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510(k) Data Aggregation
(455 days)
Pollogen STOP U Model UXV Device
The STOP U Model UXV device is intended for use in the non-invasive treatment of mild to moderate facial wrinkles for adult users who have Fitzpatrick Skin Types I-IV.
The STOP U Model UXV device delivers RF current into the skin to generate heat through electrical impedance in the dermis and subcutaneous layers. The device consists of the following components and accessories: The STOP U Model UXV device (applicator unit), the STOP U Model UXV Power Supply and the STOP Preparation Gel.
This FDA 510(k) summary describes the Pollogen STOP U Model UXV Device, which is intended for the non-invasive treatment of mild to moderate facial wrinkles. The document details the device's technical specifications, performance tests, and comparison to a predicate device to demonstrate substantial equivalence for clearance.
Here's an analysis of the provided information, focusing on acceptance criteria and study details:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly present a table of acceptance criteria with corresponding performance results in a standalone section. Instead, compliance is reported against various performance standards and general functional expectations.
Acceptance Criteria / Performance Standard | Reported Device Performance |
---|---|
System's Technical Specification for Max RF Power Output | Verification test demonstrated that the STOP U Model UXV meets the system's technical specification for the max RF power output. (Implicitly, the device delivers 5.7W (+/- 10%) RF power as stated in the technological characteristics). |
Electrical Safety and Compatibility (referencing power control & accuracy related to user's input) | Electrical safety and compatibility testing was performed to validate that the STOP U Model UXV's power control and accuracy is in reference to the user's input. (Implicitly, it passed these tests). |
Software Validation Requirements | The STOP U Model UXV software was validated as required. (Implicitly, it passed validation). |
General Functionality as Intended | In all instances, the STOP U Model UXV device functioned as intended and observations were as expected. (This is a general statement of success for the performance tests conducted). |
Usability for Self-Selection (Correct self-selection rate for potential device users) | The Self-Selection study using the final packaging and design produced a correct self-selection rate that met Pollogen's goal. (Specific percentage not provided, but deemed successful). |
Human Factors Validation (Users can safely and effectively self-select, set up, and deliver treatment) | 61 subjects participated in the Human Factors validation with a 100% success rate. These results indicated that the design facilitated safe use. |
Clinical Efficacy and Safety for Mild to Moderate Facial Wrinkles (Indirectly, through the TriPollar technology) | A clinical study was conducted demonstrating the effect of the TriPollar technology for mild to moderate facial wrinkles and rhytides while using the FDA-cleared STOP U device for prescription use (K140255). This substantiated the safety and effectiveness of the technology. |
Compliance with Specific Performance Standards: |
- IEC/EN 60601-1 Ed 3.1 & A1:2012 (Medical Electrical Equipment: General safety)
- IEC 60601-1-6 (Usability)
- IEC 60601-1-11:2015 (Home healthcare environment)
- IEC/EN 60601-2-2 (High frequency surgical equipment)
- IEC 62304 (Software life cycle processes)
- IEC 60601-1-2 (Electromagnetic disturbances)
- ISO 15223-1:2016 (Symbols on labels)
- ISO 14971:2007 (Risk management) | The STOP U Model UXV device complies with all listed performance standards. (Implicitly, the device met the requirements of these standards). |
| Biocompatibility (Cytotoxicity, Sensitization) | The body contact materials are biocompatible per ISO 10993-5 (cytotoxicity) and ISO 10993-10 (irritation and skin sensitization). |
2. Sample Size Used for the Test Set and Data Provenance
- Self-Selection Study:
- Sample Size: Not explicitly stated for the "test set" demonstrating the correct self-selection rate, but the study "produced a correct self-selection rate that met Pollogen's goal."
- Data Provenance: Not specified (e.g., country of origin). The study was likely prospective, conducted by Pollogen Ltd.
- Human Factors Validation:
- Sample Size: 61 subjects.
- Data Provenance: Not specified (e.g., country of origin). The study was prospective, conducted by Pollogen Ltd.
- Clinical Study (for TriPollar Technology):
- Sample Size: Not specified.
- Data Provenance: Not specified regarding country of origin or whether it was retrospective or prospective, though "a clinical study was conducted" generally implies a prospective study. It refers to a previously cleared device (K140255), suggesting this data predates the current submission.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
- Self-Selection Study & Human Factors Validation: The document does not describe the use of experts to establish a "ground truth" in the traditional sense. These studies evaluated user interaction and self-selection by users, not by expert interpretation of clinical outcomes.
- Clinical Study (for TriPollar Technology): The document does not specify the number or qualifications of experts used to establish ground truth for the clinical study that demonstrated the effect on wrinkles. It only states that the study "demonstrating the effect... for mild to moderate facial wrinkles and rhytides."
4. Adjudication Method for the Test Set
- Self-Selection Study & Human Factors Validation: Adjudication methods are not described as these studies focused on user performance with the device/packaging, not expert consensus on specific findings.
- Clinical Study (for TriPollar Technology): The adjudication method for assessing wrinkle reduction in the clinical study is not described.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No, the document does not describe a Multi-Reader Multi-Case (MRMC) comparative effectiveness study comparing human readers with and without AI assistance. The device in question is a medical aesthetic device, not an AI diagnostic or assistance tool for human readers.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
Not applicable. This device is a physical electrosurgical device for aesthetic use, not an algorithm. Therefore, "standalone" performance in the context of AI algorithms is not relevant.
7. The Type of Ground Truth Used
- Self-Selection Study & Human Factors Validation: The ground truth was based on the outcome of user tasks (e.g., correct self-selection, successful setup and treatment delivery). There wasn't a "ground truth" in terms of a clinical diagnosis or objective measurement adjudicated by experts.
- Clinical Study (for TriPollar Technology): The ground truth for this study was the effect on mild to moderate facial wrinkles and rhytides. The specific methodology for measuring and verifying this effect (e.g., blinded assessments, imaging, standardized scales) is not detailed.
8. The Sample Size for the Training Set
Not applicable. The document describes a physical medical device, not an AI algorithm that requires a training set. The clinical study mentioned would be considered for validation/performance, not for training an algorithm.
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there is no mention of a training set for an AI algorithm.
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