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510(k) Data Aggregation
(121 days)
V30 system, V20 system, V10 system, V-VR Hand piece
The Viora V10 system is intended for dermatological procedures.
The V10 system with the V-VR Handpiece is indicated for the temporary relief of minor muscle aches and pain, temporary relief of muscle spasm, and temporary improvement of local blood circulation.
The Viora V20 system is intended for dermatological procedures.
The V20 system with the V-VR Handpiece is indicated for the temporary relief of minor muscle aches and pain, temporary relief of muscle spasm, and temporary improvement of local blood circulation.
The Viora V30 system is intended for dermatological procedures.
The V30 system with the V-VR Handpiece is indicated for the temporary relief of minor muscle aches and pain, temporary relief of muscle spasm, and temporary improvement of local blood circulation.
Multi-application, multi-technology platform device intended for use in dermatologic procedures. The main console unit incorporates a touch-screen control panel, power supply modules, cooling system, switching module and service panel. Cooled by deionized water based on the well-established bipolar radiofrequency (RF) technology used for heating of soft tissues. The main console unit incorporates a touch-screen control panel, power supply modules, RF generator and service panel.
The V-VR Handpiece is supported by Viora's V10, V20 and V30 systems.
The provided text describes a 510(k) premarket notification for the Viora V-VR Handpiece compatible with V30, V20, V10 Systems. The document focuses on demonstrating substantial equivalence to predicate devices rather than providing a detailed study proving the device meets specific performance acceptance criteria for a new clinical claim.
Therefore, much of the requested information regarding acceptance criteria, study methodologies, sample sizes, expert involvement, and ground truth establishment, which are typical for studies validating a new clinical claim or an AI/ML device, are not present in this regulatory submission. This submission is for a modified accessory (handpiece) with similar intended use to an already cleared device, primarily relying on bench testing and software validation to show equivalence and safety, not on a new clinical study.
However, based on the information provided, here's what can be extracted:
1. Table of Acceptance Criteria and Reported Device Performance:
The document outlines performance standards for safety and electrical characteristics rather than clinical efficacy metrics. The primary "acceptance criterion" demonstrated through bench testing is the capability of the V-VR Handpiece to safely maintain superficial skin therapeutic temperature between 40-45 ℃ during 14 minutes of treatment.
Acceptance Criteria (Performance Standard) | Reported Device Performance |
---|---|
Electrical Safety: Conformance with IEC 60601-1:2012 | Device determined to be in conformance. |
Electromagnetic Compatibility (EMC): Conformance with IEC 60601-1-2: 2014 | Device determined to be in conformance. |
Non-Laser Light Source Equipment Safety (for V20, V30): Conformance with IEC 60601-2-57:2011 | Device determined to be in conformance. |
Surgical/Therapeutic Laser Equipment Safety (for V20, V30): Conformance with IEC 60601-2-22:2007 | Device determined to be in conformance. |
Laser Product Safety (for V20, V30): Conformance with IEC 60825-1:2014 | Device determined to be in conformance. |
Therapeutic Temperature Maintenance for V-VR IR (Infra-Red) handpiece: Safely maintain superficial skin temperature between 40-45 ℃ during 14 minutes of treatment. | Bench testing "demonstrated that the Viora V10, V20, V30 system with V-VR Handpiece performs per its device specifications." This implicitly confirms the temperature maintenance capability. |
Biocompatibility: Meet requirements of ISO 10993-1 for surface device with limited to transient contact. | All components coming into contact with skin (tip, electrodes) are biocompatible and meet the requirement. |
Software Functionality: Software verification and validation testing results acceptable for software release. | Testing results were found acceptable for software release. |
Overall Performance: Perform according to specifications and function as intended. | All performance testing demonstrated that the device performs according to specifications and functions as intended. |
2. Sample size used for the test set and the data provenance:
The document does not mention a clinical test set or patient data. The validation relies on bench testing for performance, electrical safety, EMC, and software. There is no mention of country of origin or whether data was retrospective or prospective, as it's not a data-driven clinical study.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
Not applicable as no clinical test set requiring expert ground truth for a diagnostic or AI claim was conducted. The "ground truth" for the engineering and safety tests is based on established industry standards (IEC, ISO) and internal device specifications.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
Not applicable as no clinical test set requiring adjudication was conducted.
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 is not an AI/ML device for diagnostic or interpretive purposes, nor a device that assists human readers.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
Not applicable. This is a medical device (handpiece) that performs a physical therapeutic action, not an algorithm.
7. The type of ground truth used (expert concensus, pathology, outcomes data, etc):
The "ground truth" for this regulatory submission is adherence to safety and performance standards (IEC, ISO), as measured by technical bench tests and software validation. For the clinical claims (temporary relief of minor muscle aches and pain, etc.), the device relies on substantial equivalence to the predicate devices which had already established these indications.
8. The sample size for the training set:
Not applicable. This is not an AI/ML device that requires a training set.
9. How the ground truth for the training set was established:
Not applicable.
Summary of the Study:
The "study" described in this 510(k) summary is primarily a series of non-clinical bench tests and engineering analyses to demonstrate that the new V-VR Handpiece, when used with existing Viora systems (V10, V20, V30), is as safe and effective as the predicate V-ST Handpiece, and meets applicable safety standards. The core argument for acceptance is substantial equivalence to already cleared devices, rather than a de novo clinical demonstration of efficacy.
The key tests performed were:
- V-VR IR temperature assessment: To verify its capability to safely maintain superficial skin therapeutic temperature (40-45 ℃ for 14 minutes).
- Electrical Safety & EMC Testing: Conformance to IEC standards (60601-1, 60601-1-2, 60601-2-57, 60601-2-22, 60825-1).
- Biocompatibility Testing: Conformance to ISO 10993-1.
- Software Verification and Validation: To ensure the software supporting the handpiece functions correctly and as intended.
The acceptance criteria are therefore implicit in meeting these standards and demonstrating performance per device specifications, without needing a separate clinical study with patient samples or expert adjudication for this specific submission.
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V30 System, V20 System, V10 System, V-FR Handpiece
The Viora V10 system is intended for dermatological procedures.
The V10 system with V-FR is indicated for dermatological procedures requiring ablation and resurfacing of the skin.
The Viora V20 system is intended for dermatological procedures. The V20 system with V-FR is indicated for dermatological procedures requiring ablation and resurfacing of the skin.
The Viora V30 system is intended for dermatological procedures. The V30 system with V-FR is indicated for dermatological procedures requiring ablation and resurfacing of the skin.
The V-FR Handpiece is fractional Bi-polar radiofrequency (RF) Handpiece is supported by Viora's V10, V20 and V30 systems.
V30: Multi-application, multi-technology platform device intended for use in dermatologic procedures. The main console unit incorporates a touch-screen control panel, power supply modules, cooling system, switching module and service panel.
V20: dermatologic procedures. The main console unit incorporates a touch-screen control panel, power supply modules, cooling system, switching module and service panel. Cooled by deionized water
V10: based on the well-established bipolar radiofrequency (RF) technology used for heating of soft tissues. The main console unit incorporates a touch-screen control panel, power supply modules, RF generator and service panel.
The FDA 510(k) clearance letter and summary for the Viora V30, V20, V10 Systems and V-FR Handpiece (K201064) provides information about the device's substantial equivalence to predicate devices, but it does not include acceptance criteria or the specifics of a study proving the device meets those criteria in the typical sense of a clinical performance study with predefined endpoints and statistical analysis.
Instead, the document focuses on demonstrating substantial equivalence through:
- Comparison of technological characteristics with predicate devices.
- Non-clinical testing, including electrical safety, electromagnetic compatibility, performance bench tests, biocompatibility, and software verification/validation.
- An animal study to evaluate safety and effectiveness for the indicated use.
Therefore, many of the requested categories for a study proving acceptance criteria cannot be directly extracted from this document in the traditional format. However, I can provide the available information:
1. Table of "Acceptance Criteria" (interpreted as performance standards and study findings) and Reported Device Performance:
Category | Acceptance Criteria (from performance standards / study goals) | Reported Device Performance |
---|---|---|
Electrical Safety | Conformance to IEC 60601-1:2012 | Device was determined to be in conformance with IEC 60601-1:2012. |
Electromagnetic Compatibility | Conformance to IEC 60601-1-2:2014 | Device was determined to be in conformance with IEC 60601-1-2:2014. |
Non-Laser Light Source (V20, V30) | Conformance to IEC 60601-2-57:2011 | V20, V30 systems determined to be in conformance with IEC 60601-2-57:2011. |
Surgical Laser (V20, V30) | Conformance to IEC 60601-2-22:2007 | V20, V30 systems determined to be in conformance with IEC 60601-2-22:2007. |
Laser Product Safety (V20, V30) | Conformance to IEC 60825-1:2014 | V20, V30 systems determined to be in conformance with IEC 60825-1:2014. |
General Performance | Performs per device specifications; safe and effective as cleared predicate devices (Bench testing goal) | Bench testing demonstrated that the V-FR Handpiece performs per its device specifications and is as safe and effective as the cleared predicate devices. All performance testing demonstrated it performs according to specifications and functions as intended. |
Biocompatibility (V-FR tip) | Meet requirements of ISO 10993-1 for surface device contacting breached/compromised skin in limited duration (Cytotoxicity, Irritation, Sensitization tests) | Results showed that the V-FR tip materials meet the requirement of ISO 10993-1 for indicated contact type. |
Software Functionality | Software verification and validation testing results found acceptable for release (Software goal) | Software verification and validation testing was conducted, and results demonstrated that testing results were found acceptable for software release. |
Animal Study (Safety/Effectiveness) | Evaluate safety and effectiveness for dermatological procedures requiring ablation and resurfacing of the skin; no device-related serious adverse events | Action of V-FR handpiece (coagulation and ablation of epidermis/superficial dermis) was confirmed. Histopathological evaluation indicated well-circumscribed coagulation necrosis limited to treated tissue, with intact skin in-between. Healing initiated from intact areas without adjacent tissue complications (inflammation, thrombosis). Clear, consistent, time-related progressive healing without adverse reactions. No device-related serious adverse events. |
2. Sample Size Used for the Test Set and Data Provenance:
- Test Set (Animal Study): "female domestic pigs (Sus scrofa domestica)" were used, but the specific number (sample size) is not provided.
- Data Provenance: The animal study was "prospective" as described, but the country of origin of the data is not explicitly stated.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts:
- The document mentions "Histopathological evaluation of the tissue samples" but does not specify the number or qualifications of experts performing this evaluation in the animal study.
4. Adjudication Method for the Test Set:
- The document does not describe an adjudication method for the animal study.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:
- No MRMC comparative effectiveness study involving human readers and AI assistance was mentioned or conducted, as this device (V-FR Handpiece) is a fractional radiofrequency device, not an AI-assisted diagnostic tool.
6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study:
- This is not applicable as the device is a physical medical device (RF handpiece) and not an AI algorithm. Its performance is evaluated through bench testing and animal studies.
7. Type of Ground Truth Used (Animal Study):
- Histopathology/Histopathological evaluation: This involved examining skin biopsies for depth/width of ablated tissue, coagulative necrosis, and signs of healing/complications.
- Macroscopic evaluation: Local reactions were evaluated grossly.
8. Sample Size for the Training Set:
- Not applicable/Not provided: This device does not involve an AI algorithm with a distinct "training set" in the context of machine learning. The "training" for the device, if one considers it, would be its design, engineering, and manufacturing based on existing medical device knowledge and standards.
9. How the Ground Truth for the Training Set Was Established:
- Not applicable: As noted above, there is no AI training set in the context of this device. Ground truth for the device's design and functionality would stem from established medical physics, dermatology principles, and engineering standards.
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V30 system, V20 system, V10 system, V-FC Handpiece
The Viora V10 system is intended for dermatological procedures. The V10 system with V-FC Handpiece is indicated for delivering non thermal RF combined with massage, Relief of minor muscle aches and pain, relief of muscle spasm, temporary improvement of local blood circulation and Temporary reduction in the appearance of cellulite.
The Viora V20 system is intended for dermatological procedures. The V20 system with V-FC Handpiece is indicated for delivering non thermal RF combined with massage, Relief of minor muscle aches and pain, relief of muscle spasm, temporary improvement of local blood circulation and Temporary reduction in the appearance of cellulite.
The Viora V30 system is intended for dermatological procedures. The V30 system with V-FC Handpiece is indicated for delivering non thermal RF combined with massage, Relief of minor muscle aches and pain, relief of muscle spasm, temporary improvement of local blood circulation and Temporary reduction in the appearance of cellulite.
The V-FC Handpiece is supported by Viora's V10, V20 and V30 systems. The V10, V20 and V30 systems are multi-application, multi-technology platform devices intended for use in dermatologic procedures. The main console unit incorporates a touch-screen control panel, power supply modules, cooling system, switching module and service panel. Cooled by deionized water based on the well-established bipolar radiofrequency (RF) technology used for heating of soft tissues. The main console unit incorporates a touch-screen control panel, power supply modules, RF generator and service panel.
The document does not contain information about specific acceptance criteria related to a diagnostic or AI-based device's performance metrics (e.g., sensitivity, specificity, AUC) or a study proving that such criteria were met.
Instead, this document is a 510(k) Premarket Notification from the FDA, asserting substantial equivalence for the Viora V30, V20, V10 systems with the V-FC Handpiece to previously cleared predicate devices. The "performance criteria" and "study" described are focused on proving that the new handpiece and system configurations are as safe and effective as the existing predicate devices for their indicated uses.
Therefore, I cannot populate the requested table or answer most of the questions as they pertain to a type of study and acceptance criteria not present in this regulatory document.
However, I can extract information related to the device's technical performance and safety testing.
Here's an analysis of the provided information:
1. Table of Acceptance Criteria and Reported Device Performance
As noted, the document does not present acceptance criteria in terms of diagnostic performance metrics. The "performance" discussed is primarily related to safety and maintaining therapeutic temperature.
Acceptance Criteria (Internal/Safety-focused) | Reported Device Performance |
---|---|
Maintain superficial skin therapeutic temperature between 39-42 °C during 14 minutes of treatment. | "The V-FC handpiece can be easily operated to ensure therapeutic body temperature between 39-42 ℃, while treating in operating room temperature between 10° C to 30° C..." |
System stops RF energy delivery if the handpiece IR sensor detects body temperature above 47°C. | "In cases of temperature decreasing below 39C or increasing above 42C the practitioner investigator was able to react immediately to increase /decrease the RF power. In addition to increase the safety profile, the system software is designed in such way that once the handpiece IR sensor detects body temperature above 47C. the system stops delivery of RF energy." |
Compliance with Electrical Safety and Electromagnetic Compatibility (e.g., IEC 60601-1, IEC 60601-1-2). | "The V-FC Handpiece compatible with V30, V20, V10 Systems was determined to be in conformance with applicable IEC standards..." |
Biocompatibility of skin-contacting components (tip, electrodes) meeting ISO 10993-1 requirements. | "Thus, all components that come into contact with the skin (tip, electrodes) are biocompatible and meet the requirement of the ISO 10993-1." "Additional biological evaluation for the V-FC Handpiece is considered to have meet the requirements for a surface device with limited to transient contact and can be considered safe and suitable for its intended use." |
Software verification and validation demonstrating acceptable results for release and performance to specifications. | "Software verification and validation testing was conducted, and results demonstrated that testing results were found acceptable for software release. All performance testing demonstrated that the Viora V10, V20, V30 system with V-FC Handpiece performs according to specifications and functions as intended." |
As safe and effective as predicate devices. | "In conclusion, the V-FC Handpiece compatible with V30, V20, V10 Systems is substantially equivalent to its predicate device." "The differences do not raise any new issues of safety or effectiveness." |
2. Sample size used for the test set and the data provenance
The document mentions "Dedicated tests were performed during three days" to assess temperature maintenance. It refers to "participants" but does not specify the number of human participants for this test. It also mentions "previous ex-vivo tests on the chicken breast" for the 47°C safety cutoff.
- Sample Size (human): Not specified, only refers to "participants."
- Sample Size (ex-vivo): Not specified (e.g., number of chicken breasts).
- Data provenance: The testing was done internally as part of the safety and performance verification for the 510(k) submission. No specific country of origin is mentioned for these particular tests, but the submitter Viora Ltd. is based in Netanya, Israel. It's a prospective internal test for regulatory submission.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This information is not applicable as the document describes safety and performance bench tests and not a clinical diagnostic performance study requiring expert ground truth establishment.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This information is not applicable as the document does not describe a diagnostic study with a test set requiring adjudication.
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
This information is not applicable. This is a device for dermatological procedures involving RF and massage, not an AI-assisted diagnostic device.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This information is not applicable. This is a physical medical device, not an AI algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
The document describes safety and performance bench tests where "ground truth" was based on:
- Measured temperature: Using an integrated IR thermometer and LED indications.
- System response: Observing if the system stopped RF energy delivery when a certain temperature threshold was reached (tested on chicken breast).
- Compliance with defined standards: Such as IEC and ISO for electrical safety, EMC, and biocompatibility.
8. The sample size for the training set
This information is not applicable. This is not an AI/machine learning device that would require a training set.
9. How the ground truth for the training set was established
This information is not applicable.
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(158 days)
V20 system
The Viora V20 system is intended for dermatological procedures.
The V-ST Handpiece is indicated for the temporary relief of minor muscle aches and pain, temporary relief of muscle spasm, and temporary improvement of local blood circulation.
The V-IPL Handpiece with wavelengths 415-1200nm (with 5 different filters) is indicated for the treatment of: Moderate inflammatory acne vulgaris.
Benign pigmented epidermal lesions including dyschromia, hyperpigmentation, melasma, and ephelides (freckles). Cutaneous lesions including warts, scars and striae.
Benign cutaneous vascular lesions including port wine stains, hemangiomas, facial, truncal and leg telangiectasias, rosacea, erythema of rosacea, angiomas, poikiloderma of Civatte and venous malformations. Removal unwanted hair. It is also intended for permanent reduction in unwanted hair. Permanent hair reduction is defined as the long-term stable reduction in the number of hairs regrowing when measured at 6, 9, and 12 months after the completion of a treatment regimen.
The V-Form Handpiece (with BC and FC applicators) is indicated for delivering non thermal RF combined with massage: relief of minor muscle aches and pain, relief of muscle spasm, temporary improvement of local blood circulation and temporary reduction in the appearance of cellulite.
The Viora V20 system is a RF and IPL multi application platform with three available treatment Handpieces:
V-ST Handpiece - Bi polar radiofrequency (RF) Handpieces
V-IPL Handpiece - Intense Pulsed Light (IPL) Handpiece
V - Form Handpiece (with BC and FC applicators) - mechanical vacuum massage and Bi-polar radiofrequency (RF) Handpiece.
The Main Unit (console) provides the operational and safety function of the system. The operator can modify the treatment parameters to achieve specific tissue effects depending on individual patient's skin condition and anatomical structure. The Foot Switch is used for system activation.
The provided text does not contain acceptance criteria or a study proving the device meets those criteria in the context of an AI/ML-driven medical device.
The document is a 510(k) premarket notification for the Viora V20 System, a multi-application RF and IPL device for dermatological procedures. It focuses on demonstrating substantial equivalence to previously cleared predicate devices, rather than presenting performance data from a new study against defined acceptance criteria.
Here's why the requested information cannot be extracted and what is described instead:
- Acceptance Criteria and Reported Device Performance: This document does not specify quantitative acceptance criteria (e.g., sensitivity, specificity, accuracy targets) or report corresponding performance metrics for a new study. Instead, it argues for substantial equivalence by stating that the current device has "the same technological characteristics and the same performance characteristics" as its predicate devices, or that "no new safety or efficacy issues can be raised."
- Sample Size and Data Provenance: No new study data is presented, so there is no mention of sample size for a test set or data provenance.
- Number and Qualifications of Experts: No experts were used to establish ground truth because no new clinical study data is presented for performance evaluation.
- Adjudication Method: Not applicable, as no new study requiring ground truth establishment is described.
- Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study: Not applicable. This is a 510(k) for a physical medical device, not an AI/ML diagnostic or assistive tool that would typically involve human-in-the-loop studies.
- Standalone Performance: Not applicable. The device is a physical system (RF and IPL handpieces) and not an algorithm/software with standalone performance metrics in the typical AI sense.
- Type of Ground Truth: Not applicable, as no new performance study data is presented.
- Sample Size for Training Set: Not applicable. This refers to an AI/ML training set, which is not relevant to this device's submission type.
- How Ground Truth for Training Set was Established: Not applicable.
What the document does state regarding "proof" and "performance":
- Substantial Equivalence: The core argument is substantial equivalence to predicate devices (Viora V20 system K142093 and Viora V10 system K150035). The manufacturer asserts that the V20 system with the V-Form Handpiece is "exactly the same" or has "the same technological characteristics and the same performance characteristics" as the cleared predicate devices, thus raising "no new safety or efficacy issues."
- Bench Testing: "Bench testing demonstrated that the V20 system (with the V- Form Handpiece) is as safe and effective as the cleared predicate devices." However, specific numerical results or acceptance criteria for this bench testing are not provided in this summary.
- No Clinical Studies Required: "Since the technological parameters of the Viora V20 system with the V- Form Handpiece are well within the parameters of the previously cleared V20 and V10 systems, Viora believes that animal and clinical studies are not required to determine the safety and efficacy of the V20 system with the V- Form Handpiece." This explicitly states that no new clinical study (which would typically generate performance data against acceptance criteria) was conducted or deemed necessary for this submission.
- Compliance with Standards: The V20 system complies with several IEC standards (IEC 60601-1, IEC 60601-1-2, IEC 60601-2-2, IEC 60601-2-57), which demonstrate safety and essential performance through adherence to recognized international standards.
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(105 days)
V20 SYSTEM
The Viora V20 system is intended for dermatological procedures.
The V-ST Handpiece is indicated for the temporary relief of minor muscle aches and pain, temporary relief of muscle spasm, and temporary improvement of local blood circulation.
The V-IPL Handpiece with wavelengths 415-1200nm (with 5 different filters) is indicated for the treatment of:
- Moderate inflammatory acne vulgaris.
- Benign pigmented epidermal lesions including dyschromia, hyperpigmentation, melasma, and ephelides (freckles).
- Cutaneous lesions including warts, scars and striae.
- Benign cutaneous vascular lesions including port wine stains, hemangiomas, facial, truncal and leg telangiectasias, rosacea, erythema of rosacea, angiomas, poikiloderma of Civatte and venous malformations.
- Removal unwanted hair. It is also intended for permanent reduction in unwanted hair. Permanent hair reduction is defined as the long-term stable reduction in the number of hairs regrowing when measured at 6, 9, and 12 months after the completion of a treatment regimen.
The Viora V20 system is a RF and IPL multi application platform with two available treatment Handpieces:
V-ST Handpiece: Bi polar radiofrequency (RF) Handpieces
V-IPL Handpiece: Intense Pulsed Light (IPL) Handpiece
The Main Unit (console) provides the operational and safety function of the system.
The operator can modify the treatment parameters to achieve specific tissue effects depending on individual patient's skin condition and anatomical structure. The Foot Switch is used for system activation.
The provided text describes the Viora V20 System, a medical device, and its substantial equivalence to a predicate device (Viora V-total, K133837). However, the document does not contain the kind of detailed information typically found in a study demonstrating how a device meets specific acceptance criteria based on performance data.
Instead, this document is a 510(k) summary for the FDA, focusing on establishing substantial equivalence to a previously cleared device. It asserts that because the V20 system's technological parameters are "well within" the cleared Viora V-total system and the handpieces are "exactly the same," animal and clinical studies are not required to determine its safety and efficacy.
Therefore, many of the requested categories of information cannot be extracted from this document, as a standalone performance study with detailed acceptance criteria and results is not presented here.
Here's a breakdown based on the available information:
1. A table of acceptance criteria and the reported device performance:
Acceptance Criteria (Not explicitly stated as such, but inferred from the claims) | Reported Device Performance (as stated in the document) |
---|---|
Intended Use Equivalence: The V20 system should have the same intended use as the predicate device. | The V20 system and its predicate have the same intended use. |
Indications for Use Equivalence: The V20 system's indications for use should be the same as the predicate device. | The V20 system and its predicate have the same indications for use (for ST and IPL Handpieces). |
Technological Features Equivalence: The V20 system should have similar technological features to the predicate device. | The V20 system and the predicate device have similar technological features. The V-ST and V-IPL Handpieces are exactly the same as the cleared Viora V-total ST and IPL Handpieces (K133837). |
Safety and Effectiveness (No New Issues): Any differences in software and system design should not raise new issues of safety and effectiveness. | "Any differences in the software and in the system design do not raise any new issues of safety and effectiveness, as was verified by performance testing." |
Compliance with Standards: The V20 system must comply with relevant medical electrical equipment standards. | The V20 system complies with IEC 60601-1, IEC 60601-1-2, IEC 60601-2-2, and IEC 60601-2-57. |
Effectiveness (Bench Testing): Bench testing should demonstrate the V20 system is as safe and effective as the cleared predicate devices. | "Bench testing demonstrated that the V20 system is as safe and effective as the cleared predicate devices." |
2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective):
- Not provided. The document states that "animal and clinical studies are not required" to determine safety and efficacy due to technological equivalence. The mention of "performance testing" and "bench testing" does not specify sample sizes or data provenance.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable / Not provided. Since clinical studies or specific performance evaluations with a "test set" and "ground truth" (in the typical sense of expert review of patient data) were deemed unnecessary for this 510(k) submission, this information is absent.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Not applicable / Not provided. See point 3.
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 an aesthetic and dermatological treatment system (IPL/RF), not an AI-powered diagnostic or assistive tool for human readers. Therefore, an MRMC study comparing human reader performance with and without AI assistance is not relevant to this device.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. This device is a physical system with handpieces for treatment, not an algorithm.
7. The type of ground truth used (expert concensus, pathology, outcomes data, etc):
- Not applicable / Not provided. The basis for clearance relies on substantial equivalence to a predicate device, which implies that the prior device's established safety and efficacy serve as the "ground truth" for the current device's performance claims. No new, specific ground truth creation for the V20 system itself is detailed.
8. The sample size for the training set:
- Not applicable / Not provided. This document does not describe the development of a machine learning algorithm or an AI model that would require a training set.
9. How the ground truth for the training set was established:
- Not applicable / Not provided. See point 8.
In summary: The provided text is a regulatory submission focused on substantial equivalence. It asserts that the V20 system is substantially equivalent to a previously cleared device (Viora V-total K133837) due to identical intended use, indications for use, and handpiece technology, along with compliance with performance standards and positive bench testing. It explicitly states that clinical studies were not required for this determination, which means the detailed performance study information requested is not present in this document.
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