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510(k) Data Aggregation

    K Number
    K973266
    Device Name
    Z DEQ-II
    Manufacturer
    Date Cleared
    1997-09-23

    (25 days)

    Product Code
    Regulation Number
    874.3300
    Reference & Predicate Devices
    N/A
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The indication for use of the air conduction hearing aids in this submission is to amplify sound for individuals with impaired hearing. The devices are indicated for individuals with losses in the following category(ies). (Check appropriate space(s));
    Severity:
    _1. Light
    _2. Mild
    _3. Moderate
    _4. Severe
    _5. Profound
    Configuration:
    ✓1. High Frequency - Precipitously Sloping
    ✓2. Gradually Sloping
    ✓3. Reverse Slope
    ✓4. Flat
    _5. Other Variable to 1-4
    Other
    ✓1. Low tolerance To Loudness
    _2.
    _3.

    Device Description

    Not Found

    AI/ML Overview

    This is a fascinating challenge, as the document provided is a 510(k) clearance letter from the FDA, and as such, it does not contain the acceptance criteria or study details in the way a modern regulatory submission document (like a more detailed 510(k) summary or an IDE report) would.

    A 510(k) clearance letter primarily states that the device is "substantially equivalent" to a predicate device. For devices cleared in 1997, particularly a Class I device like a hearing aid (Procode: 77 ESD), the level of detail regarding performance studies and acceptance criteria in the public domain or even the initial submission was significantly less prescriptive than it is today, especially for AI/ML-driven devices.

    Therefore, for aspects like acceptance criteria, sample sizes, expert qualifications, adjudication methods, MRMC studies, standalone performance, and ground truth methodologies, the document is largely silent because these were not explicitly required to be detailed in this type of public clearance letter at the time. The FDA's decision was based on a comparison to a predicate, assuming the new device performs similarly and is as safe and effective.

    However, I can interpret what would typically be inferred for a device like this in 1997, and explain why the information isn't directly present in this specific document.


    Analysis of the Provided Document

    The provided document is an FDA 510(k) clearance letter for the "2DEQ-II Hearing Aid" (K973266).

    • Device Type: Air Conduction Hearing Aid
    • Regulatory Class: I (21 CFR 874.3300)
    • Procode: 77 ESD
    • Date of Clearance: September 23, 1997

    The core of a 510(k) clearance, especially for a Class I device in 1997, is the demonstration of "substantial equivalence" to a legally marketed predicate device. This means the new device has the same intended use and technological characteristics as the predicate, or if it has different technological characteristics, it does not raise different questions of safety and effectiveness, and is as safe and effective as the predicate.

    Crucially, this letter does NOT describe a specific study proving the device meets specific acceptance criteria set out for it in a clinical trial. Instead, it attests that the device is substantially equivalent to a predicate.

    Given this context, I will address your points by explaining why the information is not present and then inferring what might have been considered for a 1997 hearing aid submission, though this is speculative based on common practice, not directly from the document.


    Response to Specific Information Requests:

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

      Performance Metric (Hypothetical for a Hearing Aid)Acceptance Criteria (Hypothetical)Reported Device Performance (Not in document)Explanation for Missing Data
      No specific performance metrics or acceptance criteria are detailed in this 510(k) clearance letter. The letter confirms "substantial equivalence" to a predicate device. For a hearing aid, this would typically involve demonstrating similar acoustic performance (e.g., gain, frequency response, output) to the predicate and safety (e.g., biocompatibility, electrical safety, maximum output levels to prevent further hearing damage).Based on "substantial equivalence" to a predicate hearing aid. Performance would be expected to fall within similar ranges and meet international and national standards (e.g., ANSI standards for hearing aids available at the time).Not reported in this letter. A 510(k) summary (a separate public document, if available and from this era) might have contained some summary data, but the clearance letter itself doesn't.The 510(k) clearance for a Class I device in 1997 primarily confirmed substantial equivalence to a predicate, rather than detailing specific de novo performance studies against predefined acceptance criteria. Clinical studies were often not required for this type of submission unless there was a significant new technology or new intended use that raised different questions of safety/effectiveness.
    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

      • Not Applicable / Not Provided: The document does not describe a clinical "test set" or a performance study in the way modern AI/ML device submissions would. For a 1997 hearing aid, substantial equivalence would likely have been supported by a combination of:
        • Bench testing: Acoustic measurements (gain, frequency response, output limits, distortion) compared to the predicate and relevant standards.
        • Technical comparison: Documentation showing the new device's design, materials, and technological characteristics were similar to the predicate.
        • Limited clinical data (if any): If performed, this would involve a small group of hearing-impaired individuals assessing comfort, sound quality, and perhaps speech understanding in quiet, but not a large-scale efficacy trial with a formal "test set" as one would expect for an AI/ML device. Such data was rarely detailed in the public clearance letter itself.
      • Data Provenance: Not specified. Any data would likely have been generated by the manufacturer (Electone, Inc.) in the US or wherever their R&D/manufacturing facilities were located.
    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 / Not Provided: As no specific "test set" for ground truth establishment is described, this information is not present. For a hearing aid, "ground truth" relates to the user's perception of sound quality, comfort, and hearing improvement, often assessed indirectly through audiological evaluations and patient feedback. This is distinct from establishing ground truth for diagnostic imaging.
      • Any clinical input would come from audiologists or otolaryngologists, but their role would be in evaluating patient outcomes, not establishing a "ground truth" for an algorithm.
    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

      • Not Applicable / Not Provided: This concept of adjudication for a test set is not relevant to a 1997 hearing aid 510(k) submission based on substantial equivalence. This method is typically used in diagnostic imaging studies to resolve discrepancies among expert readers and establish a robust ground truth for algorithmic performance evaluation.
    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

      • No: This device is a traditional hearing aid, not an AI/ML diagnostic tool. Therefore, an MRMC comparative effectiveness study involving human "readers" (in the diagnostic sense) and AI assistance would not have been conducted or required. The "human" in the loop is the hearing aid user, aided by the device's amplification.
    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

      • Not Applicable: This device is a hearing aid, which by its nature is a "human-in-the-loop" device (the user wears it). It does not have a "standalone algorithm" that performs a diagnostic or prognostic task independent of a human. While the internal processing of the hearing aid (e.g., sound amplification, noise reduction algorithms) operates without conscious human input on a moment-to-moment basis, its purpose is to interact with and enhance human hearing.
    7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)

      • Not Applicable / Not Directly Stated: For a hearing aid, "ground truth" is typically tied to the subjective experience of the user and objective audiological measures. This might involve:
        • Audiological evaluations: Pre- and post-fitting audiograms, speech recognition in quiet and noise tests.
        • Patient reported outcomes (PROs): Questionnaires on perceived benefit, sound quality, and listening effort.
        • Expert assessment: Audiologists evaluating the fit, programming, and user satisfaction.
      • These are not "ground truths" in the sense of a definitive diagnosis like pathology but rather assessments of the device's functional benefit.
    8. The sample size for the training set

      • Not Applicable / Not Provided: This device would not have a "training set" in the context of AI/ML. Its design and "programming" (e.g., setting the gain, frequency response curves) are based on acoustic engineering principles and established audiology.
    9. How the ground truth for the training set was established

      • Not Applicable: As there is no "training set" in the AI/ML sense, there is no ground truth established for it. The performance characteristics of a hearing aid are calibrated and verified through bench testing and, optionally, limited clinical evaluation against established audiological outcomes.

    Conclusion from the Document:

    The FDA 510(k) clearance letter for the 2DEQ-II Hearing Aid (K973266) is a regulatory document affirming "substantial equivalence" to a predicate device. It is a testament to the regulatory landscape of 1997 for Class I devices, where the focus was on demonstrating that a new device was as safe and effective as existing legally marketed devices, primarily through comparison of technical characteristics and existing standards. It does not contain the detailed performance study information, acceptance criteria, ground truth methodologies, or AI/ML-specific data that would be found in modern regulatory submissions for AI/ML-driven medical devices.

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