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510(k) Data Aggregation

    K Number
    K193288
    Device Name
    Koya Ripple
    Manufacturer
    Date Cleared
    2020-06-16

    (202 days)

    Product Code
    Regulation Number
    870.5800
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Koya Dayspring system is a prescription only wearable compression system that is intended for use in a clinic or home setting by medical professionals and patients who are under medical supervision for the following:

    • Lymphedema
    • Primary lymphedema
    • Post mastectomy edema
    • Edema following trauma and sports injuries
    • Post immobilization edema
    • Venous insufficiency
    • Reducing wound healing time
      The Koya Dayspring system is developed on a wearable compression technology platform, which is designed to provide mobility for patients.
    Device Description

    The Koya Dayspring™ system is powered by an active smart compression technology that is calibrated, instant-acting, and silent. This technology uses a Nickel Titanium (Ni-Ti) shape-memory alloy programmed by a controller system. A disposable stockinette is worn as an accessory under the device to prevent direct patient contact with the device is wrapped around the patient's arm so that the device fits snugly. The device has up to 16 independently controlled sections in each arm. The controller can be programmed to provide sequential compression therapy to the affected area over a range of 0-100 mmHg. The device is powered by a rechargeable Lithium-ion battery pack. The device was developed to provide patients with untethered access and a functional range of motion and mobility while treating chronic lymphedema.

    AI/ML Overview

    The Koya Dayspring is a wearable compression system intended for lymphedema and related conditions. The FDA determined it to be substantially equivalent to the Flexitouch Plus System.

    No specific acceptance criteria related to a study of device performance for diagnostic use (like sensitivity, specificity, accuracy) are mentioned in this document. The provided information focuses on engineering and regulatory testing to ensure device safety and functional equivalence to a predicate device, rather than a clinical performance study with defined acceptance criteria for diagnostic efficacy.

    Here's a breakdown of the studies conducted, as per the provided text, and how they contribute to demonstrating the device's acceptability:

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

    As stated above, this document does not present clinical performance data against acceptance criteria for diagnostic outputs. Instead, it describes engineering and safety testing.

    Test CategoryAcceptance Criteria (Implied)Reported Device Performance
    Sterilization & Shelf-life TestingComponents should not deteriorate; battery shelf-life adequate.Device non-sterile, components unlikely to deteriorate with age (except Li-ion battery). Battery shelf-life and charge/discharge testing data provided and found acceptable (implied).
    Biocompatibility Testing (Stockinette Liner)Safe for intact skin contact (<24 hrs exposure): non-cytotoxic, non-sensitizing, non-irritating.Passed cytotoxicity (ISO 10993-5), sensitization (ISO 10993-10), and irritation (ISO 10993-10) studies. All results acceptable, material safe for intended use.
    Electrical Safety and Electromagnetic Compatibility (EMC)Compliance with relevant electrical safety and EMC standards.Adheres to ANSI AAMI ES60601-1:2005/(R)2012 And A1:2012, IEC 60601-1-2 Ed. 4.0, IEC 60601-1-11 Ed. 2.0, IEC 62133-2 Ed. 1.0.
    Software Verification and Validation TestingCompliance with software development and cybersecurity guidelines.Performed in accordance with IEC 62304 Ed. 1.1 and relevant FDA Guidance documents.
    Mechanical and Acoustic TestingApplied pressure comparable to predicate device; transport integrity maintained.Benchtop mechanical testing showed comparable pressure to predicate device. Transport shipping testing conducted in accordance with ASTM D4169.

    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 primarily describes benchtop engineering and safety tests, not clinical studies involving patient data.
    • For biocompatibility, electrical safety, software V&V, and mechanical testing, the "sample size" would refer to the number of devices or components tested. This specific number is not provided in the summary.
    • Data provenance is not specified, but these are typically prospective engineering tests conducted in a lab setting rather than clinical data from a specific country.

    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)

    • This information is not applicable as no "ground truth" for diagnostic purposes or clinical interpretation by experts was established in the context of this submission. The tests performed are objective engineering measures (e.g., pressure output, electrical safety, material biocompatibility).

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    • This is not applicable as there was no expert review or adjudication of a test set for diagnostic performance.

    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

    • A MRMC comparative effectiveness study was not done. This device is a therapeutic compression system, not an AI-assisted diagnostic tool for human readers.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    • This is not applicable as the Koya Dayspring is a physical medical device delivering compression therapy, not an algorithm, and its performance is assessed directly through its physical output and safety features.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    • For the engineering and safety tests, the "ground truth" is defined by established engineering standards, biocompatibility requirements, and direct physical measurements (e.g., actual pressure output compared to expected output, current leakage within limits, material cytotoxicity results). There is no "expert consensus," "pathology," or "outcomes data" in the traditional clinical sense for these types of tests.

    8. The sample size for the training set

    • This is not applicable. The Koya Dayspring is not an AI/ML device that requires a training set of data for an algorithm.

    9. How the ground truth for the training set was established

    • This is not applicable as there is no training set for this device.
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