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510(k) Data Aggregation

    K Number
    K243775
    Date Cleared
    2025-07-18

    (221 days)

    Product Code
    Regulation Number
    890.5900
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    ITH

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The DRX9000-SL True Non-Surgical Spinal Decompression System provides a primary treatment modality for the management of pain and disability for patients suffering with incapacitating low back pain and sciatica. It is designed to apply spinal decompressive forces to compressive and degenerative injuries of the spine. It has been found to provide relief of pain and symptoms associated with herniated discs, bulging or protruding intervertebral discs, degenerative disc disease, posterior facet syndrome and sciatica.

    Device Description

    The DRX9000-SL True Non-Surgical Spinal Decompression System provides accurately controlled tensions designed to relax and confuse paraspinal muscles and allow distractive forces to decompress intervertebral spinal disc space. The user interface provided by the treatment computer constantly updates a servo-amplifier controlling a servo-motor to immediately and safely apply forces as determined by qualified healthcare personnel. Load-cell feedback is utilized to further verify and adjust tensile forces, allowing for variations in patient posture and outside forces such that continuous and smooth tension is experienced by the patient.

    An upper chest harness and a lower pelvic harness are used to help distribute the applied forces evenly. Once in place, the patient is slowly reclined to a horizontal position. Following the physician's orders, the therapist localizes the pain, makes any adjustments and directs the treatment to the proper area. The DRX9000-SL True Non-Surgical Spinal Decompression System helps to mobilize the troubled disc segment without introducing further damage to the spine.

    The patient safety switch is held by the patient who at any time and for any reason may quickly pause any tensile forces. The patient safety switch is monitored and executed by two redundant systems, which will gradually reduce the tension to zero to stop the treatment and after a 5 second delay directly disable the treatment motor.

    The emergency stop button is accessible to the operator who at any time and for any reason may quickly pause any tensile forces. The emergency stop button is monitored and executed by two redundant systems, which will gradually reduce the tension to zero to stop the treatment and after a 5 second delay directly disable the treatment motor.

    Integral to effective spinal decompression and included in the device are continuous load-cell tensile feedback into the treatment computer, dedicated and matched servo-amplifier and servo-motor, smoothly modulated cyclic tension application (high and low tension plateaus transitioned into via non-linear tension change), two segment (upper and lower) textile patient harness, patient safety switch, and free-floating lower body mattress. The free-floating lower body mattress allows the interdiscal segments of the lumbar spine to decompress at their own rate. As tension is cycled, the lower body can extend independent of the upper body which is held in place via an upper body textile patient harness. The treatment bed and textile harness allow the patient to relax completely and require no conscious exertion on the part of the patient. Total patient relaxation encourages paraspinal muscle relaxation from both a physical and psychological standpoint and is a key to spinal decompression.

    AI/ML Overview

    The provided FDA 510(k) clearance letter and summary for the DRX9000-SL True Non-Surgical Spinal Decompression System do not contain information related to acceptance criteria for an AI device, nor any study that proves an AI device meets such criteria.

    The submission is for a medical device that applies spinal decompressive forces, and it primarily focuses on demonstrating substantial equivalence to a predicate device (DRX9000 True Non-Surgical Spinal Decompression System) through non-clinical testing of electrical safety, EMC, usability, risk management, biocompatibility, and software.

    Therefore, I cannot provide the requested information, as the input document does not pertain to an AI device or a study with typical AI-related acceptance criteria.

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    K Number
    K243366
    Date Cleared
    2025-06-18

    (233 days)

    Product Code
    Regulation Number
    890.5900
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    ITH

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The DRX9000C-SL Cervical Spinal Decompression System provides a program of treatments for relief from pain for those patients suffering with neck pain. It is designed to apply spinal decompressive forces to the spine. Conditions that may be treated include neck pain associated with herniated discs, protruding intervertebral discs, degenerative disc disease, and posterior facet syndrome.

    Device Description

    The DRX9000C-SL Cervical Spinal Decompression System provides accurately controlled tensions designed to relax and confuse paraspinal muscles and allow distractive forces to decompress intervertebral spinal disc space. The user interface provided by the treatment computer constantly updates a servo-amplifier controlling a servo-motor to immediately and safely apply forces as determined by qualified healthcare personnel. Load-cell feedback is utilized to further verify and adjust tensile forces, allowing for variations in patient posture and outside forces such that continuous and smooth tension is experienced by the patient.

    A headpiece harness is used to help distribute the applied forces evenly. Once in place, the patient is slowly reclined to a horizontal position. Following the physician's orders, the therapist localizes the pain, makes any adjustments and directs the treatment to the proper area. The DRX9000C-SL Cervical Spinal Decompression System helps to mobilize the troubled disc segment without introducing further damage to the spine.

    The patient safety switch is held by the patient who at any time and for any reason may quickly pause any tensile forces. The patient safety switch is monitored and executed by two redundant systems, which will gradually reduce the tension to zero to stop the treatment and after a 5 second delay directly disable the treatment motor.

    The emergency stop button is accessible to the operator who at any time and for any reason may quickly pause any tensile forces. The emergency stop button is monitored and executed by two redundant systems, which will gradually reduce the tension to zero to stop the treatment and after a 5 second delay directly disable the treatment motor.

    Integral to effective spinal decompression and included in the device are continuous load-cell tensile feedback into the treatment computer, servo-amplifier and servo-motor, smoothly modulated cyclic tension application (high and low tension plateaus transitioned into via non-linear tension change), headpiece harness, patient safety switch, and mattress.

    AI/ML Overview

    The provided FDA clearance letter for the DRX9000C-SL Cervical Spinal Decompression System does not contain information regarding detailed acceptance criteria for device performance with specific metrics, nor does it describe a clinical study of the device proving it meets acceptance criteria.

    Instead, the submission focuses on demonstrating substantial equivalence to a predicate device (DRX5000) primarily through non-clinical testing and comparison of technical characteristics.

    Here's a breakdown of the requested information based on the provided text, highlighting what is not present:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not specify quantifiable acceptance criteria for device performance (e.g., specific pain reduction percentages, success rates, or ranges of therapeutic effectiveness). It broadly states the device "provides a program of treatments for relief from pain" and is "designed to apply spinal decompressive forces."

    Acceptance CriteriaReported Device Performance
    Not specified in the document.Not specified in the document in measurable terms of clinical outcome.

    The most direct "performance" metrics described relate to the device's capabilities rather than clinical outcomes:

    • Traction Force: Can be varied between 0 – 50lbs pull. (This is a capability, not a clinical outcome or acceptance criterion).
    • Treatment Time: Up to 30 – 45 minutes. (Again, a capability).

    2. Sample Size Used for the Test Set and Data Provenance

    No clinical test set is described or utilized for proving device performance. The submission explicitly states: "Clinical testing is not required for this submission. The non-clinical performance testing described above is sufficient to support substantial equivalence of the subject device to the predicate device."

    3. Number of Experts Used to Establish Ground Truth and Qualifications

    Not applicable. No clinical test set requiring expert ground truth establishment was conducted or referenced.

    4. Adjudication Method for the Test Set

    Not applicable. No clinical test set requiring adjudication was conducted or referenced.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    No MRMC comparative effectiveness study was done. The document explicitly states clinical testing was not required. Therefore, no effect size of human readers improving with AI vs. without AI assistance can be provided. This device is a mechanical traction system, not an AI-assisted diagnostic or treatment planning tool.

    6. Standalone (Algorithm Only) Performance

    Not applicable. This is a mechanical device, not an algorithm, so a "standalone" or "algorithm only" performance assessment is irrelevant in this context. Its function is to apply physical forces, controlled by software, but not to provide diagnostic or interpretative output like an algorithm.

    7. Type of Ground Truth Used

    Not applicable in the sense of clinical outcome ground truth. The "ground truth" for this submission revolves around demonstrating that the device's technical specifications and safety standards meet regulatory requirements and are substantially equivalent to a predicate device. This is achieved through:

    • Engineering and Safety Standard Conformance: Verification that the device adheres to standards like IEC 60601-1 (electrical safety), IEC 60601-1-2 (EMC), IEC 60601-1-6 & IEC 62366-1 (usability), ISO 14971 (risk management), ISO 10993-1 (biocompatibility), and IEC 62304 (software life cycle processes).
    • Predicate Device Comparison: Establishing substantial equivalence by comparing technological characteristics and intended use to the DRX5000 (K023160).

    8. Sample Size for the Training Set

    Not applicable. This device undergoes non-clinical engineering and safety testing, not machine learning model training.

    9. How the Ground Truth for the Training Set Was Established

    Not applicable. No training set for a machine learning model is involved.


    In summary, the FDA clearance for the DRX9000C-SL Cervical Spinal Decompression System was based on non-clinical testing demonstrating conformance to recognized safety and performance standards, and a comparison of its technological characteristics and intended use to a legally marketed predicate device (DRX5000) to establish substantial equivalence. The submission explicitly states that clinical testing was not required.

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    K Number
    K214037
    Date Cleared
    2024-02-22

    (791 days)

    Product Code
    Regulation Number
    890.5900
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    ITH

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Back on Trac (BOTGEN1) and Cervi-Trac Systems are in professional healthcare facilities, to relieve pressures on structures that may be causing pain of skeletal or muscular origin (cervical, thoracic, lumbar, hip, shoulder).

    Back on Trac
    The Back on Trac (BOTGEN1) is intended for use to relieve pressures on structures that may be causing pain of skeletal or muscular origin (cervical, thoracic, lumbar, hip, shoulder)". The device may be used to manage and reduce pain associated with the following conditions:

    • facet syndrome,
    • herniated disc,
    • protruding disc,
    • extruded disc,
    • sciatica,
    • spondylosis (degenerative disc disease & facet syndrome),
    • joint pain.

    Vibration and heat are available options that can be utilized with the Back on Trac (BOTGEN1) at the discretion of the healthcare professional. When activated, the vibration mode can provide muscle relaxation and temporary relief of minor aches and pains. The heat mode, when activated, can provide temporary relief of minor aches and pains. The local warmth temporarily stimulates local blood circulation in your lower back.

    Cervi-Trac
    The Cervi-Trac is intended for use as an accessory to the Back on Trac (BOTGEN1) to relieve pressures on structures that may be causing pain of skeletal or muscular origin. The Cervi-Trac accessory focuses specifically on the cervical region.

    Device Description

    The Ergo-Flex Technologies Systems that are the subject of this premarket notification are prescription use only and are intended for use by licensed, qualified healthcare professionals, such as physicians, chiropractors, physical therapists, etc.

    Ergo-Flex Back on Trac System:
    The (BOTGEN1) is comprised of a reclinable therapeutic cushioned chair with back support portion and a second lower back, upper and lower leg support section that is movable in an axial direction with respect to the back support section and is also arcuately movable about a pivot axis that is perpendicular to the axial direction. The chair includes remotely controlled linear actuators to control the relative movement of the different sections of the device.

    Ergo-Flex Cervi-Trac:
    The Cervi-Trac (CT) is an accessory to the Back on Trac (BOTGEN1) that focuses specifically on the cervical region. The patient is not restrained by the Back on Trac arm bolsters, therefore lumbar traction is not activated by the Cervi-Trac during this therapy.

    AI/ML Overview

    This document is a 510(k) summary for the Ergo-Flex Technologies Back on Trac (BOTGEN1) and Cervi-Trac devices. It demonstrates substantial equivalence to a predicate device, as opposed to proving the device meets specific performance criteria through a clinical study. Therefore, the information requested regarding acceptance criteria, study design, ground truth establishment, and expert involvement is not applicable in the context of this document.

    Here's why and what information is provided:

    • 510(k) Premarket Notification: This is a regulatory pathway used to demonstrate that a new medical device is "substantially equivalent" to a legally marketed predicate device. It generally relies on non-clinical performance data and a comparison of technological characteristics, rather than de novo clinical efficacy studies with specific acceptance criteria that would typically be required for novel devices or those seeking a new indication.

    Based on the provided document, here's what can be stated regarding the requested categories:

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

      • Not Applicable. This document does not present a table of acceptance criteria and reported device performance in the way a clinical trial or performance study would. The acceptance is based on demonstrating "substantial equivalence" to a predicate device, which is achieved by showing similar intended use and technical/functional characteristics, and adherence to relevant consensus standards.
      • Instead, the document provides a "Comparison of the IFU and Technical Specifications and Performance Characteristics" (Table 1 on page 9) between the subject device and the predicate device. This table highlights similarities and differences in parameters like intended use, environment, treatment areas, electrical safety, EMC, and traction mechanism.
      • For performance, it states: "Performance testing on the Back on Trac (BOTGEN1) and Cervi-Trac Systems demonstrated the design, operational and functional parameters and safety features met the established specifications for each device and demonstrate performance substantial that is equivalent to the predicate device." However, specific numerical performance metrics are not listed as "acceptance criteria" but rather as "specifications" met.
    2. Sample sized used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective):

      • Not Applicable. The submission did not involve clinical testing to demonstrate substantial equivalence. Therefore, there are no "test sets" of patient data in the typical sense for clinical performance.
      • The "testing" mentioned refers to non-clinical performance testing and compliance with recognized consensus standards (e.g., IEC 60601-1 for electrical safety, ISO 14971 for risk management). These are tests on the device itself, not on patient samples.
      • Data provenance for such non-clinical testing is typically internal company data or reports from certified testing facilities, not patient data from specific countries or study designs.
    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. Since no clinical test set with patient data was used to establish "ground truth" for efficacy or diagnostic performance, there were no experts establishing such ground truth.
    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:

      • Not Applicable. No clinical test set requiring adjudication was used.
    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. No MRMC study was conducted. This device is "Power traction equipment," which is a physical therapy device, not an AI or diagnostic imaging device that would typically involve human readers or AI assistance in interpretation.
    6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done:

      • Not Applicable. This is not an algorithm-based device.
    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

      • Not Applicable. No ground truth for clinical efficacy or diagnostic accuracy was established as part of this 510(k) submission. Substantial equivalence is based on engineering and performance characteristics compared to a predicate device, and compliance with safety standards.
    8. The sample size for the training set:

      • Not Applicable. As this is not an AI/machine learning device, there is no "training set."
    9. How the ground truth for the training set was established:

      • Not Applicable. There is no training set for an AI/machine learning model.

    In summary, the document states:

    • Clinical Performance: "Not applicable. Clinical testing was not provided to demonstrate the substantial equivalence of the Back on Trac (BOTGEN1) and Cervi-Trac." (Page 12)
    • Non-Clinical Performance: The devices underwent "100% performance testing and Quality Assurance inspection" by the manufacturer, and "Performance testing...demonstrated the design, operational and functional parameters and safety features met the established specifications for each device and demonstrate performance substantial that is equivalent to the predicate device." (Page 12).
    • The device was evaluated and tested by independent certified testing facilities in conformance with various consensus standards related to electrical safety (IEC 60601-1), electromagnetic compatibility (IEC 60601-1-2), usability (IEC 60601-1-6, IEC 62366-1), risk management (ISO 14971), and biocompatibility (IEC 10993). (Page 13)

    This 510(k) clearance is based on the comparison to a legally marketed predicate device (Chattanooga Group's Triton/Tru-Trac/TX/Triton DTS Traction, K053223) and compliance with relevant safety and performance standards for mechanical devices, not on the demonstration of clinical efficacy through formal acceptance criteria and studies with human data.

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    K Number
    K222912
    Device Name
    c1Trac
    Date Cleared
    2023-05-16

    (232 days)

    Product Code
    Regulation Number
    890.5900
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    ITH

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    clTrac is intended to provide relief for the management of pain and symptoms from a variety of pressures on muscular or skeletal structures. clTrac may be used to treat pain and symptoms associated with the following conditions: herniated discs, bulging or protruding intervertebral disc disease, posterior facet syndrome, acute facet problems, radicular pain, prolapsed discs, spinal root impingement, hypomobility, degenerative joint disease, facet syndrome, compression fractures, joint pain, and discogenic pain.

    Device Description

    The clTrac is powered traction equipment that offers both static and intermittent traction. Spinal traction is a form of decompression that relieves the pressure on the spine. Traction is a non-surgical, non-invasive and non-pharmaceutical treatment for the management of pain and symptoms from a variety of pressures on muscular or skeletal structures. The clTrac is intended to be used by healthcare professionals (HCP) on their patients. When device is operational, the applied force shall not exceed +/-10% of the target force as set by the operator. clTrac applies a specific force onto the traction cord. The applied force is set by the operator by means of the touch screen and rotary knob. A patient interrupt button is available for the patient to pause the therapy. The cl Trac is a non-invasive therapeutic device. The device consists of a console with ABS housing. The console consists of an aluminium ground plate, an ABS outer shell, a 7" touch screen and a steel central control knob. A 2.9m long cord with a plastic patient interrupt button is plugged into the console. The console is intended to be fastened to a standardized traction table using screws that are tightly screwed into its aluminium ground plate, with holes in a standardized pattern. The implemented motor-gear unit applies traction via a traction cord that is fixed into the console with a 360° swivel head with guide pulley. The traction cord is intended to be attached to hip and thoracic traction belts that are sold separately.

    AI/ML Overview

    The provided document is an FDA 510(k) clearance letter for the clTrac device, a powered traction equipment. It focuses on demonstrating substantial equivalence to a predicate device (Eltrac 471) rather than a deep dive into specific performance study details with acceptance criteria for an AI/ML-based medical device.

    Therefore, many of the requested details regarding acceptance criteria, specific study types (MRMC, standalone), sample sizes for test and training sets, expert qualifications, and ground truth establishment methods for an AI/ML device are NOT present in this document.

    The document details the device's indications for use, technological characteristics, and compliance with various voluntary general and electrical safety standards. It explicitly states:

    • Clinical Performance: Not applicable. This device does not require clinical testing for demonstration of substantial equivalence and safety/effectiveness."

    This means the 510(k) clearance was based on non-clinical performance (bench testing, electrical safety, software validation, usability, risk management, and biocompatibility) and comparison to a predicate, not on a study demonstrating clinical performance with specific metrics like sensitivity, specificity, or reader improvement, which are typical for AI/ML device clearances.

    Here's a breakdown of what can be extracted or inferred based on the provided text, and where the information is missing:

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

    The document doesn't present "acceptance criteria" in the way one would for an AI/ML diagnostic or prognostic device (e.g., target specificity, sensitivity thresholds). Instead, it refers to compliance with established medical device standards and the device's operational specifications.

    Acceptance Criteria Category (Inferred from document)Specific Criteria/StandardReported Device Performance
    Indications for Use EquivalenceIdentical to predicate deviceStated as "identical" to the predicate device (Eltrac 471).
    Technological EquivalenceSimilar design, display, conditions of use, technology (software control, patient interrupt), power supply, and safety features to predicate."No significant technological differences" stated. "The subject device has all features of the predicate device." Differences (e.g., central control knob in addition to touchscreen) do not affect safety or performance.
    Applied Force AccuracyApplied force shall not exceed +/-10% of the target force as set by the operator."When device is operational, the applied force shall not exceed +/-10% of the target force as set by the operator." (This is a design specification and implied acceptance criterion, not a direct performance result from a specific test report in this summary doc).
    Electrical SafetyCompliance with ANSI AAMI ES60601-1"X" (Compliant)
    Electromagnetic Compatibility (EMC)Compliance with IEC 60601-1-2"X" (Compliant)
    UsabilityCompliance with IEC 60601-1-6 and IEC 62366-1"X" (Compliant) for both. Note: Predicate's compliance status not publicly available for these.
    Software Life Cycle ProcessesCompliance with IEC 62304"X" (Compliant)
    Risk ManagementCompliance with ISO 14971"X" (Compliant)
    BiocompatibilityCompliance with ISO 10993-1"X" (Compliant). Note: Predicate's compliance status not publicly available for this.
    Manufacturing Quality SystemCompliance with 21 CFR Part 820 (QS Regulation)Implied by 510(k) clearance, as stated in the general provisions of the letter.

    2. Sample size used for the test set and the data provenance

    • Sample Size: Not applicable. No clinical test set. The performance testing was primarily bench testing and engineering verification/validation against standards.
    • Data Provenance: Not applicable for clinical data. The testing mentioned (electrical safety, EMC, usability, software, risk, biocompatibility) would be performed in a lab setting by the manufacturer.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    • Not applicable. There was no clinical test set requiring expert-established ground truth.

    4. Adjudication method for the test set

    • Not applicable.

    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 powered traction equipment, not an AI/ML diagnostic aid for human readers.

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

    • No. This device is electro-mechanical, not an AI/ML algorithm. Its "performance" refers to its physical operation and safety, not an intelligent diagnostic output.

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

    • Not applicable. Ground truth for an AI/ML algorithm is not relevant here. The "ground truth" for the device's functionality would be engineering specifications and measurements (e.g., force output measured by a calibrated sensor, electrical safety limits).

    8. The sample size for the training set

    • Not applicable. This device does not use an AI/ML algorithm that requires a training set.

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

    • Not applicable.

    In summary, the provided document is for a medical device clearance (clTrac, a powered traction equipment) that relies on demonstrating substantial equivalence to a predicate device and compliance with general device safety and performance standards. It explicitly states that clinical testing was "not applicable." As such, the detailed requirements for AI/ML device clearances (like test set/training set sizes, expert ground truth establishment, MRMC studies) are not relevant to this specific FDA submission and are not found in this document.

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    K Number
    K151640
    Device Name
    ELTRAC 471
    Manufacturer
    Date Cleared
    2015-10-16

    (120 days)

    Product Code
    Regulation Number
    890.5900
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    ITH

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The ELTRAC 471 Traction device, with its accessories, is intended to provide relief for the management of pain and symptoms from a variety of pressures on muscular or skeletal structures. The ELTRAC 471 Traction device may be used to treat pain and symptoms associated with the following conditions: hermiated discs, bulging or protruding intervertebral discs, degenerative disease, posterior facet syndrome, acute facet problems, radicular pain, prolapsed discs, spinal root impingement, hypomobility, degenerative joint disease, facet syndrome, compression fractures, joint pain, and discogenic pain.

    Device Description

    The Eltrac 471 traction device applies forces to the spine to alleviate pain caused by a variety of pressure on muscular or skeletal structures. It exerts defined forces on the human body to alleviate pain and utilizes computer technology for programming of different kinds of traction.

    This device is intended for use by professional users only, such as qualified personnel in physiotherapy, rehabilitation and adjacent areas. The device is designed with a plastic housing that holds the motor and has a full color touch screen interface on which the professional user can enter various parameters by touch. The forces from the motor are transferred to the patient by cords and connected accessories. Sequential programming is possible for programming combinations of traction which can be stored as favorites for later use.

    AI/ML Overview

    The provided text describes the regulatory clearance for the "Eltrac 471 Traction device" based on substantial equivalence to a predicate device, rather than a study designed to prove the device meets specific acceptance criteria through performance metrics. Therefore, many of the requested details about acceptance criteria, study design, and performance against those criteria are not present.

    However, I can extract the information that is available regarding regulatory requirements and the non-clinical performance evaluation.

    Here's a breakdown of the available information based on your request:

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

    The document does not specify quantitative acceptance criteria for device performance (e.g., accuracy, sensitivity, specificity) against which the Eltrac 471 was compared. Instead, it relies on demonstrating substantial equivalence to a predicate device and adherence to recognized non-clinical standards.

    The "performance" is generally described as meeting safety and functionality requirements through verification and validation tests against these standards.

    Acceptance Criterion (Implicit)Reported Device Performance (Summary)
    SafetyAdheres to ISO 14971, IEC 60601-1, IEC 60601-1-2. Electronic safeguards of force and mechanical safety for maximum force limitation. Hardware mitigations protect from excessive force. Patient stop function. Remote control can decrease force but not increase it.
    Basic Safety and Essential PerformanceAdheres to IEC 60601-1.
    Electromagnetic Compatibility (EMC)Adheres to IEC 60601-1-2 (Electromagnetic disturbances - Requirements and tests).
    Software Life Cycle ProcessAdheres to IEC 62304.
    FunctionalityApplies forces to the spine, utilizes computer technology for programming, sequential programming possible, full color touch screen, transfers force via cords and accessories.
    Technological CharacteristicsSubstantially equivalent to predicate device (Triton/Tru-Trac/TX/Triton DTS Traction devices) regarding electrical input, software control, motor-driven force delivery, safety/warning features. Minor differences in body positions, maximum treatment time (150 min vs 165 min), and force speed deemed not to raise new risks.

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    This information is not provided in the document. The non-clinical performance refers to "Verification and validation tests" conducted by Enraf-Nonius, B.V., but details about specific test sets, sample sizes, or data provenance (e.g., retrospective/prospective, country of origin) are absent. This is typical for submissions based on substantial equivalence for non-clinical devices where the "test set" would be the device itself subject to engineering and safety tests.

    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 provided. Clinical ground truth, experts, or their qualifications are not mentioned, as no clinical testing was performed or required. The "ground truth" for non-clinical tests would typically be defined by engineering specifications and standard requirements.

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

    This information is not provided. Adjudication methods are relevant for clinical studies, which were explicitly stated as "Not applicable" for this device.

    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 and not provided. This device is a physical therapy traction device, not an AI-assisted diagnostic or imaging device used by human readers/interpreters. No MRMC study was conducted.

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

    This information is not applicable in the context of typical AI algorithm-only performance. The "device" itself, the Eltrac 471, performs its function (applying traction) independently to the extent of its programming. The "non-clinical performance" section describes tests on the device's electrical, safety, and software functionality, which could be considered a form of standalone testing for the device's inherent design.

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

    For the non-clinical performance, the "ground truth" implicitly used would be engineering specifications, design requirements, and the pass/fail criteria defined by the cited international standards (ISO 14971, IEC 60601-1, IEC 60601-1-2, IEC 62304). This does not involve clinical "ground truth" like pathology or outcomes data, as no clinical studies were performed.

    8. The sample size for the training set

    This information is not applicable and not provided. This device is not an AI/ML algorithm that requires a training set in the conventional sense. The "software" component refers to control software, not a learned model.

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

    This information is not applicable and not provided for the reasons stated in point 8.

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    K Number
    K150695
    Device Name
    Modpod
    Manufacturer
    Date Cleared
    2015-08-13

    (148 days)

    Product Code
    Regulation Number
    890.5900
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    ITH

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Modpod cervical traction provides mobilization of skeletal structures and muscles in static, intermittent, progressive, and regressive distraction forces to relieve pressures that may be causing pain of skeletal or muscular origin. These effects are achieved through decompression of intervertebral discs, that is, unloading due to distraction and positioning, and may be used to relieve peripheral radiation/sciatica and pain associated with:
    • Protruding discs
    • Bulging discs
    • Herniated discs
    • Degenerative disc disease
    • Posterior facet syndrome
    • Acute facet problems
    • Radicular pain
    • Prolapsed discs
    • Spinal root impingement
    • Hypomobility
    • Degenerative joint disease
    • Facet syndrome
    • Compressions fracture
    • Joint pain
    • Discogenic pain

    Device Description

    The Modpod™ Cervical Traction Device provides static and intermittent distraction forces to the cervical spine to relieve pressures on structures that may be causing pain of skeletal or muscular origin. Therapeutic distraction can be applied in a variety of programmable patterns and functions.

    The device design allows a clinician access to a patients head and neck when hands-on interaction and positioning is needed. Use of the device reduces the level of exertion experienced by the clinician when compared to manual traction therapy techniques. Additionally, hands-on interaction and positioning by the clinician may occur before or after treatment.

    Painted sheet metal and ABS plastic encasement housing electronic circuitry; software and electronics engage a gear driven motor with load sensors; slide mechanism, and patient head harness to apply cervical traction.

    AI/ML Overview

    I am sorry, but I cannot fulfill your request to describe the acceptance criteria and the study that proves the device meets the acceptance criteria from the provided text. The document is a 510(k) premarket notification letter from the FDA to Hollywog, LLC, regarding their device called "Modpod".

    This document primarily focuses on establishing substantial equivalence to previously marketed predicate devices (K051938 and K053223). It details:

    • Indications for Use: The medical conditions the device is intended to treat.
    • Technical Specifications: Information about the device's design, power supply, components, and operational characteristics.
    • Comparison to Predicate Devices: A comprehensive table comparing the Modpod to the predicate devices across various parameters like regulation, product class, intended use, anatomical site, maximum traction force, electrical standards, etc.

    However, the document does not contain information about specific acceptance criteria (performance metrics) or a study report with associated data and statistical analysis that proves the device meets such criteria. It states that "The Modpod cervical traction device is as safe and effective, and performs as well or better than the claimed predicate devices," which is a conclusion based on the comparison provided, but not a detailed study report with results against predefined acceptance criteria.

    Therefore, I cannot extract the requested information regarding:

    1. A table of acceptance criteria and reported device performance.
    2. Sample size and data provenance for a test set.
    3. Number and qualifications of experts for ground truth.
    4. Adjudication method.
    5. MRMC comparative effectiveness study results.
    6. Standalone algorithm performance.
    7. Type of ground truth used.
    8. Training set sample size.
    9. How training set ground truth was established.
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    K Number
    K131983
    Date Cleared
    2014-09-10

    (439 days)

    Product Code
    Regulation Number
    890.5900
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    ITH

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The iTrac c2i cervical traction system is intended for use as a conservative in patients presenting with cervicogenic pain symptoms of mechanical origin related to reduced cervical lordosis extension and altered posture. It temporarily positions the cervical spine into an extension posture of varying degrees, as determined by a clinician. This device is for prescription use only and is not provided in a sterile condition.

    Device Description

    The iTrac™ c2i cervical traction system is intended for use as a conservative treatment alternative in patients presenting with cervicogenic pain symptoms of mechanical origin related to reduced cervical lordosis/extension and altered posture. It temporarily positions the cervical spine into an extension posture of varying degrees, as determined by a clinician. This device is for prescription use only and is not provided in a sterile condition.

    Operational software controls the exertion and release of the pulling forces, operation cycle, and treatment times prescribed by the physician. The iTrac's operational components consist of software, an air compressor, three pneumatic cylinders, two electro-pneumatic regulators, a traction line and pullev system, head halter, fulcrum strap, magnetic safety release, backup flow controls, and mechanical pressure relief valves.

    All accessories necessary to provide the traction to the patient are included with the device making it a ready to use traction device. A head halter captures the patient's chin during treatment and is connected to an adjustable overhead traction bar that can be manually adjusted by the doctor to the doctor-prescribed traction angle. A fulcrum strap rests on the back of the patient's neck and may be used to provide an additional anterior force. During setup, an electric lift column allows the fulcrum/traction section to be raised or lowered by the doctor to the height doctor prescribed for each patient.

    For each treatment session the Doctor commands the software to implement a specific treatment time, traction force, and fulcrum force. Utilizing a piecewise linear function calculation the software generates an output signal causing the electro-pneumatic pressure controllers to adjust pressure, delivering the doctor prescribed forces to the fulcrum and traction cylinders. For safety, limits are hard coded in the software to prevent traction and fulcrum forces from exceeding the allowable limits. The software is loaded on a standard personal computer which interfaces with the device via a standard network connection; this standard connection is limited to connection only with the iTrac.

    A Patient Stop Switch provides additional protection to the patient by operating independent of software to relieve all forces when pressed. When activated, the patient stop switch triggers a relay which, in turn, triggers a solenoid-controlled pneumatic valve causing a quick stop and venting of all pneumatic pressure to the cylinders. This action immediately relieves the patient of traction forces and sends a discrete output from the relay to the I/O Module, placing the treatment session into 'Pause' within the software. As an added safety measure the software requires the patient stop switch to be pressed before the start of each treatment during the treatment start protocol to ensure its functionality.

    AI/ML Overview

    The provided document is a 510(k) summary for the iTrac c2i Cervical Traction System. It focuses on demonstrating substantial equivalence to a predicate device, the CTBox Cervical/Lumbar Traction System, rather than presenting a clinical study to prove device performance against specific acceptance criteria in the manner usually seen for AI/ML-driven devices.

    Therefore, many of the requested categories for acceptance criteria and study details are not directly applicable or available in this type of submission. The document primarily details technical specifications and safety features compared to a predicate device.

    Here's an attempt to answer the questions based on the available information, noting when information is not present in the document.

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

    Since this is a substantial equivalence submission for a physical medical device (traction system), "acceptance criteria" here refers to demonstrating that the new device's technical characteristics and safety features are equivalent to or better than a legally marketed predicate device. There aren't "performance metrics" in the typical sense of accuracy, sensitivity, specificity, etc., as would be the case for AI/ML diagnostic tools.

    Acceptance Criteria (Inferred from comparison to predicate)Reported Device Performance (iTrac™ c2i Cervical Traction System)
    Functional Equivalence
    Intended UseThe iTrac c2i cervical traction system is intended for use as a conservative treatment alternative in patients presenting with cervicogenic pain symptoms of mechanical origin related to reduced cervical lordosis/extension and altered posture. It temporarily positions the cervical spine into an extension posture of varying degrees, as determined by a clinician. (Similar to predicate, but only for cervical).
    Treatment AreaCervical only. (Predicate treats Cervical or Lumbar).
    Treatment PositionSeated. (Predicate allows Seated or Supine).
    Lift MechanismElectromechanical. (Predicate uses electric).
    Traction Force Range (Cervical)Min. and Max. traction force = 0-20 lbs (traction force) / 0-40 lbs (fulcrum force). (Predicate's cervical traction limit is 40 lbs).
    System ControlComputer-controlled traction system with operational software residing on a computer. (Predicate's control mechanism not detailed, but described as "Eccentric Drive Motor" and "gear motor that revolves rope hook-ups").
    Operational ComponentsAir compressor and Pneumatic cylinders, software controlled pneumatic regulator, pulley assembly to generate linear force. (Predicate uses Eccentric Drive Motor, pulley assembly, and suspended weights/ratcheting winches).
    Traction SpeedStepless, Continuous, Adjustable. (Predicate is Continuous and Adjustable).
    Force DisplayActual Force / Preset Force (digital). (Predicate uses Analog weight scale).
    Treatment Time5-15 min. (Predicate is 15-20 minutes).
    Therapy ModeContinuous. (Predicate offers Continuous and Intermittent).
    Additional ComponentsThe iTrac system includes the iTrac device and necessary accessories to function as a ready-to-use traction device. (Predicate provides the motorized mechanism and may be connected to a separate Traction L-Frame for accessories).
    Safety Features
    Safety system for force releaseMultiple protections including patient safety switch (releases all forces), manual release, unit stop button, compressor regulator, magnetic safety release, pressure release valve, backup flow control, feedback gauges. (Predicate has Manual Release, Hand held on/off switch which releases only 1-7 lb delta force).
    Power supply110-120V (60Hz), 220-240V (50Hz). (Predicate is 115V (60Hz)).
    Allowable Voltage FluctuationMax ±10%. (Predicate UNK). Verified through NRTL testing.
    Casing leakage of electricity
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    K Number
    K130249
    Date Cleared
    2014-02-06

    (370 days)

    Product Code
    Regulation Number
    890.5900
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    ITH

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Integrity Spinal Care System 3.0 provides a primary treatment modality for the management of pain and disability for patients suffering with incapacitating low back pain and sciatica. It is designed to apply spinal decompressive forces to compressive and degenerative injuries of the spine. It has been found to provide relief of pain and symptoms associated with herniated discs, bulging or protruding intervertebral discs, degenerative disc disease, posterior facet syndrome, and sciatica.

    Device Description

    The Integrity Spinal Care System 3.0 incorporates the same principles and working characteristics of the predicate devices, the DRX9000 True Non Surgical Decompression System (K060735) and is same in size, shape and function. The components of The Integrity Spinal Care System 3.0 are substantially equivalent in form, fit, function and configuration to its predicate device the DRX9000 True Non Surgical Decompression System (K060735).There are similar key design technical characteristics; multi-function table designed to applied distraction forces and controlled by a computer console, same/similar components for treatment and measurement; similar size, power source, and performance.

    AI/ML Overview

    The Integrity Spinal Care System 3.0 is a spinal decompression device. The provided text indicates that no clinical data was required for its 510(k) clearance, as non-clinical comparisons to its predicate device, the DRX9000 True Non Surgical Decompression System (K060735), demonstrated substantial equivalence. Therefore, the information regarding acceptance criteria and a study proving the device meets these criteria is limited to non-clinical testing.

    Here's the information based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    Criterion/ParameterAcceptance Criteria (Implied)Reported Device Performance
    Functional Equivalence to Predicate DeviceSubstantial equivalence in principles, characteristics, size, shape, function."incorporates the same principles and working characteristics of the predicate devices," and "is same in size, shape and function." "substantially equivalent in form, fit, function and configuration." "essentially the same product as the predicate device."
    Component Equivalence to Predicate DeviceSimilar/same components for treatment and measurement."has the same components to the DRX9000 True Non Surgical Decompression System."
    Performance in Applying Controlled TensionsAccurately controlled tensions, smooth and gentle logarithmically applied distraction, smooth logarithmic release rate, cyclic periodicity, upper limits on distractions."delivers accurately controlled tensions in the same manner as its predicate device." "smooth and gentle logarithmically applied distraction tensions, the smooth logarithmic release rate of tensions and relaxation cycles, the cyclic periodicity, the upper limits on distractions."
    Safety FeaturesInclusion of a patient safety switch."patients hold a patient safety switch to allow at anytime the pausing of any tensile forces." "patients can stop the treatment by pressing the patient hand held safety switch."
    Electromagnetic Compatibility (EMC)Compliance with IEC 60601-1-2."The device is in compliance with the following safety standards: ... IEC 60601-1-2:2001 Medical Electrical Equipment Part 1 2: General requirements for ● Safety - Collateral Standard, Electromagnetic Compatibility - Requirements and Tests."
    Electrical SafetyCompliance with IEC 60601-1."The device is in compliance with the following safety standards: ... IEC 60601-1, Medical Electrical Equipment Part 1: General Requirements for Safety, . 1988: Amendment 1, 1991-11, Amendment 2, 1995."
    Risk ManagementApplication of risk management to medical devices (ISO 14971)."The Integrity Spinal Care System has been reviewed for risk management utilizing ISO 14971:2007, Application of risk management to medical devices ensuring all aspects of the device are reviewed for potential hazards."
    Tension Measurement AccuracyDisplayed tension readings comparable to calibrated dynamometer and predicate devices."Measurements of tension demonstrate that the tension readings displayed and noted from the calibrated dynamometer are comparable to predicate devices."

    2. Sample Size Used for the Test Set and Data Provenance

    • Sample Size for Test Set: Not applicable in the context of clinical data for this 510(k). The non-clinical testing involved a "calibrated dynamometer" to stimulate a patient, implying a hardware-based test rather than a patient dataset. The sample size for this non-clinical test is not specified, but it refers to a device-to-device comparison and standard compliance tests.
    • Data Provenance: Not applicable for clinical data. For non-clinical tests, the data was generated internally by the applicant (Integrity Life Sciences) and/or by an "independent party" for evaluation of modifications to appearance.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts

    • Not applicable as no clinical ground truth was established for the 510(k) clearance. The determination of substantial equivalence was based on non-clinical engineering and performance comparisons.

    4. Adjudication Method for the Test Set

    • Not applicable as no clinical ground truth was established.

    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 a physical traction system, not an AI-assisted diagnostic tool.

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

    • Not applicable. This device is a physical traction system, not an algorithm, and its performance is inherently "standalone" in the sense that its mechanical operation is evaluated independently of a human interpreter.

    7. The Type of Ground Truth Used

    • For functional and performance characteristics, the "ground truth" was established by comparison to the predicate device (DRX9000 True Non Surgical Decompression System) and compliance with recognized consensus standards (IEC 60601-1, IEC 60601-1-2, ISO 14971). The accuracy of tension display was verified against a calibrated dynamometer.

    8. The Sample Size for the Training Set

    • Not applicable as no machine learning algorithm was involved, and thus no training set was used.

    9. How the Ground Truth for the Training Set was Established

    • Not applicable as no machine learning algorithm was involved.
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    K Number
    K112074
    Date Cleared
    2012-02-01

    (196 days)

    Product Code
    Regulation Number
    890.5900
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    ITH

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Everyway Traction System, model EVER-TRAC ET-800 is intended for medical purpose for use in conjunction with traction accessories, such as belts and harnesses , to exert therapeutic pulling forces on the patient's body.

    Device Description

    Everyway Traction Unit, model EVER-TRAC ET-800 is a medical device constructed for use in conjunction with traction accessories, such as belts and harnesses, to exert therapeutic pulling forces on the patient's body. For this intended operation function, ET-800 is the combination of driving moter, speed reduction gear, pulley assembly, spring, force and speed control unit... etc. All of the operational parts as above mentioned are mounted on the frame of device housing. The pulling force for ET-800 is generated by the combination of induction motor and speed reduction gear. For the operation of ET-800, the single phase AC power shall be supplied from the general wall socket of house (Note: In USA, the power supply specification is single phase, 60Hz, 120V). Basically ET-800 is a microprocessor-controlled traction system in which the operational software is built inside the control unit to properly control the exertion and release of pulling force according to the setting for applying force, operation cycle, and operation time prescribed by the physician. To ensure the safety of operation, the device was designed and constructed to provide the following safety protection: Manual release, Auto shutdown, and Safe protect. In addition, the device also provides warning alarm function for same near dangerous situations as mentioned in user's manual.

    AI/ML Overview

    Here's an analysis of the provided 510(k) summary, specifically addressing the requested information about acceptance criteria and studies:

    1. Table of Acceptance Criteria and Reported Device Performance

    Based on the provided document, there are no specific quantitative acceptance criteria or detailed device performance metrics reported for the Everyway Traction Unit, model EVER-TRAC ET-800. The submission focuses on demonstrating substantial equivalence to a predicate device through non-clinical testing.

    Acceptance Criteria (Quantitative/Qualitative)Reported Device Performance
    Not explicitly stated in terms of specific performance thresholds (e.g., force accuracy, speed range compliance)The device passed electrical compliance and EMC compliance tests as per IEC 60601-1 and IEC 60601-1-2.
    General safety features (manual release, auto shutdown, safe protect, warning alarms)These features are designed into the device, implying they function as intended to meet safety objectives.
    Substantial equivalence to predicate device (Ever Prosperous Traction System model DIGIT-TRAC 930) in technological and operational featuresThe document concludes that the device maintains the "same safety and effectiveness" as the predicate device, indicating that its performance in these areas is considered equivalent.

    2. Sample Size Used for the Test Set and Data Provenance

    The provided document does not mention a "test set" in the context of clinical performance or a specific dataset used for evaluating the device's therapeutic effectiveness. The tests conducted were non-clinical:

    • Non-Clinical Testing: Electrical Compliance Test and EMC Compliance Test.
    • Sample Size: Not applicable in the context of clinical data. These tests would typically be performed on a single or a few units of the manufactured device.
    • Data Provenance: Not applicable for clinical data. The tests were performed by "accredited laboratory."

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts

    Not applicable. No clinical test set or ground truth established by experts is mentioned in the provided document. The basis for clearance is substantial equivalence to a predicate device, supported by non-clinical safety testing.

    4. Adjudication Method (e.g., 2+1, 3+1, none) for the Test Set

    Not applicable. No clinical test set or adjudication process is mentioned.

    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. The device is a powered traction unit, not an AI-assisted diagnostic or therapeutic device that would involve human readers or AI assistance.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

    Not applicable. The device is a physical medical instrument, not a standalone algorithm.

    7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.)

    Not applicable for clinical performance. For the safety and performance evaluation, the "ground truth" used would be the standards themselves (IEC 60601-1 and IEC 60601-1-2). The device's electrical and EMC characteristics were compared against the requirements of these standards.

    8. The Sample Size for the Training Set

    Not applicable. The device is not an AI/ML algorithm that requires a training set.

    9. How the Ground Truth for the Training Set Was Established

    Not applicable. The device is not an AI/ML algorithm that requires a training set.


    Summary of the Study:

    The provided document describes a 510(k) premarket notification for the Everyway Traction Unit, model EVER-TRAC ET-800. The study conducted to demonstrate the device meets acceptance criteria (specifically for market clearance via substantial equivalence) is not a clinical study. Instead, it relies on non-clinical verification activities:

    • Electrical Compliance Test: According to IEC 60601-1, performed by an accredited laboratory.
    • EMC Compliance Test: According to IEC 60601-1-2, performed by an accredited laboratory.

    The conclusion is that these tests, along with the device's similar technological and operational features to the predicate device (Ever Prosperous Traction System model DIGIT-TRAC 930), demonstrate substantial equivalence and maintain "the same safety and effectiveness" as the cleared predicate device. No particular clinical test was conducted for this device. Therefore, the "acceptance criteria" primarily relate to compliance with specified electrical and electromagnetic compatibility standards, and the "study" is limited to these non-clinical engineering tests.

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    K Number
    K103248
    Date Cleared
    2011-04-05

    (153 days)

    Product Code
    Regulation Number
    890.5900
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    ITH

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Integrity Spinal Care System provides a program of treatments for relief from pain for those patients suffering with low back pain or neck pain. Each treatment consists of a physician prescribed treatment period on the Integrity Spinal Care System and is designed to provide static, intermittent, and cycling distraction forces to relieve pressures on structures that may be causing low back or neck pain. Conditions that may be treated include neck pain and back pain associated with herniated discs, protruding discs, degenerative disc disease, posterior facet syndrome, and sciatica. It achieves these effects through decompression of intervertebral discs, that is, unloading due to distraction and positioning.

    Device Description

    The Integrity Spinal Care System is a multi-function distraction table designed to apply distraction forces and controlled by a computer console. It has similar components for treatment and measurement, similar size, power source, and performance to the predicate devices. Key elements include a stand on/stand off tilt type bed, a split bed with two slideable cushions, a traction unit mounted to both ends of the bed with a belt pulley system attached to a vertical movable platform, a control panel for programming and controlling the traction unit, continuous monitoring of treatment parameters shown by LCD readout, automatic return to zero tension at the conclusion of treatment, an incorporated DVD player and headphones, and instantaneous release of tensions via a patient safety switch or stop buttons.

    AI/ML Overview

    The provided text is related to a 510(k) summary for the "Integrity Spinal Care System," a traction equipment device. The document primarily focuses on establishing substantial equivalence to predicate devices and detailing the device's technical characteristics, intended use, indications for use, and safety features.

    However, the document does not contain information about:

    • Specific acceptance criteria for device performance (beyond compliance with recognized standards).
    • A "study that proves the device meets the acceptance criteria" in terms of clinical performance or a formal performance study with a test set, ground truth, or expert review.
    • Sample sizes for test or training sets.
    • Data provenance, number of experts, adjudication methods, MRMC studies, or standalone algorithm performance, as these are typically associated with performance evaluation of diagnostic or AI-based devices.

    The document mainly states that "Non-clinical Tests: The Integrity Spinal Care System is as safe and effective as the predicate devices demonstrating compliance to FDA recognized Consensus Standards. A calibrated dynamometer won placed between the tower and bed to stimulate a patient. Measurements of tension demonstrate the tension readings displayed and noted from the calibrated dynamometer are compirative to predicate devices." This describes a basic technical comparison rather than a detailed performance study against acceptance criteria.

    Therefore, most of the requested information cannot be extracted from the provided text.

    Here's what can be stated based on the text:

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

    Acceptance Criteria (Implied)Reported Device Performance
    Compliance with FDA recognized Consensus StandardsThe device is in compliance with:
    • IEC 60601-1, Medical Electrical Equipment Part 1
    • IEC 60601-2-38, Hospital Beds
    • IEC 60601-1-2, Electromagnetic Compatibility
    • ISO 14971:2007, Application of risk management to medical devices |
      | Tension measurements comparable to predicate devices | "Measurements of tension demonstrate the tension readings displayed and noted from the calibrated dynamometer are comparative to predicate devices." (Performed using a calibrated dynamometer to simulate a patient). |
      | Key descriptive elements and safety features as designed | The document lists 14 key descriptive elements (e.g., tilt bed, split cushions, harnesses, 10-200 lbs tension, LCD readout) and 8 summary safety features (e.g., 24-volt circuit, patient safety switch, manual re-entry of parameters, no manual override of max tension). The implication is that the device performs according to these listed characteristics. |
      | Safety and effectiveness similar to predicate devices | The conclusion states: "The comparisons to the predicate devices demonstrate that the proposed device is safe and effective and does not raise any new potential safety risks and is substantially equivalent to the predicate devices." |
      | Application of accurately controlled distraction tension to spine | The operating principles "permit the application of accurately controlled distraction tension to the lumbar and cervical spine in order to decompress the intervertebral discs and spinal structures." |

    2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    • The document describes non-clinical bench testing using a "calibrated dynamometer" to simulate a patient. It does not involve a "test set" of patient data.
    • Sample Size for Test Set: Not applicable / Not provided. The testing involved a dynamometer, not patient samples.
    • Data Provenance: Not applicable / Not provided, as it was bench testing.

    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. No ground truth based on expert review was established for this non-clinical test.

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

    • Not applicable. No adjudication method for a test set was mentioned.

    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 a traction equipment, not an AI-based diagnostic device where MRMC studies would typically be performed.

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

    • Not applicable. This device does not involve an algorithm for standalone performance evaluation in the context of diagnostics.

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

    • Not applicable for a typical medical device performance study. For the non-clinical testing, the "ground truth" was the expected/designed tension readings and compliance with specified engineering and safety standards, as measured by a calibrated dynamometer.

    8. The sample size for the training set

    • Not applicable. This device does not involve a training set as it is not an AI/machine learning device.

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

    • Not applicable. This device does not involve a training set.
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