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510(k) Data Aggregation
(44 days)
Yarlap II
The device is intended to provide electrical stimulation and neuromuscular re-education for the purpose of rehabilitation of weak pelvic floor muscles for the treatment of stress, urge and mixed urinary incontinence in women and to maintain urinary continence in women.
The Applicant device, YARLAP II, Model ECS323P, is a portable precision Class II device housed in a sturdy lightweight shock-and water-resistant cabinet with stylus. The device is battery-powered with a full color touch screen Liquid Crystal Display (LCD) and offers the user a choice of six pre-set Neuro-Muscular Electrical Stimulation (NMES) programs with four pre-set biofeedback response-based sound-enriched games. The NMES programs in the Applicant device are Work/Rest modes of operation and identical to the programs in the Predicate. The four biofeedback programs in the Applicant device are to facilitate user graduation from "muscle stimulation" to patient-initiated muscle contractions (i.e., "true exercise"). Neither the Applicant device nor the Predicate have a TENS program. Bluetooth in the Applicant device facilitates gaming and therein patientinitiated "exercise" by permitting use of a larger external Bluetooth compatible display (e.g., computer screen or television). The Bluetooth signal is out-going only. Any external Bluetooth-capable display is optional and is not supplied with the unit. The Applicant device is supplied with a vaginally inserted electrode used with the device to stimulate the muscle of the female pelvic floor (the electrode, essential technology and intended use are identical to the Predicate: K141643). The Applicant device is supplied with a biofeedback reference lead wire with a skin electrode(s). The Applicant device control unit connects directly to the vaginal electrode and reference wire by cable and plug (design extant for the industry).
This document is a 510(k) summary for a medical device called "YARLAP II, Model ECS323P", a nonimplanted electrical continence device with biofeedback. The purpose of this document is to demonstrate "substantial equivalence" of the YARLAP II device to a previously cleared predicate device, "Yarlap, Model ECS 323 (K141643)".
The document does not describe a clinical study for the YARLAP II device to explicitly prove it meets acceptance criteria with quantitative results. Instead, it argues for substantial equivalence based on the device's technical characteristics, unchanged indications for use, and a risk assessment.
Here's an breakdown of the provided information, addressing your questions where possible:
1. A table of acceptance criteria and the reported device performance
The document does not provide explicit "acceptance criteria" in terms of performance metrics (like sensitivity, specificity, accuracy) from a clinical study for the YARLAP II. Instead, the "acceptance criteria" are implied by demonstrating substantial equivalence to the predicate device, Yarlap (K141643).
The performance data presented is a comparison of the output parameters of the YARLAP II (Applicant Device) to the predicate Yarlap (Predicate Device) for the Neuro-Muscular Electrical Stimulation (NMES) programs (programs 1-6). The "reported device performance" are these matched parameters.
Device Substantial Equivalence and Safety of the Applicant and Predicate Programs (Section 5.0, Table 3 and 4) | Predicate Device (K141643) Performance | Applicant Device (K160773) Performance | Acceptance Criteria (Implied) |
---|---|---|---|
NMES Programs (1-6) Output Parameters | Identical to Predicate | Identical to Predicate | Must be identical to Predicate for NMES |
Frequency (Hz) | 10 Hz - 35Hz, program dependent | 10 Hz - 35Hz, program dependent | Same as Predicate |
Pulse Width (μS) | 200 μS - 250 μS, program dependent | 200 μS - 250 μS, program dependent | Same as Predicate |
Max Output Current peak @ 500 Ohms | 80mA +0/- 8% | 80mA +0/- 8% | Same as Predicate |
Max Output Current peak @ 2K Ohms | 50mA +/-10% | 50mA +/-10% | Same as Predicate |
Net Charge @ 500 ohms (μC per pulse) | Zero, Asymmetrical DC zero (Transformer output) | Zero, Symmetrical DC zero (Transformer output) | Maintain zero net charge |
Max Phase Charge, (μC) at 500 ohms | 20 μC (80mA x 250 μS) | 20 μC (80mA x 250 μS) | Same as Predicate |
Max Current Density (mA/cm²) Vaginal | 12.5 mA/sq. cm (Surface = 6.4 cm²) | 12.5 mA/sq. cm (Surface = 6.4 cm²) | Same as Predicate |
Max Current Density (mA/cm²) 2 X 2 | 3.2 mA/sq. cm (Surface = 25 cm²) | 3.2 mA/sq. cm (Surface = 25 cm²) | Same as Predicate |
Max Power Density, (W/cm²) at 500 ohms | 3.5 mW/sqcm (at max frequency of 35Hz pulse width 200μS and current of 80mA) | 3.5 mW/sqcm (at max frequency of 35Hz pulse width 200μS and current of 80mA) | Same as Predicate |
Biofeedback Programs (7-10) | None | Added (0.3-2000 μV) | - |
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 does not describe a clinical test set or study with human participants for the YARLAP II alone. The "study" proving the device meets criteria is primarily a technical and risk assessment comparison to a predicate device. There is no mention of a test set sample size, country of origin, or whether any data was retrospective or prospective in a clinical sense.
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)
Not applicable. As no clinical test set is described, there's no mention of experts determining ground truth for such a set. The risk assessment was prepared by an "independent firm" and reviewed by "independent commentators," but their specific qualifications beyond being independent are not detailed.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. No clinical test set is described.
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 electrical stimulation device, not an AI diagnostic tool intended to assist human "readers."
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This question is geared towards AI/software performance. While the YARLAP II has software and biofeedback, it's a physical neuromodulation device where the "human-in-the-loop" is the user. The document doesn't discuss algorithm performance in a standalone AI context. It states the biofeedback feature is an accessory that supplements the performance of the parent device (NMES programs).
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
Not applicable. For the NMES programs, the "ground truth" is that the device's electrical output parameters are identical to the predicate. For the biofeedback, the "ground truth" is that it provides a new way of using the device without changing its intended use, and its performance is defined under 21 CFR 882.5050 (which defines biofeedback devices as accessories). There's no clinical "ground truth" needed in this substantial equivalence argument for the YARLAP II modifications.
8. The sample size for the training set
Not applicable. This is not an AI/machine learning device that requires a training set in the conventional sense.
9. How the ground truth for the training set was established
Not applicable. As above, this is not an AI/machine learning device.
In summary:
This 510(k) notification focuses on demonstrating that the YARLAP II, Model ECS323P, is substantially equivalent to a previously cleared predicate device. The core of the "study" proving it meets acceptance criteria is a technical comparison of specifications and a risk assessment, rather than a clinical trial with performance metrics. The changes in the YARLAP II (e.g., full-color screen, Bluetooth, biofeedback) are presented as modifications that do not affect the intended use or fundamental scientific technology, and thus do not raise new questions of safety or effectiveness when compared to the established predicate. The "acceptance criteria" are effectively met by demonstrating these technical and functional equivalences, particularly the identical output parameters for the therapeutic NMES programs.
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