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510(k) Data Aggregation

    K Number
    K244056
    Device Name
    DOC Band 3D
    Date Cleared
    2025-03-17

    (76 days)

    Product Code
    Regulation Number
    882.5970
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    OAN

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

    The DOC Band is indicated for use on infants from three to eighteen months of age with moderate to severe nonsynostotic cranial deformation, infants with plagiocephalic-, and scaphocephalic-, and scaphocephalic-shaped heads, or a combination thereof.

    The DOC Band 3D is also indicated for adjunctive use for infants from three to eighten months of age whose synostosis has been surgically corrected, but who still have moderate to severe cranial deformities including plagiocephalic-. brachycephalic-, and scaphocephalic-shaped heads, or a combination thereof.

    Device Description

    The DOC Band 3D is a cranial orthosis intended to treat positional plagiocephaly in infants from 3 to 18 months of age. The band is intended to apply a mild pressure to the prominent regions of an infant's cranium and to improve cranial symmetry, proportion, and/or shape.

    AI/ML Overview

    The provided text describes the DOC Band 3D, a cranial orthosis, and its substantial equivalence to predicate devices, focusing on changes in manufacturing processes and materials rather than a clinical performance study. Therefore, robust information regarding acceptance criteria and a detailed study proving the device meets those criteria, particularly for clinical effectiveness, is limited.

    However, based on the non-clinical data provided, we can infer some "acceptance criteria" related to device properties and the "study" that addresses them.


    1. Table of Acceptance Criteria and Reported Device Performance

    Given the information, the acceptance criteria are largely focused on ensuring the new manufacturing process and material for the outer shell maintain the essential performance characteristics, biocompatibility, and clinical usability of the predicate devices.

    Feature/ParameterAcceptance Criteria (Implied)Reported Device Performance (DOC Band 3D)
    Intended UseIdentical to predicate device (treating deformational plagiocephaly brachycephaly (DPB) as a cranial orthosis).Met: "The DOC Band 3D (band) is a medical device known generically as a cranial orthosis. A cranial orthosis is used to treat a medical condition known as deformational plagiocephaly brachycephaly (DPB)." (Identical to predicate)
    Indications for UseIdentical to predicate device (treatment of moderate to severe non-synostotic cranial deformation in infants 3-18 months, and adjunctive use post-surgical correction for synostosis).Met: "The DOC Band 3D is indicated for use on infants from three to eighteen months of age with moderate to severe non-synostotic cranial deformation, including infants with plagiocephalic-, brachycephalic-, and scaphocephalic-shaped heads, or a combination thereof. The DOC Band 3D is also indicated for adjunctive use for infants from three to eighteen months of age whose synostosis has been surgically corrected..." (Identical to predicate)
    Outer Shell Material BiocompatibilityNew material (polyamide 12 resin) must be biocompatible as per ISO 10993 standards.Met: "It is a polyamide 12 resin, which was tested per ISO 10993 for cytotoxicity, irritation and sensitization, passing all tests per standards."
    Mechanical PropertiesMechanical properties (shear, flexural, stiffness, fatigue, bond strength) must be substantially equivalent to or exceed predicate devices.Met: "Bench testing has demonstrated that the device's mechanical properties meet or exceed those of the predicate devices." (Confirmed for shear, flexural, stiffness, fatigue, and bond strength).
    Clinical UsabilityDonning, doffing, trims, and adjustment procedures must be equivalent to predicate devices.Met: "Senior clinicians evaluated the proposed device against the predicate device to confirm equivalent donning and doffing procedures, trims and adjustment procedures, demonstrating substantial equivalence in the fit and treatment protocols."
    SafetyDevice must be safe.Met: "The DOC Band 3D is made from biocompatible materials that have undergone ISO 10993 testing to ensure safety." (Implied by biocompatibility and mechanical testing results).
    EffectivenessExpected to be comparable to predicate devices.Met (by inference): "The clinical performance of the DOC Band 3D is expected to be comparable to the predicate devices in the treatment of deformational plagiocephaly." (This is an expectation based on substantial equivalence of design and non-clinical data, not a direct clinical effectiveness study.)

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

    The provided text does not include information on a clinical test set sample size or its data provenance. The evaluation for this submission focuses on non-clinical data.

    • Mechanical Testing: The sample size for mechanical tests (shear, flexural, stiffness, fatigue, bond strength) is not specified.
    • Clinician Evaluation: The number of "Senior clinicians" who evaluated the device for usability is not specified.
    • Biocompatibility Testing: The sample size for materials tested per ISO 10993 is not specified.

    All data described appears to be prospective bench testing and expert evaluation conducted by Cranial Technologies, Inc. (the applicant). The country of origin for this data is not explicitly stated but would presumably be the USA where the company is based.

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

    • Number of Experts: The text refers to "Senior clinicians" who evaluated the device for substantial equivalence in fit and treatment protocols. The exact number of these clinicians is not specified.
    • Qualifications of Experts: The term "Senior clinicians" is used, implying experienced medical professionals relevant to the application of cranial orthoses. Specific qualifications (e.g., "radiologist with 10 years of experience") are not provided.

    4. Adjudication Method for the Test Set

    Given that the evaluation described is one of "Senior clinicians" confirming equivalence in procedures, a formal adjudication method like MRMC (e.g., 2+1, 3+1) is not applicable or described. The assessment was likely a qualitative endorsement of equivalence in handling and fit by these clinicians.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done

    No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done or described in this submission. The device is cleared based on substantial equivalence to predicate devices, primarily through non-clinical testing of its modified manufacturing process and material, and an expectation of comparable clinical performance. There is no mention of human readers or AI assistance in the context of this submission.

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

    The DOC Band 3D is a physical cranial orthosis, not an algorithm or software device. Therefore, a standalone (algorithm-only) performance study is not applicable to this device.

    7. The Type of Ground Truth Used

    For the non-clinical evaluations:

    • Mechanical Properties: The "ground truth" (or reference) for mechanical performance was the predicate DOC Band's mechanical properties. The new device's performance was measured against these established properties.
    • Biocompatibility: The "ground truth" was established ISO 10993 standards for cytotoxicity, irritation, and sensitization.
    • Clinical Usability: The "ground truth" for clinical usability (donning, doffing, trims, adjustments) was the established procedures and fit characteristics of the predicate DOC Band, as assessed by senior clinicians.

    8. The Sample Size for the Training Set

    This submission describes a medical device (cranial orthosis), not an AI/ML algorithm that requires a "training set." Therefore, the concept of a training set sample size is not applicable.

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

    As noted above, the concept of a "training set" is not applicable to this device.

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    K Number
    K240466
    Device Name
    STARband 3D
    Date Cleared
    2024-03-15

    (28 days)

    Product Code
    Regulation Number
    882.5970
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    OAN

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

    The STARband® 3D™ is intended for medical purposes for use on infants from 3 to 18 months of age, with moderate to severe non-synostotic positional plagiocephaly, including infants with plagiocephalic, brachycephalic and scaphocephalic-shaped heads by applying mild pressure to prominent regions of the infant's cranium to improve cranial symmetry and/or shape.

    Device Description

    The STARband® 3D™ redirects the head growth to improve proportion and symmetry. The practitioner takes a 3-dimensional captured image of the infant's head to acquire the existing shape. The 3-dimensional positive model is modified to obtain greater symmetry and space in the areas of flattening. The STARband® 3D™ provides total contact over the prominent or bossed areas of the baby's head to discourage growth there. Over the course of treatment, the inside of the band is further modified by the practitioner to provide space for growth to occur in the flat or depressed areas. The shape of the STARband® 3D™ directs growth into the areas of least resistance and creates a precise pathway for the head shape to improve in symmetry and proportion.

    AI/ML Overview

    This document is an FDA 510(k) clearance letter and summary for a medical device called STARband 3D. It focuses on establishing substantial equivalence to a predicate device rather than detailing specific studies conducted to prove acceptance criteria for a new, independent device.

    Therefore, the information required to accurately answer the prompt (acceptance criteria, specific study details, sample sizes, ground truth establishment, expert qualifications, etc.) is not present in the provided text. The document states that:

    • "Nonclinical performance testing performed for the predicate device and reference device remains applicable as there was no design change to the device."
    • "Validation was conducted to evaluate one potential risk identified during design control activities and no impact on safety or effectiveness was identified."
    • "These tests are referenced in the submission." (But the submission itself is not provided).

    Without the actual submission that details the non-clinical performance tests and their results, I cannot provide the specific information requested in the prompt regarding the device's acceptance criteria and the study that proves it meets them.

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    K Number
    K211376
    Device Name
    STARband
    Date Cleared
    2021-08-17

    (105 days)

    Product Code
    Regulation Number
    882.5970
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    OAN

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

    The STARband is intended for medical purposes for use on infants from three to 18 months of age, with moderate to severe non-synostotic positional plagiocephaly, infants with plagiocephalic-, brachycephalic-, and scaphocephalic- shaped heads by applying mild pressure to prominent regions of the infant's cranium in order to improve cranial symmetry and/or shape. The device is also indicated for adjunctive use for infants from three to eighteen months of age whose synostosis has been surgically corrected, but who will have moderate to severe cranial deformities including plagiocephalic-, brachycephalic-, and scaphocephalic- shaped heads.

    Device Description

    The STARband® redirects the head growth to improve proportion and symmetry. The practitioner takes a plaster impression or 3-dimensional captured image of the infant's head to acquire the existing shape. The mold is sealed and filled with plaster or the 3dimensional image is carved from a rigid polyurethane foam blank to create a positive model of the head shape. The positive model is modified to obtain greater symmetry and space in the areas of flattening. The STARband® provides total contact over the prominent or bossed areas of the baby's head to discourage growth there. Over the course of treatment, the inside of the band is further modified by the practitioner to provide space for growth to occur in the flat or depressed areas. The shape of the STARband® directs growth into the areas of least resistance and creates a precise pathway for the head shape to improve in symmetry and proportion.

    The STARband® Side Opening design and STARband® Bi-Valve design are made with an outer shell of 5/32" polyethylene-polypropylene copolymer plastic with an inner liner made of 1/2" pelite polyethylene foam or 1/2" Aliplast foam (closed cell polyethylene). The STARband® Side Opening design has a top opening and a side opening. The band is held in place by a Velcro® strap (1½" for STARband® Side Opening) across the side opening. The STARband® Bi-Valve design consists of two plastic shells that overlap with a superior sliding mechanism. The right and left overlap tabs are connected via a Velcro strap with chafe and loop.

    The STARband® Plus cranial orthosis device proposed in this submission has identical indications for use to the predicate submission K082950. The difference with this proposed device is a structural change to a dual side opening design with a living hinge at the top. The indications for use, the intended use, and the underlying principles of operation of the STARband® cranial orthosis remain exactly the same.

    AI/ML Overview

    The provided document describes materials testing and durability testing for the STARband® Plus cranial orthosis. It does not contain information about a study that assesses the device's performance in improving cranial symmetry or shape in infants, which would typically involve clinical outcomes or efficacy data related to the device's intended use. The provided information focuses on the physical properties and structural integrity of the device itself.

    Based on the provided text, here's what can be extracted regarding acceptance criteria and studies:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (for Durability)Reported Device Performance
    Living hinge to achieve or exceed 1440 cycles without experiencing failure (fatigue/fracture/yield) when donned and doffed roughly 4 times a day for 6 months.All STARband Plus configurations (1/2" Aliplast, (4) 1/8" Aliplast, and ½" Pelite) successfully completed 1440 cycles without fatigue/failure impacting the living hinge.

    2. Sample size used for the test set and the data provenance
    The document states that the "sample population included both deformational and post-operative patients" for the STARband Plus durability test, but it does not specify the exact number of devices (sample size) or the provenance of the data (e.g., country of origin, retrospective or prospective).

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
    This information is not applicable as the described study is a non-clinical, mechanical durability test and does not involve human expert assessment for ground truth.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
    This information is not applicable as the described study is a non-clinical, mechanical durability test and does not involve adjudication by multiple reviewers. The assessment involved visual inspection for wear or failure.

    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. The device is a cranial orthosis, not an AI-assisted diagnostic or imaging device, so an MRMC study is not relevant here.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
    This information is not applicable. The device is a physical medical device (cranial orthosis), not an algorithm or software. The testing described is for the physical durability of the device.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
    For the durability test, the "ground truth" was the physical integrity of the device's living hinge after repeated cycling, assessed by visual inspection for signs of wear or failure.

    8. The sample size for the training set
    This information is not applicable. There is no "training set" mentioned or implied as this is a non-clinical, mechanical durability test of a physical device, not an algorithm that requires training.

    9. How the ground truth for the training set was established
    This information is not applicable as there is no training set involved.

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    K Number
    K203098
    Date Cleared
    2021-04-27

    (195 days)

    Product Code
    Regulation Number
    882.5970
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    OAN

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

    The STARband, STARlight, and St. Louis Band are intended for medical purposes for use on infants from 3 to 18 months of age, with moderate-to-severe non-synostotic positional plagiocephaly, including infants with plagiocephalic-, brachycephalic- and scaphocephalic-shaped heads by applying mild pressure to prominent regions of the infant's cranium in order to improve cranial symmetry and/or shape. These devices are also indicated for infants from 3 to 18 months of age whose synostosis has been surgically corrected, but who still have moderate-to-severe cranial deformities including plagiocephalic-, brachycephalic- and scaphocephalic-shaped heads.

    Device Description

    The STARband and STARlight redirects the head growth to improve proportion and symmetry. The practitioner takes a plaster impression or 3-dimensional captured inage of the infant's head to acquire the existing shape. The mold is sealed and filled with plaster or the 3-dimensional image is carved from a rigid polyurethane foam blank to create a positive model of the head shape. The positive model is modified to obtain greater symmetry and space in the areas of flattening. The STARband and STARlight provide total contact over the prominent or bossed areas of the baby's head to discourage growth there. Over the course of treatment, the inside of the band is further modified by the practitioner to provide space for growth to occur in the flat or depressed areas. The shape of the STARband and STARlight directs growth into the areas of least resistance and creates a precise pathway for the head shape to improve in symmetry and proportion.

    The STARband and STARlight product families as it was last cleared in K180109 are essentially still the same devices. The STARband Side Opening design and STARband Bi-Valve design is made with an outer shell of 5/32" polyethylene-polypropylene copolymer plastic with an inner liner made of 1/2" pelite polyethylene foam or 1/2" Aliplast foam (closed cell polyethylene). The STARlight Side Opening design and the STARlight Bi-Valve design are made of a plastic shell of 5/32" - 1/4" clear Surlyn or 1/8" - 7/32" Clear Co-Polyester. The STARlight PRO (Post-operative Remolding Orthosis) design is made of 1/4" to 3/8" clear Surlyn. Optional Aliplast (closed cell polyethylene) padding is available for the clear plastic bands and in addition, optional Reston (polyurethane - 3M Medical Product) foam is available for the STARlight PRO design.

    The STARband Side Opening design and the STARlight Side Opening design has a top opening and a side opening. The band is held in place by a Velcro strap (1½" for STARband Side Opening and 1" for STARlight Side Opening) across the side opening. The STARlight PRO has two side openings, no top opening, and is held in place by a Velcro strap across each side opening. The STARlight Bi-Valve design and the STARband Bi-Valve design consist of two plastic shells that overlap with a superior sliding mechanism. The right and left overlap tabs are connected via a Velcro strap with chafe and loop.

    The St. Louis Band (formally known as the O&P Bivalve Molding Helmet in K063395) was last cleared in K180109 by Orthomerica Products Inc. The St. Louis Band is a Bi-Valve design made with an outer shell of 1/4" polyethylene-polypropylene copolymer plastic with an inner liner made of 1/4" Aliplast foam (closed cell polyethylene). The Bi-Valve design consists of two plastic shells that overlap and are held together with rivet fasteners. The St. Louis Band utilizes a Velcro strap with chafe and loop for a secure fit.

    The Cranial Comparison Utility (CCU) is a software component for a previously cleared shape capture method, the STARscanner Data Acquisition System, distributed by Orthomerica Products, Inc. The CCU is a separate software program that is designed to present specific measurements derived from a three-dimensional (3D) digital model and can be used to compare three-dimensional (3D) digital models during the patient treatment period for the purpose of tracking progress. These presented measurements can be incorporated into the patient assessment.

    The proposed addition is a new software component for a previously cleared shape capture method, the NetVirta SmartSoc Data Acquisition System, distributed by Orthomerica Products, Inc. The new software component is the Measurement Comparison Utility (MCU). The MCU is a separate software program, not used in manufacturing, which is designed to present specific measurements derived from a threedimensional (3D) digital model and can be used to compare three-dimensional (3D) digital models during the patient treatment period for the purpose of tracking progress. These presented measurements can be incorporated into the patient assessment.

    AI/ML Overview

    The provided document describes a 510(k) premarket notification for Orthomerica Products Inc.'s cranial orthoses (STARband, STARlight, and St. Louis Band) with the addition of a new software component, the Measurement Comparison Utility (MCU). The acceptance criteria and supporting study details are primarily focused on the MCU Accuracy and Capabilities Study.

    Here's a breakdown of the requested information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly state numerical acceptance criteria in a table format. However, it indicates that the MCU's performance was evaluated against the predicate Cranial Comparison Utility (CCU) and manual/3D-CAD software measurements. The reported device performance is that the MCU was determined to be substantially equivalent to the predicate CCU.

    FeatureAcceptance Criteria (Implicit)Reported Device Performance
    Measurement Accuracy & CapabilitiesTo be comparable to manual measurements and 3D-CAD software, and substantially equivalent to the predicate CCU in terms of model alignment, differential maps, calculations, and reporting.MCU was determined to be substantially equivalent to the predicate CCU regarding accuracy of measurements and capabilities of model alignment, differential maps, calculations, and reporting.

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

    • Test Set Sample Size: The document states that the MCU Accuracy and Capabilities Study "Utilized representative cranial shapes that reflect symmetrical and asymmetrical cranial shapes." However, it does not specify the exact number (sample size) of these cranial shapes used in the test set.
    • Data Provenance: The document does not specify the country of origin of the data or whether the study was retrospective or prospective. It refers to "representative cranial shapes," which could be phantom models or de-identified patient data.

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

    The document states that the MCU was "Compared... to manual measurements and 3D-CAD software." This implies that the ground truth for some measurements was established through manual methods and potentially by experts using 3D-CAD software. However, the document does not specify the number of experts used or their qualifications.

    4. Adjudication Method

    The document does not describe any specific adjudication method (e.g., 2+1, 3+1, none) for establishing the ground truth of the test set.

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

    A multi-reader multi-case (MRMC) comparative effectiveness study was not conducted in this submission. The focus was on the performance of the software (MCU) in comparison to established methods (manual measurements, 3D-CAD, and predicate software).

    6. Standalone (Algorithm Only) Performance

    A standalone performance study was performed. The "MCU Accuracy and Capabilities Study" evaluates the MCU software program itself, without human intervention in its measurement calculations or reporting. It compares the MCU's outputs to manual measurements and 3D-CAD software.

    7. Type of Ground Truth Used

    The ground truth used for the MCU Accuracy and Capabilities Study was:

    • Manual measurements
    • 3D-CAD software measurements

    This combination provided a reference for assessing the accuracy of the MCU's measurements and capabilities.

    8. Sample Size for the Training Set

    The document does not mention a training set sample size. The MCU is described as a software component designed to present specific measurements from 3D digital models. It seems to function as a measurement and comparison tool rather than a machine learning algorithm that requires a traditional training set for model development in this context. The study focuses on its accuracy for processing existing 3D models.

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

    Since a training set is not explicitly mentioned as relevant for this type of software (a measurement utility rather than a predictive model), the document does not describe how ground truth for a training set was established.

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    K Number
    K180109
    Date Cleared
    2018-03-01

    (44 days)

    Product Code
    Regulation Number
    882.5970
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    OAN

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

    The STARband, STARlight, and St. Louis Band are intended for medical purposes for use on infants from 3 to 18 months of age, with moderate-to-severe non-synostotic positional plagiocephaly, including infants with plagiocephalic-, brachycephalic- and scaphocephalic-shaped heads by applying mild pressure to prominent regions of the infant's cranium in order to improve cranial symmetry and/or shape. These devices are also indicated for infants from 3 to 18 months of age whose synostosis has been surgically corrected, but who still have moderate-to-severe cranial deformities including plagiocephalic-, brachycephalic- and scaphocephalic-shaped heads.

    Device Description

    The STARband®, STARlight®, and St. Louis Band are custom made cranial orthoses. The STARband® and STARlight® redirect head growth to improve proportion and symmetry in infants with moderate-to-severe non-synostotic positional plagiocephaly. The practitioner takes a plaster impression or 3-dimensional captured image the head to acquire the existing shape. The mold is sealed and filled with plaster or the 3-dimensional image is carved from a rigid polyurethane foam blank to create a positive model of the head shape. The positive model is modified to obtain greater symmetry and space in the areas of flattening. The STARband® and STARlight® provide total contact over the prominent or bossed areas of the baby's head to discourage growth there. Over the course of treatment, the inside of the band is further modified by the practitioner to provide space for growth to occur in the flat or depressed areas. The shape of the STARband® and STARlight® directs growth into the areas of least resistance and creates a precise pathway for the head shape to improve in symmetry and proportion. The St. Louis Band is a Bi-Valve design made with an outer shell of 1/4" polyethylene-polypropylene copolymer plastic with an inner liner made of 1/4" Aliplast foam (closed cell polyethylene). The Bi-Valve design consists of two plastic shells that overlap and are held together with rivet fasteners. The St. Louis Band utilizes a Velcro® strap with chafe and loop for a secure fit. The proposed device modification is the addition of the CurveCapture application for iOS enabled device for a previously cleared shape capture method, the Net Virta SmartSoc™ System distributed by Orthomerica Products, Inc, used with the STARband, STARlight, and St. Louis Band devices. The system uses a flexible fabric sock with a customized non-repetitive printed pattern and a consumer grade mobile phone device with a camera and a built-in flash light source. The built-in flash feature is a non-coherent (i.e. non-laser light) light source. The CurveCapture™ application uses the camera on the device to take video footage of the patient wearing the SmartSoc. Specific images are then selected and sent to the cloud to be processed into a detailed 3D digital model of the patient's cranium.

    AI/ML Overview

    The provided text describes a 510(k) submission for a medical device (cranial orthoses STARband, STARlight, and St. Louis Band) with a modification related to the associated 3D imaging system called SmartSoc. The modification involves the addition of an iOS-compatible application (CurveCapture) for the SmartSoc system. The document focuses on demonstrating substantial equivalence to predicate devices, primarily through technological characteristics and non-clinical performance data, particularly an accuracy study.

    Here's a breakdown of the information requested based on the provided text:

    Acceptance Criteria and Device Performance:

    The document broadly states that the "Cranial Shape Capture Accuracy Verification was performed concluding that the SmartSoc™ System for iOS enabled device yields a safe and effective product that is substantially equivalent to the predicate device." It also mentions that the study compared the proposed device to a cast and the predicate device, considering "Associated Coordinate Planes (A-P; M-L; P-D and various Radius Parameters; Squareness; Flatness)."

    However, specific numerical acceptance criteria (e.g., "accuracy must be within X mm") and the reported device performance values against those criteria are not explicitly stated in a quantitative table format within this summary. The text only indicates that the device met the criteria for substantial equivalence.

    1. Table of Acceptance Criteria and Reported Device Performance:

    Acceptance Criteria CategorySpecific Metric (if available)Acceptance Threshold (if available)Reported Device Performance (if available)
    Cranial Shape Capture AccuracyAccuracy in various coordinate planes (A-P; M-L; P-D), Radius Parameters, Squareness, FlatnessNot explicitly stated numericallyDevice yields "a safe and effective product that is substantially equivalent to the predicate device" in cranial shape capture accuracy.
    BiocompatibilityCytotoxicity (Agar Diffusion)Grade 0 (Non-cytotoxic) or Grade 1 for slight reactivity (Non-cytotoxic)All materials tested (Surlyn, Copolymer with Pelite Foam, Copolymer with Aliplast Foam) showed "Non-cytotoxic" results (Grade 0 or Grade 1 as noted in table 3).
    Closed Patch SensitizationNot a Sensitizer, No Erythema or Edema FormationAll materials showed "Not a Sensitizer" and "No Erythema or Edema Formation".
    Primary Dermal IrritationNegligible Dermal Response (e.g., Primary Irritation Index: 0.00 or 0.06 as noted in table 3).All materials showed "Negligible Dermal Response".
    SafetyEye Protection RequirementSafe to use on infants without any eye protection."The system uses a consumer grade camera and is safe to use on infants without any eye protection."

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

    The document mentions "Cranial Shape Capture Accuracy Study" but does not specify the sample size for the test set (i.e., how many cranial shapes or subjects were included in this accuracy study). It also does not specify the geographic origin (country of origin) of the data or whether the study was retrospective or prospective. It only states that the study "Utilized a representative cranial shape that possesses a predefined shape with known dimensions" and "Compared proposed device to cast and predicate device."

    3. Number of Experts and Qualifications for Ground Truth:

    The document does not mention the involvement of experts in establishing the ground truth for the test set. The ground truth seems to be based on a "representative cranial shape that possesses a predefined shape with known dimensions" and comparison to a physical "cast," implying an objective measurement rather than expert consensus on images.

    4. Adjudication Method:

    Given that expert involvement is not mentioned, an adjudication method (like 2+1 or 3+1) for the test set is not applicable and not described in the document.

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

    A multi-reader multi-case (MRMC) comparative effectiveness study was not performed or described. This study focuses on the accuracy of the imaging system itself in capturing shape, not on the improvement of human readers' performance with or without AI assistance. The device is a shape capture system for orthotic fabrication, not a diagnostic imaging interpretation tool for humans.

    6. Standalone (Algorithm Only) Performance:

    The "Cranial Shape Capture Accuracy Study" described is essentially a standalone (algorithm only) performance study as it evaluates the ability of the SmartSoc System for iOS to accurately capture the "predefined shape with known dimensions" and compare it to a cast and the predicate device. It assesses the algorithm's output (3D digital model) directly.

    7. Type of Ground Truth Used:

    The ground truth used for the accuracy verification was:

    • An objective, known "predefined shape with known dimensions" (likely a phantom or a precisely manufactured model).
    • Comparison to a physical "cast" of a cranial shape.

    This is not expert consensus, pathology, or outcomes data, but rather a direct measurement against a known physical standard.

    8. Sample Size for the Training Set:

    The document does not specify any training set size for the CurveCapture application or the SmartSoc system. This suggests that the development of the CurveCapture application might have relied on existing algorithms from the Android version, or that the training data details are not considered part of this simplified FDA summary for a Special 510(k). For a Special 510(k), significant changes to the algorithm often require more detailed information on training, but here the focus is on the "firmware expansion" and consistent technological characteristics.

    9. How Ground Truth for Training Set was Established:

    Since a training set is not explicitly mentioned or detailed, the method for establishing its ground truth is not provided.

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    K Number
    K161138
    Device Name
    St. Louis Band
    Date Cleared
    2016-07-20

    (89 days)

    Product Code
    Regulation Number
    882.5970
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    OAN

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

    The St. Louis Band is intended for medical purposes for use on infants from 3 to 18 months of age, with moderate-to-severe non-synostotic positional plagiocephaly, including infants with plagiocephalic-, brachycephalic- and scaphocephalic-shaped heads by applying mild pressure to prominent regions of the infant's cranium in order to improve cranial symmetry and/or shape. This device is also indicated for adjunctive use for infants from 3 to 18 months of age whose synostosis has been surgically corrected, but who still have moderate-to-severe cranial deformities including plagiocephalic-, brachycephalic- and scaphocephalic-shaped heads.

    Device Description

    The St. Louis Band redirects the head growth to improve proportion and symmetry. The practitioner takes a plaster impression or 3-dimensional captured image of the infant's head to acquire the existing shape. The mold is sealed and filled with plaster or the 3dimensional image is carved from a rigid polyurethane foam blank to create a positive model of the head shape. The positive model is modified to obtain greater symmetry and space in the areas of flattening. The St. Louis Band provides total contact over the prominent or bossed areas of the baby's head to discourage growth there. Over the course of treatment, the band is further modified by the practitioner to provide space for growth to occur in the flat or depressed areas. The shape of the St. Louis Band directs growth into the areas of least resistance and creates a precise pathway for the head shape to improve in symmetry and proportion.

    The St. Louis Band (formally known as the O&P Bivalve Molding Helmet) was released in K063395. The St. Louis Band is a Bi-Valve design made with an outer shell of 1/4" polyethylene-polypropylene copolymer plastic with an inner liner made of 1/4" Aliplast foam (closed cell polyethylene). The Bi-Valve design consists of two plastic shells that overlap and are held together with rivet fasteners. The St. Louis Band utilizes a Velcro® strap with chafe and loop for a secure fit.

    The proposed device modifications include:

    (1) A clarification to the indications for use for the St. Louis Band. This change would have the device indicated for adjunctive use for infants from 3 to 18 months of age whose synostosis has been surgically corrected, but who still have moderate-to-severe cranial deformities including plagiocephalic-, brachycephalic- and scaphocephalic-shaped heads.

    (2) The addition of two new 3-dimensional shape capture methods, specifically, the STARscanner™ Data Acquisition System and the SmartSocTM System. The STARscanner is a stationary system that uses Class I Lasers and cameras to record surface data for shape capture. The SmartSoc System is a hand held system that uses a flexible fabric sock with a customized non-repetitive printed pattern and a consumer grade digital camera with it's a built-in flash light source. The built-in flash feature is a non-coherent (i.e. non-laser light) light source. Both of these shape capture systems are cleared with the STARband predicate device (K151979).

    AI/ML Overview

    The provided text describes the acceptance criteria and study proving the device meets them for the Orthomerica Products, Inc. "St. Louis Band" cranial orthosis (K161138), primarily focusing on the addition of new 3D shape capture methods (STARscanner and SmartSoc System) rather than the orthosis itself.

    Here's an analysis of the requested information, based on the provided document:

    Acceptance Criteria and Reported Device Performance

    Acceptance Criteria / TestReported Device Performance
    Repeatability and Reproducibility (R&R) AnalysisThe shape capture devices (STARscanner and SmartSoc System) passed the acceptance criteria. The relevancy of the tests determined substantial equivalence of the proposed shape capture devices to the casting process.
    Cranial Shape Capture Accuracy StudyThe shape capture devices (STARscanner and SmartSoc System) passed the acceptance criteria for all parameters (A-P, M-L, P-D, various radius parameters, squareness, and flatness). The relevancy of the test determined substantial equivalence of the proposed shape capture device to the casting process.
    Material Biocompatibility Testing (Copolymer with Aliplast Foam)Closed Patch Sensitization: A score of 0.00/0.00 (Test/Control) was given for both Incidence and Severity in the 24-hour and 48-hour scoring interval, concluding "Not a Sensitizer" and "No Erythema or Edema Formation." Primary Dermal Irritation: Primary Irritation Index: 0.00, concluding "Negligible Dermal Response." Cytotoxicity – Agar Diffusion: Cell culture treated with test sample exhibited slight reactivity (Grade 1), concluding "Non-cytotoxic."

    Study Details for Shape Capture Devices

    This document primarily focuses on the validation of the new 3D shape capture methods (STARscanner and SmartSoc System) for manufacturing the St. Louis Band, not clinical efficacy of the band itself with these new methods.

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

      • Repeatability and Reproducibility (R&R) Analysis: "Utilized uniform shapes with known dimensions that represent various sizes of pediatric patients between ages 3 to 18 months of age." The specific number of shapes or scans is not provided.
      • Cranial Shape Capture Accuracy Study: "Utilized a representative cranial shape that possesses a predefined shape with known dimensions." The specific number of shapes or scans is not provided.
      • Data Provenance: Not specified, but given the manufacturing context, it's likely internal testing by the manufacturer. It is not specified if it was retrospective or prospective, but the nature of the tests suggests bespoke testing/data collection.
    2. 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)

      • For both R&R and Accuracy studies, the ground truth was established by "uniform shapes with known dimensions" and a "representative cranial shape that possesses a predefined shape with known dimensions." This implies engineered or measured physical models, not human expert assessment of clinical cases. Therefore, no clinical experts were used for ground truth for these specific tests on the shape capture devices.
    3. Adjudication method (e.g. 2+1, 3+1, none) for the test set

      • Not applicable as the ground truth was based on physical models with known dimensions. There was no clinical adjudication process described for these engineering validation tests.
    4. 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 MRMC or comparative effectiveness study involving human readers or AI assistance in a clinical diagnostic context was described. The testing focused on the accuracy and precision of the shape capture devices for manufacturing, comparing them to a traditional casting method.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

      • The "standalone" performance here refers to the device's ability to accurately capture shape data compared to a physical reference ("casting process" or "known dimensions"). This was evaluated. The results indicate that the STARscanner and SmartSoc System "passed the acceptance criteria" and were "substantially equivalent" to the casting method in terms of accuracy and repeatability/reproducibility.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

      • For the R&R and Accuracy studies of the shape capture devices, the ground truth was based on known dimensions of uniform/representative physical shapes/models, not clinical data from patients or expert consensus.
    7. The sample size for the training set

      • The document does not describe a "training set" in the context of an AI/machine learning algorithm. The tests are for the accuracy and precision of a measurement device, not a classification or diagnostic algorithm.
    8. How the ground truth for the training set was established

      • Not applicable as no AI/ML training set is mentioned or implied. The ground truth for the validation tests was established by physical models with precisely known dimensions.
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    K Number
    K151979
    Date Cleared
    2015-09-18

    (63 days)

    Product Code
    Regulation Number
    882.5970
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    OAN

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

    The STARband and STARlight are intended for medical purposes for use on infants from 3 to 18 months of age, with moderate-to-severe non-synostotic positional plagiocephaly, infants with plagiocephalic-, brachycephalic- and scaphocephalic-shaped heads by applying mild pressure to prominent regions of the infant's cranium in order to improve cranial symmetry and/or shape. The devices are also indicated for infants from 3 to 18 months of age whose synostosis has been surgically corrected, but who still have moderate-to-severe cranial deformities including plagiocephalic-, brachycephalic- and scaphocephalic-shaped heads.

    Device Description

    The STARband and STARlight redirects the head growth to improve proportion and symmetry. The practitioner takes a plaster impression or 3-dimensional captured image of the infant's head to acquire the existing shape. The mold is sealed and filled with plaster or the 3-dimensional image is carved from a rigid polyurethane foam blank to create a positive model of the head shape. The positive model is modified to obtain greater symmetry and space in the areas of flattening. The STARband and STARlight provide total contact over the prominent or bossed areas of the baby's head to discourage growth there. Over the course of treatment, the inside of the band is further modified by the practitioner to provide space for growth to occur in the flat or depressed areas. The shape of the STARband and STARlight directs growth into the areas of least resistance and creates a precise pathway for the head shape to improve in symmetry and proportion.

    The STARband and STARlight product families as it was released in K141842 are essentially still the same devices. The STARband Side Opening design and STARband Bi-Valve design is made with an outer shell of 5/32" polyethylene-polypropylene copolymer plastic with an inner liner made of 1/2" pelite polyethylene foam or 1/2" Aliplast foam (closed cell polyethylene). The STARlight Side Opening design and the STARlight Bi-Valve design are made of a plastic shell of 5/32" - 1/4" clear Surlyn or 1/8" - 7/32" Clear Co-Polyester. The STARlight PRO (Post-operative Remolding Orthosis) design is made of 1/4" to 3/8" clear Surlyn. Optional Aliplast (closed cell polyethylene) padding is available for the clear plastic bands and in addition, optional Reston (polyurethane - 3M Medical Product) foam is available for the STARlight PRO design.

    The STARband Side Opening design and the STARlight Side Opening design has a top opening and a side opening. The band is held in place by a Velcro strap (1½" for STARband Side Opening and 1" for STARlight Side Opening) across the side opening. The STARlight PRO has two side openings, no top opening, and is held in place by a Velcro strap across each side opening. The STARlight Bi-Valve design and the STARband Bi-Valve design consist of two plastic shells that overlap with a sliding mechanism. The right and left overlap tabs are connected via a Velcro strap with chafe and loop.

    The proposed device modification is the addition of a new 3-dimensional shape capture method, specifically, the Vorum Spectra™ 3D Scanner uses a high quality LED structured light projector and a single camera to detect the shape of the surface captured. This scanner utilizes LED light which is a non-coherent (i.e. non-laser) light source.

    AI/ML Overview

    This document describes the acceptance criteria and study proving the device meets these criteria for the STARband® and STARlight® Cranial Orthosis, specifically focusing on the addition of the Vorum Spectra™ 3D Scanner as a new method for capturing infant head shape.

    Here's a breakdown of the requested information:

    1. Table of Acceptance Criteria and Reported Device Performance:

    TestAcceptance Criteria (Implied)Reported Device Performance
    Repeatability & Reproducibility (R&R) AnalysisTo demonstrate that the proposed shape capture device (Spectra 3D Scanner) shows similar repeatability and reproducibility to the casting process and the predicate device for parameters like A-P (Anterior-Posterior) and M-L (Medial-Lateral) dimensions.The shape capture device passed the acceptance criteria, demonstrating substantial equivalence to the predicate device.
    Cranial Shape Capture Accuracy StudyTo demonstrate that the proposed shape capture device (Spectra 3D Scanner) shows similar accuracy to the casting process and the predicate device for parameters like A-P, M-L, P-D (Posterior-Divergency), various radius parameters, squareness, and flatness using a predefined cranial shape with known dimensions.The shape capture device passed the acceptance criteria for all parameters, demonstrating substantial equivalence to the predicate device.
    Material Biocompatibility Testing- Not a Sensitizer (for Closed Patch Sensitization)
    • Negligible Dermal Response (for Primary Dermal Irritation)
    • Non-cytotoxic (for Cytotoxicity – Agar Diffusion) | All materials (Surlyn, Copolymer with Pelite Foam, Copolymer with Aliplast Foam) met the acceptance criteria for non-sensitization, negligible dermal irritation, and non-cytotoxicity (with one noted slight reactivity for Copolymer with Aliplast Foam, still deemed non-cytotoxic). |

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

    • R&R Analysis & Cranial Shape Capture Accuracy Study: The document mentions "Utilized uniform shapes with known dimensions that represent various sizes of pediatric patients between ages 3 to 18 months of age" for the R&R analysis, and "Utilized a representative cranial shape that possesses a predefined shape with known dimensions" for the accuracy study. Specific numeric sample sizes are not provided in the given text.
    • Data Provenance: The studies were conducted by Orthomerica Products, Inc., likely within their internal testing processes. The country of origin and whether the data was retrospective or prospective is not explicitly stated for these performance studies. However, as it's for a 510(k) submission, it would typically be prospective testing conducted by the manufacturer.

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

    • Not applicable for these engineering performance studies. The ground truth for the R&R analysis and Cranial Shape Capture Accuracy Study was established using "uniform shapes with known dimensions" and "a representative cranial shape that possesses a predefined shape with known dimensions." This implies the "ground truth" was a precisely manufactured physical standard with measurable dimensions. No human expert interpretation was required.

    4. Adjudication Method for the Test Set:

    • Not applicable. As the ground truth was based on physical standards with known dimensions, human adjudication was not part of these engineering performance tests.

    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 is not an AI-assisted diagnostic device, but rather a medical device (cranial orthosis) with a new 3D scanning method for fabrication. Therefore, an MRMC comparative effectiveness study involving human readers and AI assistance would not be relevant.

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

    • Yes, effectively. The performance studies (R&R and Cranial Shape Capture Accuracy) evaluated the Spectra 3D Scanner itself (an "algorithm only" component in the context of data capture) against known physical standards and compared its results to existing methods (casting and predicate devices). The scanner's output (3D head shape data) is then used in a manufacturing process, but the studies focused on the performance of the scanner as a standalone data capture tool.

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

    • For the Repeatability and Reproducibility (R&R) Analysis and Cranial Shape Capture Accuracy Study, the ground truth was based on known dimensions of uniform shapes and a predefined cranial shape. This is a form of physical/reference standard.
    • For Material Biocompatibility Testing, the ground truth was established by standardized laboratory test procedures (e.g., scoring criteria for sensitization and irritation, cell reactivity grades for cytotoxicity).

    8. The Sample Size for the Training Set:

    • Not explicitly stated in the provided text. As this is a 510(k) submission for a physical device with a new input method (scanner) rather than a complex AI model, the concept of a separate "training set" for the device itself (cranial orthosis) is likely not applicable in the same way it would be for a machine learning algorithm. The scanner itself would have internal calibration and testing procedures during its development, but these are not detailed here.

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

    • Not applicable as a separate "training set" for the device's clinical performance or the scanner's core functionality is not detailed as per the response to point 8. The "ground truth" for the performance studies shown here (R&R, Accuracy) was established through precisely manufactured physical standards.
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    K Number
    K151147
    Date Cleared
    2015-07-01

    (62 days)

    Product Code
    Regulation Number
    882.5970
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    OAN

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

    The STARband and STARlight are intended for medical purposes for use on infants from 3 to 18 months of age, with moderate-to-severe non-synostotic positional plagiocephaly, infants with plagiocephalic-, brachycephalic- and scaphocephalic-shaped heads by applying mild pressure to prominent regions of the infant's cranium in order to improve cranial symmetry and/or shape. These devices are also indicated for infants from 3 to 18 months of age whose synostosis has been surgically corrected, but who still have moderate-to-severe cranial deformities including plagiocephalic-, brachycephalic- and scaphocephalic-shaped heads.

    Device Description

    The STARband and STARlight redirects the head growth to improve proportion and symmetry. The practitioner takes a plaster impression or 3-dimensional captured image of the infant's head to acquire the existing shape. The mold is sealed and filled with plaster or the 3-dimensional image is carved from a rigid polyurethane foam blank to create a positive model of the head shape. The positive model is modified to obtain greater symmetry and space in the areas of flattening. The STARband and STARlight provide total contact over the prominent or bossed areas of the baby's head to discourage growth there. Over the course of treatment, the inside of the band is further modified by the practitioner to provide space for growth to occur in the flat or depressed areas. The shape of the STARband and STARlight directs growth into the areas of least resistance and creates a precise pathway for the head shape to improve in symmetry and proportion.

    The STARband and STARlight product families as it was released in K141842 are essentially still the same devices. The STARband Side Opening design and STARband Bi-Valve design is made with an outer shell of 5/32" polyethylene-polypropylene copolymer plastic with an inner liner made of 1/2" pelite polyethylene foam or 1/2" Aliplast foam (closed cell polyethylene). The STARlight Side Opening design and the STARlight Bi-Valve design are made of a plastic shell of 5/32" - 1/4" clear Surlyn or 1/8" - 7/32" Clear Co-Polyester. The STARlight PRO (Post-operative Remolding Orthosis) design is made of 1/4" to 3/8" clear Surlyn. Optional Aliplast (closed cell polyethylene) padding is available for the clear plastic bands and in addition, optional Reston (polyurethane - 3M Medical Product) foam is available for the STARlight PRO design.

    The STARband Side Opening design and the STARlight Side Opening design has a top opening and a side opening. The band is held in place by a Velcro strap (1½" for STARband Side Opening and 1" for STARlight Side Opening) across the side opening. The STARlight PRO has two side openings, no top opening, and is held in place by a Velcro strap across each side opening. The STARlight Bi-Valve design and the STARband Bi-Valve design consist of two plastic shells that overlap with a superior sliding mechanism. The right and left overlap tabs are connected via a Velcro strap with chafe and loop.

    The proposed device modification is the addition of a new 3-dimensional shape capture method, specifically, the Rodin4D M4DScan System and the BodyScan System. The BodyScan System is the same as the M4DScan System (Hardware and Software included) except it is distributed in the United States by TechMed 3D, Inc. on behalf of Rodin4D. This system uses a structured white light projector and a single camera to detect the shape of the surface captured. This system utilizes LED white light which is a non-coherent (i.e. non-laser) light source. Because this system utilizes a non-coherent light source, it is safe to use on infant patients under all circumstances.

    AI/ML Overview

    This document describes the 510(k) premarket notification for the STARband and STARlight Cranial Orthosis, specifically focusing on the addition of the Rodin4D M4DScan System and the BodyScan System as new 3-dimensional shape capture methods.

    Here's an analysis of the acceptance criteria and study information:

    1. Table of Acceptance Criteria and Reported Device Performance

    TestAcceptance Criteria (Implied)Reported Device Performance
    Repeatability and Reproducibility (R&R) AnalysisThe new shape capture device (M4DScan/BodyScan) should demonstrate comparable repeatability and reproducibility to the casting process and the predicate device."The shape capture device passed the acceptance criteria. The relevancy of the test determined substantial equivalence of the proposed shape capture device." (Page 9)
    Cranial Shape Capture Accuracy StudyThe new shape capture device (M4DScan/BodyScan) should demonstrate comparable accuracy to the casting process and the predicate device for predefined cranial shapes and dimensions (A-P, M-L, P-D, radius parameters, squareness, flatness)."The shape capture device passed the acceptance criteria for all parameters. The relevancy of the test determined substantial equivalence of the proposed shape capture device." (Page 9)
    Material Biocompatibility Testing (Surlyn, Copolymer with Pelite Foam, Copolymer with Aliplast Foam)Materials used in the orthosis should be non-sensitizing, cause negligible dermal response, and be non-cytotoxic.Surlyn: Not a Sensitizer, No Erythema or Edema Formation (Closed Patch Sensitization); Negligible Dermal Response (Primary Dermal Irritation); Non-cytotoxic (Cytotoxicity – Agar Diffusion).
    Copolymer with Pelite Foam: Not a Sensitizer, No Erythema or Edema Formation; Negligible Dermal Response; Non-cytotoxic.
    Copolymer with Aliplast Foam: Not a Sensitizer, No Erythema or Edema Formation; Negligible Dermal Response; Non-cytotoxic (Note: exhibited slight reactivity (Grade 1) in Cytotoxicity, but conclusion states Non-cytotoxic, implying it met the criteria). (Page 10)

    Note on Acceptance Criteria: The document primarily states that the devices "passed the acceptance criteria" and demonstrated "substantial equivalence" rather than explicitly delineating numerical thresholds for acceptance. The acceptance criteria are inferred from the stated purpose of the tests (comparing to predicate/casting process and finding substantial equivalence).

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

    • R&R Analysis & Cranial Shape Capture Accuracy Study:
      • Sample Size: The document states the tests "Utilized uniform shapes with known dimensions that represent various sizes of pediatric patients between ages 3 to 18 months of age" and "Utilized a representative cranial shape that possesses a predefined shape with known dimensions" (Page 9). However, specific numerical sample sizes for the test set (number of uniform shapes, number of measurements, etc.) are not provided.
      • Data Provenance: Not explicitly stated (e.g., country of origin, retrospective/prospective). The study appears to be a laboratory/benchtop study using uniform or representative cranial shapes, not patient data.

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

    • R&R Analysis & Cranial Shape Capture Accuracy Study: The ground truth was established by "predefined shape with known dimensions" of uniform or representative cranial shapes (Page 9). This implies that the ground truth was based on engineered or calibrated measurements of these physical models, not expert human assessment. Therefore, no experts were used to establish the ground truth for these specific tests.

    4. Adjudication Method for the Test Set

    • Since the ground truth was based on precisely measured physical models or known dimensions, and not human interpretation, no adjudication method (like 2+1, 3+1) was necessary or performed.

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

    • No MRMC comparative effectiveness study was mentioned or performed. The clearance is for a medical device (cranial orthosis) and a new shape capture method, not an AI diagnostic algorithm that assists human readers.

    6. Standalone (Algorithm only without human-in-the-loop performance) Study

    • Yes, a standalone study was performed for the shape capture devices. The R&R Analysis and Cranial Shape Capture Accuracy Study directly evaluated the performance of the M4DScan/BodyScan System itself in accurately capturing known shapes, comparing its measurements to predefined dimensions (ground truth) and to other existing shape capture methods (casting process and predicate devices). This is essentially a standalone performance evaluation of the new technology.

    7. The Type of Ground Truth Used

    • For the R&R Analysis and Cranial Shape Capture Accuracy Study: The ground truth used was based on "uniform shapes with known dimensions" and "a representative cranial shape that possesses a predefined shape with known dimensions." This is akin to engineered ground truth or physical model measurements, where the true dimensions are precisely known.
    • For Biocompatibility Testing: The ground truth was established by recognized biological assay standards and methodologies (e.g., scoring systems for sensitization, irritation, and cytotoxicity) as per ISO 10993 standards (implied, though not explicitly cited in detail).

    8. The Sample Size for the Training Set

    • This document is for a medical device and a shape capture method, not an AI model that requires a "training set" in the machine learning sense. The device is a physical orthosis and the M4DScan/BodyScan system is a 3D scanner.
    • Therefore, the concept of a "training set" as traditionally understood for machine learning models is not applicable here, and no specific training set sample size is mentioned.

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

    • As the concept of a "training set" is not applicable, the establishment of ground truth for a training set is also not relevant to this submission.
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    K Number
    K142141
    Date Cleared
    2015-04-23

    (261 days)

    Product Code
    Regulation Number
    882.5970
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    OAN

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

    The STARband and STARlight are intended for medical purposes for use on infants from 3 to 18 months of age, with moderate-to-severe non-synostotic positional plagiocephaly, including infants with plagiocephalic-, and scaphocephalic-shaped heads by applying mild pressure to prominent regions of the infant's cranium in order to improve cranial symmetry and/or shape. These devices are also indicated for adjunctive use for infants from 3 to 18 months of age whose synostosis has been surgically corrected, but who still have moderate-to-severe cranial deformities including plagiocephalic-, brachycephalic-, and scaphocephalic-shaped heads.

    Device Description

    The STARband and STARlight redirects the head growth to improve proportion and symmetry. The practitioner takes a plaster impression or 3-dimensional captured image of the infant's head to acquire the existing shape. The mold is sealed and filled with plaster or the 3-dimensional image is carved from a rigid polyurethane foam blank to create a positive model of the head shape. The positive model is modified to obtain greater symmetry and space in the areas of flattening. The STARband and STARlight provide total contact over the prominent or bossed areas of the baby's head to discourage growth there. Over the course of treatment, the inside of the band is further modified by the practitioner to provide space for growth to occur in the flat or depressed areas. The shape of the STARband and STARlight directs growth into the areas of least resistance and creates a precise pathway for the head shape to improve in symmetry and proportion.

    The STARband Side Opening design and STARband Bi-Valve design is made with an outer shell of 5/32" polyethylene-polypropylene copolymer plastic with an inner liner made of 1/2" pelite polyethylene foam or 1/2" Aliplast foam (closed cell polyethylene). The STARlight Side Opening design and the STARlight Bi-Valve design are made of a plastic shell of 5/32" - 1/4" clear Surlyn or 1/8" - 7/32" Clear Co-Polyester. The STARlight PRO (Post-operative Remolding Orthosis) design is made of 1/4" to 3/8" clear Surlyn. Optional Aliplast (closed cell polyethylene) padding is available for the clear plastic bands and in addition, optional Reston (polyurethane - 3M Medical Product) foam is available for the STARlight PRO design.

    The STARband Side Opening design and the STARlight Side Opening design has a top opening and a side opening. The band is held in place by a Velcro strap (1½" for STARband Side Opening and 1" for STARlight Side Opening) across the side opening. The STARlight PRO has two side openings, no top opening, and is held in place by a Velcro strap across each side opening. The STARlight Bi-Valve design and the STARband Bi-Valve design consist of two plastic shells that overlap with a superior sliding mechanism. The right and left overlap tabs are connected via a Velcro strap with chafe and loop.

    The proposed device modification is a new software component for a previously cleared shape capture method, the STARscanner™ Data Acquisition System. The new software component is the Cranial Comparison Utility (CCU). The CCU is a separate software program that is designed to present specific measurements derived from a threedimensional (3D) digital model of a patient's cranium. These features are useful to medical professionals by providing more detailed shape data that can be incorporated into the patient evaluation/assessment and for tracking cranial head shape changes.

    AI/ML Overview

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

    The document describes the Cranial Comparison Utility (CCU) as a software component for the previously cleared STARscanner™ Data Acquisition System, which is used for the fabrication of STARband and STARlight Cranial Orthoses. The acceptance criteria and performance data specifically address the CCU.

    Acceptance Criteria (Stated Goal for CCU)Reported Device Performance (CCU)
    Accuracy of measurements"CCU Accuracy and Capabilities Study" was conducted. This study "Utilized a representative cranial shape that possesses a predefined shape with known dimensions" and "Compared CCU to manual measurements and 3D-CAD software." The study "Accessed accuracy of measurements and capabilities of model alignment, differential maps, calculations and reporting." The conclusion states: "The software program provides accurate information of 3D digital models from the STARscanner Data Acquisition System." and "an accuracy and capability study was conducted on the CCU and was determined to be acceptable. With sufficient accuracy..."
    Capabilities (model alignment, differential maps, calculations, reporting)The CCU Accuracy and Capabilities Study "Accessed accuracy of measurements and capabilities of model alignment, differential maps, calculations and reporting." The conclusion states: "...the CCU demonstrated a safety and effectiveness profile similar to the predicate device for measuring pediatric head shapes digital models provided from the STARscanner."
    Safety of software program"no concerns with the safety of the software program" was reported.
    Non-interference with manufacturing"The CCU does not affect the operation of the STARscanner and is not used for manufacturing of the STARband or STARlight."

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

    • Test Set Sample Size: The document states that the "CCU Accuracy and Capabilities Study" "Utilized a representative cranial shape that possesses a predefined shape with known dimensions." It does not specify a numerical sample size in terms of the number of unique patient scans or models. Instead, it refers to a single "representative cranial shape." This suggests a phantom or a standardized model rather than a dataset of patient scans.
    • Data Provenance: The document does not explicitly state the country of origin or if the data was retrospective or prospective. Given the nature of a "representative cranial shape" with "predefined shape and known dimensions," it is highly likely this refers to a synthetic or phantom model used in a controlled laboratory setting, rather than real patient data.

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

    The document does not mention the number or qualifications of experts used to establish the ground truth for the CCU's test set. The ground truth was established by "predefined shape with known dimensions" and "manual measurements and 3D-CAD software." This suggests that the ground truth was derived from engineering specifications and objective measurements rather than subjective expert consensus on patient data.

    4. Adjudication method for the test set:

    Not applicable. The ground truth for the CCU's performance was established using objective "predefined shape with known dimensions" and comparison to "manual measurements and 3D-CAD software." There was no multi-reader or human adjudication process 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:

    No, an MRMC comparative effectiveness study was not done. The CCU is a software tool for measurement and analysis of 3D cranial models, not an AI-assisted diagnostic tool for human readers. It provides "more detailed shape data that can be incorporated into the patient evaluation/assessment and for tracking cranial head shape changes" by medical professionals, but it does not describe human reader performance with or without the CCU.

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

    Yes, a standalone study evaluating the CCU (algorithm only) was performed. The "CCU Accuracy and Capabilities Study" assessed the accuracy of measurements and capabilities entirely of the software by comparing its output to "manual measurements and 3D-CAD software" on a "representative cranial shape."

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

    The ground truth used for the CCU's accuracy and capabilities study was based on:

    • "Predefined shape with known dimensions" of a representative cranial shape. This implies a precisely manufactured physical model or a digitally engineered model with exact specifications.
    • Comparison to "manual measurements and 3D-CAD software." This suggests that precise reference measurements from established tools were used as the gold standard.

    8. The sample size for the training set:

    The document does not describe a "training set" for the CCU. This suggests that the CCU software likely relies on deterministic algorithms for geometric measurements and comparisons, rather than machine learning models that require training data.

    9. How the ground truth for the training set was established:
    As no training set is described for the CCU, the method for establishing its ground truth is not applicable.

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    K Number
    K133250
    Device Name
    STARLIGHT
    Date Cleared
    2014-01-16

    (86 days)

    Product Code
    Regulation Number
    882.5970
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    OAN

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

    The STARlight is intended for medical purposes for use on infants from 3 to 18 months of age, with moderate-to-severe non-synostotic positional plagiocephaly, including infants with plagiocephalic-, brachycephalic- and scaphocephalic-shaped heads by applying mild pressure to prominent regions of the infant's cranium in order to improve cranial symmetry and/or shape. The device is also indicated for adjunctive use for infants from 3 to 18 months of age whose synostosis has been surgically corrected, but who still have moderate-to-severe cranial deformities including plagiocephalic-, brachycephalicand scaphocephalic-shaped heads.

    Device Description

    The STARlight redirects the head growth to improve proportion and symmetry. The practitioner takes a plaster impression or a scan of the infant's head to acquire the existing shape. The mold is sealed and filled with plaster or the scanned shape is carved from a rigid polyurethane foam blank to create a positive model of the head shape. The positive model is modified to obtain greater symmetry and space in the areas of flattening. The STARlight provides total contact over the prominent or bossed areas of the baby's head to discourage growth there. Over the course of treatment, the inside of the band is further modified by the practitioner to provide space for growth to occur in the flat or depressed areas. The shape of the STARlight directs growth into the areas of least resistance and creates a precise pathway for the head shape to improve in symmetry and proportion.

    The STARlight product family as it was released in K090587 are essentially still the same devices. The STARlight Side Opening design and the STARlight Bi-Valve design are made of a plastic shell of 5/32" - 1/4" clear Surlyn or 1/8" - 7/32" Clear Co-Polyester. The STARlight PRO (Post-operative Remolding Orthosis) design is made of 1/4'' to 3/8" clear Surlyn. The STARband Bi-Valve design is made with an outer shell of 5/32" polyethylene-polypropylene copolymer plastic and an inner liner of 1/2" pelite polyethylene foam. Optional Aliplast (closed cell polyethylene) padding is available for the clear plastic bands and in addition optional Reston (polyurethane - 3M Medical Product) foam is available for the STARlight PRO design.

    The STARlight Side Opening design has a top opening and a side opening. The band is held in place by a Velcro strap across the side opening. The STARlight PRO has two side openings, no top opening, and is held in place by a Velcro strap across each side opening. The STARlight Bi-Valve design and the STARband Bi-Valve design consist of two plastic shells that overlap with a superior sliding mechanism. The right and left overlap tabs are connected via a Velcro strap with chafe and loop.

    The proposed device modification is the addition of a new shape capture method. specifically the scanGogh-11" by Vorum Research, Inc. This scanner uses one laser, either Class 1 or Class 2 depending on the option, and one camera to capture shape data. The Class I laser option of the scanGogh-II is as safe as other scanner devices previously cleared for the STARlight and will not require any extra safety precautions. The Class 2 laser option is safe to use on infant patients when used in conjunction with eye protection. The Class I laser option of the scanGogh-II shall be the recommended option for scanning infants. If the Class 2 option of the scanGogh-II is used, the infant should wear eye protection as instructed in the proposed labeling.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and study information for the STARlight® Cranial Orthosis, based on the provided text:

    Acceptance Criteria and Device Performance

    The core of this submission is the addition of a new shape capture method, the scanGogh-II, for the STARlight Cranial Orthosis. The acceptance criteria and performance are tied to the accuracy of this new scanner compared to existing methods.

    Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria / Performance MetricRequirement (Implicit)Reported Device Performance (scanGogh-II vs. Cast)
    Cranial Shape Capture Accuracy StudyMaintain or improve accuracy compared to Cast method.Pass (performed superior for all listed metrics)
    Proximal RadiusSubstantially equivalent/superior to cast.Pass
    Proximal Anterior RadiusSubstantially equivalent/superior to cast.Pass
    Anterior RadiusSubstantially equivalent/superior to cast.Pass
    Anterior Posterior LengthSubstantially equivalent/superior to cast.Pass
    M-L Width AnteriorSubstantially equivalent/superior to cast.Pass
    M-L Width PosteriorSubstantially equivalent/superior to cast.Pass
    Posterior Panel FlatnessSubstantially equivalent/superior to cast.Pass
    Lateral Panel FlatnessSubstantially equivalent/superior to cast.Pass
    L-P Panels SquareSubstantially equivalent/superior to cast.Pass
    Medial Panels FlatnessSubstantially equivalent/superior to cast.Pass
    M-P Panels SquaresSubstantially equivalent/superior to cast.Pass
    Repeatability and Reproducibility (R&R) AnalysisAcceptable level of repeatability and reproducibility.Determined to be acceptable.
    Laser Safety (Class 1 Laser option)Safe for infant use without extra protection.Safe.
    Laser Safety (Class 2 Laser option)Safe for infant use with proper eye protection.Safe when used with eye protection.
    Eye Shield Fit Assessment (for Class 2 Laser option)Proper fit, complete coverage, effective protection.Pass (acceptable fit, completely covered the eye).
    Material Biocompatibility (Surlyn, Copolymer + Pelite, Copolymer + Aliplast)Non-sensitizing, negligible dermal response, non-cytotoxic.All materials passed tests as "Not a Sensitizer," "Negligible Dermal Response," and "Non-cytotoxic" (with one "slight reactivity" for Copolymer + Aliplast in Cytotoxicity).

    Study Information

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

    • Sample Size:
      • For the Cranial Shape Capture Accuracy Study: "a representative cranial shape that possesses a predefined shape with known dimensions" was utilized. This implies a single, standardized phantom or model rather than a dataset of patient scans.
      • For the Repeatability and Reproducibility (R&R) Analysis: "uniform shapes with known dimensions that represent various sizes of pediatric patients between ages 3 to 18 months of age" were utilized. No specific number is given, but it implies a set of phantoms or models.
      • For the Eye Shield Fit Assessment: "infants" were assessed. No specific number is provided.
    • Data Provenance: The studies appear to be prospective in nature, conducted specifically for this submission. The "country of origin" for this data is not explicitly stated, but given the company's location (Orlando, FL) and FDA submission, it's presumed to be within the US or compliant with US standards.

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

    • The ground truth for the Cranial Shape Capture Accuracy Study and R&R Analysis was established using "uniform shapes with known dimensions" and "a representative cranial shape that possesses a predefined shape with known dimensions". This suggests that the ground truth was based on pre-defined, precisely measured physical models or phantoms, rather than relying on human expert consensus or clinical data. Therefore, no human experts were explicitly mentioned as establishing the ground truth for the performance testing of the scanner itself.

    4. Adjudication method for the test set

    • Not applicable as the ground truth was established by known physical dimensions of models/phantoms, not by human review requiring adjudication.

    5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

    • No MRMC comparative effectiveness study was performed or needed. This device is a cranial orthosis and a new scanning method. There is no "human reader" component in the sense of image interpretation for diagnosis that would benefit from AI assistance. The scanning method replaces manual measurement or other digital scanning methods.

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

    • Yes, the performance of the scanGogh-II (the algorithm/hardware for shape capture) was evaluated in a standalone manner against known physical dimensions without a human-in-the-loop performance scenario in the context of the Cranial Shape Capture Accuracy Study and R&R Analysis.

    7. The type of ground truth used

    • Known physical dimensions of uniform and representative cranial shapes/phantoms. This is a form of engineered or precisely measured ground truth.

    8. The sample size for the training set

    • The document does not describe any "training set" in the context of machine learning or AI. This submission is for a physical medical device (cranial orthosis) and a new shape capture tool. The scanGogh-II is a scanner, not an AI algorithm that would typically require a training set to learn.

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

    • Not applicable, as no training set for an AI/ML algorithm is mentioned.
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