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510(k) Data Aggregation
(89 days)
Ulthera System (UC-1 Control Unit PRIME Model 2.1)
The Ulthera System is intended to apply focused ultrasound energy to the body to achieve temporary changes in the physical appearance of the skin.
The Ulthera System is indicated for use as a non-invasive dermatological aesthetic treatment to:
- Lift the eyebrow
- Lift lax submental (beneath the chin) and neck tissue, which can also affect the appearance of lax tissue in the submental and neck regions
- Improve lines and wrinkles of the décolleté
- Improve the appearance of skin laxity on the abdomen, anterior arms, and posterior arms
The Ulthera® System, in conjunction with the Ulthera® DeepSEE® transducer, allows for ultrasonic visualization of depths up to 8 mm below the surface of the skin. The indicated use of the imaging is to visualize the dermal and subdermal layers of tissue to:
- Ensure proper coupling of the transducer to the skin
- Confirm appropriate depth of treatment such as to avoid bone
The Ulthera® System consists of the Ulthera® Control Unit (with system software), a handpiece with cable, and interchangeable transducers. The device produces controlled tissue coagulation below the skin surface (epidermis) within the first few millimeters of tissue (dermis) using highly focused, low-energy ultrasound deposition. The Ulthera® System directs micro-focused acoustic waves to the treatment area at desired depths without affecting or requiring a secondary action to protect the skin surface. The operator may also use the device's supplemental imaging capability to visualize the treatment area and aid in assuring full/proper skin contact of the Ulthera® System transducer to the skin in the target area.
The provided FDA 510(k) clearance letter for the Ulthera System describes changes to an existing device, primarily software updates to include wireless connectivity and a new treatment planning mode (SEE.PLAN.TREAT.®). It relies heavily on demonstrating substantial equivalence to a predicate device rather than presenting a de novo clinical study with specific acceptance criteria related to a new performance claim.
Therefore, the document does not contain the kind of detailed performance data and acceptance criteria that would typically be found for a device seeking clearance based on a new clinical effectiveness claim or a novel AI-driven diagnostic. The study described focuses on nonclinical performance testing to demonstrate that the minor software and hardware differences do not affect clinical functionality or performance specifications and that the device operates as intended and is as safe and effective as the predicate.
Below is an attempt to structure the information based on your request, highlighting what is present and what is absent from the provided text.
Analysis of Acceptance Criteria and Study to Prove Device Meets Criteria
Based on the provided FDA 510(k) clearance letter for the Ulthera System (UC-1 Control Unit PRIME Model 2.1), the device's acceptance criteria and the study proving it meets these criteria are primarily focused on demonstrating substantial equivalence to a previously cleared predicate device, especially concerning software and minor hardware changes. The performance data presented are nonclinical and focus on safety, electrical compatibility, software validation, usability, and cybersecurity, rather than specific clinical effectiveness endpoints.
1. Table of Acceptance Criteria and Reported Device Performance
Given that this is a 510(k) for a software update and minor hardware changes to an existing device, the acceptance criteria are not presented as traditional clinical performance metrics (e.g., sensitivity, specificity for a diagnostic device). Instead, they relate to the continued safe and effective operation of the modified device.
Acceptance Criterion (Implied per 510(k) context) | Reported Device Performance (as stated in the document) |
---|---|
Electrical Safety (Compliance with standards) | Compliant with IEC 60601-1 and IEC 60601-1-2. Subject device functioned as intended. |
Software Functionality and Safety (Verification and Validation - low risk) | Software verification and validation testing conducted. Documentation provided. A "basic documentation level" was used, indicating that "failure or flaw... would not present a hazardous situation with a probable risk of death or serious injury." Subject device functioned as intended. |
Usability (Ability for clinicians to use new mode safely) | Usability testing conducted per IEC 62366-1 and FDA Guidance. Clinicians were able to use the device in a representative environment and use conditions. No new risks identified during simulated use study. Subject device functioned as intended. |
Cybersecurity (Compliance with standards) | Cybersecurity testing conducted. Documentation provided as recommended by FDA guidance. Subject device functioned as intended. |
Clinical Functionality/Performance Specifications (Unaffected by changes) | "The minor software and hardware differences... do not affect clinical functionality or performance specifications of the system." "Nonclinical performance testing has demonstrated that the subject device operates as intended and that it is as safe and effective as the predicate for the proposed indications for use." |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: The document does not specify a "test set" sample size in terms of patient data or clinical cases. The testing reported is nonclinical.
- For Usability Testing, it mentions "clinicians" and a "simulated use study," implying a small group of human participants, but no specific number is provided.
- Data Provenance: Not applicable as the testing is nonclinical (electrical, software, usability simulation, cybersecurity). There is no mention of patient data (e.g., country of origin, retrospective/prospective).
3. Number of Experts Used to Establish Ground Truth and Qualifications
- Not Applicable: This type of information (experts establishing ground truth for a clinical test set) is not relevant for the nonclinical tests performed to support this 510(k). The "ground truth" for the nonclinical tests is compliance with engineering standards and proper software operation.
4. Adjudication Method for the Test Set
- Not Applicable: Adjudication methods (e.g., 2+1, 3+1) are used for establishing clinical ground truth, typically in the context of reader studies or clinical trials, which were not detailed or the focus of this 510(k) summary for software/hardware updates.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was Done
- No: The document does not mention any MRMC comparative effectiveness study. The focus is on demonstrating that the device itself (with updated software) is safe and effective through nonclinical means, and that its changes do not negatively impact the clinical functionality of the predicate. There is no claim about human readers improving with or without AI assistance, as the device is a therapeutic/aesthetic system, not an AI-driven diagnostic aid for human interpretation.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was Done
- Not Applicable in the traditional sense: The Ulthera System is a therapeutic device with an imaging component for guidance. Its "performance" is whether it delivers focused ultrasound energy as intended and the new software features (like SEE.PLAN.TREAT.®) function correctly. It's not an algorithm producing a diagnostic output that would have a standalone performance metric like AUC, sensitivity, or specificity. The testing performed confirms the system's standalone operational integrity (electrical, software V&V, cybersecurity) rather than algorithmic diagnostic performance.
7. The Type of Ground Truth Used
- Engineering Specifications and Standard Compliance: For the nonclinical tests, the "ground truth" is adherence to established engineering specifications, international electrical safety standards (IEC 60601-1, IEC 60601-1-2), usability standards (IEC 62366-1), and FDA guidance for software and cybersecurity.
- Functional Verification: For the new software features, the ground truth is whether the features operate as designed and intended (e.g., wireless connectivity functions, SEE.PLAN.TREAT.® mode works).
8. The Sample Size for the Training Set
- Not Applicable: This document describes a 510(k) clearance for software/hardware updates to an existing device. It does not refer to the development of a new AI algorithm requiring a training set in the sense of machine learning on clinical data. The "software" in question is the operating system and treatment planning interface, not an independently learning AI model.
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, this information is not provided. The development of the software features would have followed standard software development life cycle (SDLC) practices, with requirements defining the intended function.
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