing response following FRM treatment for both human and porcine skin." While human skin is mentioned, the detailed procedural description (biopsy time points, H&E, HSP47, RT-PCR) is for "Micro-pig covering 10 weeks." The specific number of human or porcine subjects is not provided. The study appears to be prospective as it involves active treatment and observation over time.

    3. Number of Experts Used to Establish Ground Truth and Qualifications

    This information is not provided in the document. The studies detailed are technical (electrical, biocompatibility, software) or animal studies for wound healing, which do not typically involve human expert adjudication for ground truth establishing in the sense of medical image interpretation.

    4. Adjudication Method for the Test Set

    This information is not applicable/provided for the types of studies performed (technical bench testing, software validation, animal studies). There's no indication of a test set requiring adjudication in the context of expert consensus.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study and Effect Size

    A MRMC comparative effectiveness study was not performed or reported in this document. The device is an electrocoagulation and microneedling system; therefore, its performance is assessed directly through physical and electrical properties, biological safety, and tissue response, rather than as an aid to human interpretation like an AI diagnostic tool.

    6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study

    This concept is not applicable to the INTRAcel RF Microneedle System in the way it's usually applied to AI diagnostic algorithms. The device itself is an active treatment device, not a diagnostic algorithm. The software validation mentioned is for the control and functionality of the device, implying a "standalone" software performance in terms of controlling the hardware as intended, rather than interpreting medical data.

    7. Type of Ground Truth Used

    • For Electrical Safety & EMC: Ground truth would be defined by the specifications and pass/fail criteria of the referenced international standards (IEC 60601 series).
    • For Performance Testing: Ground truth would be defined by the device's design specifications and expected functional outputs (e.g., specific power output, tip count accuracy).
    • For Biocompatibility Testing: Ground truth is established by the results of standardized biological tests (cytotoxicity, sensitization, intracutaneous reactivity) against acceptance criteria for biocompatible materials.
    • For Sterilization & Shelf Life: Ground truth is established by the ability to achieve sterility (e.g., meeting sterility assurance levels) and maintain device integrity/functionality over time via accelerated aging.
    • For Software Verification & Validation: Ground truth is the established "Software Design Specifications" — the software's ability to operate the device as programmed and safely (per the "moderate" level of concern).
    • For Animal Performance Testing (Wound Healing): Ground truth is established through histological examination (H&E, HSP47 stain) and molecular analysis (RT-PCR for mRNA changes in collagen, HSPs, MMPs) of biopsied tissue, documenting physiological wound healing responses at different time points and energy levels.

    8. Sample Size for the Training Set

    This information is not provided and is specifically irrelevant as the document describes a physical medical device, not an AI/ML algorithm that requires a training set of data. The software mentioned handles device control, not predictive modeling or classification.

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

    This information is not applicable as there is no "training set" in the context of an AI/ML model for this device.

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