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510(k) Data Aggregation
(116 days)
KOWA, FM-600, MODEL LSS50
KOWA FM-600 is an instrument to measure the protein level contained in aqueous humor of the anterior chamber of human eye.
KOWA FM-600, here after refer to as FM-600, is a noninyasive flare photometry device that is able to assess anterior protein level quantitatively.
FM-600 consists of three units, Measurement unit, Operating unit and Power supply unit. The measurement unit is contained optical system including Laser, photo receiver and CCD camera for observation. The operating unit is contained Observation monitor. Analyzer of detected photon intensity, printer for output and migratory mechanism of the units. The power supply unit is contained Power unit.
Here's an analysis of the KOWA FM-600's acceptance criteria and study, based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly state formal "acceptance criteria" for the FM-600. Instead, it demonstrates the device's technical characteristics and performance through precision measurements (repeatability and reproducibility) and a comparison to predicate devices. The implicit acceptance is that these performance metrics are acceptable for its intended use, especially given its substantial equivalence to previously cleared devices.
I will formulate "acceptance criteria" based on the reported precision of the device and its claimed substantial equivalence.
Criteria Category | Specific Acceptance Criteria (Inferred) | Reported Device Performance |
---|---|---|
Precision | Repeatability (Standard Deviation): | |
- ≤ 1.5% for high flare values | 1.5% at 500 mg/dL BSA (77.49 PC/ms) | |
- ≤ 5% at 80 PC/ms flare | Less than 5% at 80 PC/ms | |
Reproducibility (Standard Deviation): | ||
- ≤ 4% for high flare values | 4.00 PC/ms at 1000 mg/dL BSA (144.28 PC/ms) | |
Functionality | Non-invasive measurement of anterior chamber protein level | KOWA FM-600 is a noninvasive flare photometry device that is able to assess anterior protein level quantitatively. |
Single-function device for flare measurement | Kowa FM-600 is a single-function device of laser flare measurement. | |
Safety | Compliance with optical hazard standards (ISO15004-2, IEC60825-1, IEC60601-1) | Confirmed in equivalent level of safety to the predicate devices. |
Substantial Equivalence | Good correlation and low variance with predicate devices for flare value | KOWA FM-600 has good correlation and low valiance for the predicate device. |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: The precision study used Bovine Serum Albumin (BSA) solutions at 8 different concentrations (ranging from 0 to 2000 mg/dL). For each concentration, there were:
- 3 instruments
- 10 replicate measurements per instrument
- Total measurements = 8 concentrations * 3 instruments * 10 replicates = 240 measurements.
- Data Provenance: The data is from an in-vitro study using Bovine albumin solution, not human patient data. It is from the device manufacturer, Kowa Company, Ltd., located in Japan. The study is prospective in the sense that the measurements were actively performed for the premarket notification.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
This device measures a biophysical parameter (protein level/flare). The "ground truth" for the test set (BSA solutions) was established by the known concentrations of the prepared Bovine albumin solutions. Therefore, no human experts were used to establish ground truth for the test set in the way radiologists or pathologists would for diagnostic imaging. The accuracy of the BSA preparation would be verified by standard laboratory practices.
4. Adjudication Method for the Test Set
Not applicable. As noted above, the ground truth was based on prepared chemical concentrations, not expert interpretation requiring adjudication.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No, an MRMC comparative effectiveness study was not done. The study focuses on the device's technical precision and its comparison to predicate devices based on flare value measurements from BSA solutions, not on human reader performance with or without AI assistance. The KOWA FM-600 is a measurement device, not an AI diagnostic tool.
6. Standalone Performance (Algorithm Only without Human-in-the-Loop Performance)
Yes, the device's performance as described (repeatability and reproducibility) represents its standalone performance. The FM-600 directly measures the flare value; human interpretation of the measurement itself is not part of its core functionality, though a clinician would interpret the result in the context of a patient's condition. The "algorithm" here is the device's internal measurement system.
7. Type of Ground Truth Used
The ground truth used for the precision study was the known, prepared concentrations of Bovine albumin solutions (BSA). This is a controlled experimental "ground truth" rather than clinical ground truth (e.g., pathology, outcomes data, or expert consensus from patient cases).
8. Sample Size for the Training Set
The document does not describe a separate "training set" in the context of machine learning. The KOWA FM-600 is a measurement device, not an AI algorithm that undergoes distinct training. Its design and calibration would be based on engineering principles and potentially internal testing data, but this is not typically referred to as a "training set" in the same way as for AI.
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there's no explicitly described "training set" for an AI algorithm. The device's fundamental measurement capabilities would be established through engineering design, calibration using known standards (like the BSA solutions), and quality control processes.
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