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510(k) Data Aggregation

    K Number
    K171588
    Date Cleared
    2017-07-31

    (61 days)

    Product Code
    Regulation Number
    882.5890
    Reference & Predicate Devices
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    NuBODY Skin Toning Device is intended for body skin stimulation and is indicated for over-the-counter cosmetic use.

    Device Description

    NuBODY Skin Toning Device is intended for body skin stimulation and is indicated for over-the-counter cosmetic use. Four (4) spherical electrodes, fixed on the NuBODY device main body, deliver low level electrical impulses (microcurrent) to targeted locations on the body.

    AI/ML Overview

    This document describes a 510(k) premarket notification for the NuBODY Skin Toning Device, claiming substantial equivalence to the NuFACE Plus device. As such, the study focuses on characterizing the new device's technical specifications and safety standards rather than a clinical efficacy trial.

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

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

    The document does not explicitly state "acceptance criteria" in a separate section. Instead, the performance is demonstrated by comparing the new device (NuBODY) to a legally marketed predicate device (NuFACE Plus) based on their technological characteristics, basic unit characteristics, and output specifications. The assertion is that NuBODY meets the predicate's performance by being "the same, or similar," and that "differences do not alter the clinical utility."

    Therefore, the "acceptance criteria" are implied to be that the NuBODY device should have comparable performance characteristics and meet the same safety standards as the NuFACE Plus predicate device.

    Acceptance Criteria (Implied: Comparable to NuFACE Plus Predicate)Reported NuBODY Device Performance
    Technological Characteristics:
    - Power SourceRechargeable, non-replaceable, lithium-ion battery (Same as predicate)
    - Microcurrent DeliveryFour (4) smooth, chrome-plated, spherical electrodes (Predicate has two spheres, but both deliver microcurrent)
    - WaveformContinuous alternating microcurrent delivered in a burst of positive pulses followed by a burst of negative pulses (Same as predicate)
    Basic Unit Characteristics:
    - Power SourceInternal rechargeable Lithium ion battery (Same as predicate)
    - Method of Line Current IsolationType BF (Same as predicate)
    - Patient Leakage CurrentN/A - Battery operated (Same as predicate)
    - Number of Output Channels1 (Same as predicate)
    - Regulated Current or VoltageBoth (Same as predicate)
    - Software/Firmware/Microprocessor ControlYes (Same as predicate)
    - Automatic Overload TripNot required due to circuit design (Same as predicate)
    - Automatic No-Load TripYes (Same as predicate)
    - Automatic Shut OffYes (Same as predicate)
    - Patient Override ControlYes (Same as predicate)
    - Indicator Display (On/Off, Low Battery, Voltage/Current Level)All Yes (Same as predicate)
    - Automatic Shut-Off (minutes)Yes (5 minutes) (Predicate is 20 minutes; this difference is presented without an explicit "acceptance criterion" but is deemed not to alter clinical utility from the overall conclusion)
    - Compliance with Voluntary StandardsIEC 60601-1, IEC 60601-1-2, IEC 60529, IEC 60601-2-10, ISO 14971, IEC 60601-1-6, IEC 62366 (More comprehensive than predicate which listed IEC 60601-1, IEC 60601-1-2, demonstrating compliance with relevant standards.)
    - Compliance with 21 CFR 898Yes (Same as predicate)
    - Housing Materials and ConstructionThermoplastic (Same as predicate)
    Output Specifications:
    - Waveform (e.g., pulsed monophasic, biphasic)Monophasic waveform that is delivered in a burst of pulses (Same as predicate)
    - Shape (e.g., rectangular, spike, rectified sinusoidal)Voltage Modulated Square (Same as predicate)
    - Maximum Output Voltage28 VDC (Same as predicate)
    - Output Current when not stimulating< 1 µA (Same as predicate)
    - Output Tolerance+/- 10% (Same as predicate)
    - Pulse Width60 ms (Same as predicate)
    - Frequency (Hz)Approximately 8.3 Hz (Same as predicate)
    - For interferential modesNo Beat Frequency (Same as predicate)
    - For multiphasic waveformsNot Multiphasic (Same as predicate)
    - Pulses per burst20 (Same as predicate)
    - Pulses per second8.3 (Same as predicate)
    - Burst duration (seconds)2.4 s (Same as predicate)
    - Duty Cycle [Line (b) x Line (c)] (on time per burst)20.2 s (Same as predicate)
    - ON Time (seconds)60 msec (Same as predicate)
    - OFF Time (seconds)60 msec (Same as predicate)
    Differences noted but deemed acceptable:
    - Anatomic Sites (Intended Use)Body (NuBODY) vs. Face (NuFACE Plus) - This is the primary intended use difference for which equivalence is sought.
    - Number of Electrodes4 Spheres (NuBODY) vs. 2 Spheres (NuFACE Plus)
    - External Power AdapterNuFACE 5-volt power adapter (NuBODY) vs. NuFACE 7-volt power adapter (NuFACE Plus)
    - Maximum Output Current900 µA @ 500Ω (NuBODY) vs. 400 µA @ 500Ω (NuFACE Plus)
    - Maximum Output Current Density0.468 mA/cm² (NuBODY) vs. 0.419 mA/cm² (NuFACE Plus)
    - Net Charge (µC per pulse)54 µC (NuBODY) vs. 24 µC (NuFACE Plus)
    - Maximum Average Power Density (mW/cm²)4.18 (NuBODY) vs. 1.12 (NuFACE Plus)
    - Maximum Phase Charge (µC/Burst)1.08 (NuBODY) vs. 0.48 (NuFACE Plus)
    - Automatic Shut-Off5 minutes (NuBODY) vs. 20 minutes (NuFACE Plus)
    - WeightApproximately 10-14 oz. (NuBODY) vs. 9 oz. (NuFACE Plus)
    - DimensionsApproximately 2.75" x 6.5" x 6.0" (NuBODY) vs. 2.8" x 5.1" x 1.3" (NuFACE Plus)

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

    The document describes bench testing for nonclinical performance and safety. It tests "a production equivalent of the NuBODY, and a commercial unit of the predicate."

    • Sample Size for Test Set: One "production equivalent" NuBODY device and one "commercial unit" of the NuFACE Plus predicate device were used for the performance testing.
    • Data Provenance: Not explicitly stated, but the testing would have been conducted by or for the manufacturer (Carol Cole Company/NuFACE) in the USA (Vista, CA is the address). This is non-clinical, prospective bench testing.

    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 product is a microcurrent stimulator for cosmetic use, and the submission is a 510(k) based on substantial equivalence demonstrated through bench testing and compliance with recognized standards. There is no mention of clinical studies using human subjects or expert clinical panels to establish "ground truth" for the performance criteria in this document. The "ground truth" for this type of submission is typically derived from established engineering and safety standards and comparison to a predicate device's specifications.

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

    Not applicable. As described above, there was no clinical study involving human readers or assessment that would require an adjudication method. The evaluation was based on non-clinical bench testing against engineering specifications and predicate device characteristics.

    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 a transcutaneous electrical nerve stimulator for cosmetic purposes, not an AI-powered diagnostic device or a system designed to assist human readers. Therefore, an MRMC comparative effectiveness study or AI-related performance metrics are not relevant to this submission.

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

    Not applicable. This is a physical electronic device, not an algorithm.

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

    The "ground truth" for this 510(k) submission is primarily the technical specifications and safety standards as defined by regulatory bodies (e.g., FDA regulations, IEC standards) and demonstrated by the performance of the predicate device (NuFACE Plus). The "study" (bench testing) aims to confirm that the new device's technical output and safety parameters are comparable and compliant.

    8. The sample size for the training set

    Not applicable. This device does not involve machine learning or AI, so there is no "training set."

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

    Not applicable, as there is no training set.

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