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510(k) Data Aggregation

    K Number
    K150419
    Manufacturer
    Date Cleared
    2015-06-19

    (121 days)

    Product Code
    Regulation Number
    878.4400
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    OUB

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

    The miraDry System MD4000 is indicated for use in the treatment of primary axillary hyperhidrosis plus unwanted underarm hair removal, and permanent reduction of underarm hair of all colors for Fitzpatrick skin types I - IV.

    Permanent hair reduction is defined as long-term, stable reduction in the number of hairs reasured at 6. 9 and 12 months after the completion of a treatment regime.

    Device Description

    The miraDry System MD4000 is a microwave device designed to heat tissue located at the dermal- hypodermal interface where the axillary sweat glands and hair bulbs reside using a surface contact applicator. The miraDry System MD4000 consists of: the MD4000-MC Console; the MD4000-HP miraDry Handpiece; and a disposable, sterile MD4000-BT miraDry bioTip that snaps onto the Handpiece to provide a sterile protective cover.

    As described in K131162, the miraDry System MD4000 also includes Class I components/accessories. The MD4000-TS template system is a required component for the miraDry treatment as well as the MD4000-PK priming kit. The MD4000-PK priming kit is required when the system is initially set up at a user facility. Optional accessories include an armrest and disposable ice packs.

    The MD4000-MC Console is a software-driven device which contains circuit boards, a microwave generator, integrated vacuum and cooling systems, and an integrated touch-screen user interface.

    The non-invasive miraDry Handpiece is specifically designed to deliver microwave energy to the skin at specified frequency and power levels. The proximal end of the Handpiece has a cable bundle and a console connector that supplies the energy and cooling to the Handpiece. The distal end has a sterile, disposable barrier, the miraDry bioTip, which contacts the patient.

    AI/ML Overview

    Here's an analysis of the acceptance criteria and study detailed in the provided document, restructured to address your specific points:

    The document describes the Miramar Labs miraDry System MD4000, which has an expanded indication for underarm hair removal in addition to primary axillary hyperhidrosis treatment. The information below focuses on the hair removal aspect.

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance CriteriaReported Device Performance (Hair Reduction)
    Primary Endpoint: >30% reduction (baseline to 3 months, measured by hair counts) in >50% of subjects.88.1% (37/42) of subjects showed >30% hair reduction at 3 months (lower 95% CL: 76.6%). This met the criterion.
    Secondary Endpoint: >30% reduction (comparing baseline to 12 months photos) to make a claim for permanent axillary hair reduction.95.5% (42/44) of subjects showed >30% hair reduction at 12 months (lower 95% CL: 86.4%). This met the criterion.
    Average Reduction:
    - 3 months: 66% (± 30%)
    - 6 months: 72% (± 29%)
    - 9 months: 75% (± 28%)
    - 12 months: 75% (± 27%)
    Side-by-side axilla review:
    - 3 months: 74% of pairs had at least 26-50% reduction
    - 6 months: 78% of pairs had at least 26-50% reduction
    - 9 months: 78% of pairs had at least 26-50% reduction
    - 12 months: 89% of pairs had at least 26-50% reduction
    Patient satisfaction with hair reduction (rating "very satisfied" or "somewhat satisfied"):
    - 3 months: 81%
    - 6 months: 70%
    - 9 months: 68%
    - 12 months: 70%

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

    • Sample Size: 56 subjects were enrolled.
      • For the primary endpoint (3-month hair count): 42 subjects were assessable.
      • For the secondary endpoint (12-month hair count): 44 subjects were assessable.
    • Data Provenance: The study was conducted at three private dermatology clinics in the United States. It was a prospective clinical trial, initiated in September 2012.

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

    • The document states that an "independent physician reviewer" conducted a blinded comparison of baseline to follow-up full-axilla photos to score hair reduction.
    • The specific number of independent physician reviewers is not explicitly stated (e.g., "an independent physician reviewer" could imply one, or a panel reviewed by one lead).
    • The qualifications of the independent physician reviewer(s) are not detailed beyond "physician."

    4. Adjudication Method for the Test Set

    • The document primarily mentions a "blinded comparison of baseline to follow-up full-axilla photos by an independent physician reviewer," implying a single reviewer's assessment for photo-based evaluation.
    • For hair counts, the method of counting and potential adjudication is not explicitly described. Given it's a quantitative measure, it might rely on standardized methods rather than expert adjudication in the same way image review would.

    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, a Multi Reader Multi Case (MRMC) comparative effectiveness study was not done.
    • This study evaluates the device's direct performance in hair reduction, not the influence of AI on human reader performance. The device itself is the treatment, not an AI diagnostic aid.

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

    • Yes, this was a standalone performance study of the device/treatment itself. The device, the miraDry System MD4000, is a therapeutic device that physically reduces hair. The study assesses the effectiveness of this physical treatment in a clinical setting, without any AI algorithm involved in the treatment delivery or primary assessment.
    • The "performance" described is the direct clinical outcome from using the miraDry system.

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

    The ground truth was established using a combination of:

    • Quantitative Measurement: Hair counts (primary method).
    • Expert Review: Blinded comparison of baseline and follow-up photos by an independent physician reviewer.
    • Patient-Reported Outcomes: Subject assessment of overall satisfaction, odor rating, and sweat ratings (though sweat and odor are related to the hyperhidrosis indication, they were collected).
    • Clinical Observation: Assessment of adverse events.

    8. The Sample Size for the Training Set

    • The document describes a clinical trial (performance study) for the expanded indication. It does not mention a "training set" in the context of an AI algorithm or a machine learning model.
    • Therefore, N/A (Not Applicable) as this is not an AI/ML device.

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

    • N/A (Not Applicable) as there was no training set mentioned in the context of an AI/ML device.
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    K Number
    K131162
    Device Name
    MIRADRY SYSTEM
    Manufacturer
    Date Cleared
    2013-10-25

    (184 days)

    Product Code
    Regulation Number
    878.4400
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    OUB

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

    The miraDry System is indicated for use in the treatment of primary axillary hyperhidrosis. Note: The miraDry System is not indicated for use in the treatment of hyperhidrosis related to other body areas or generalized hyperhidrosis.

    Device Description

    The miraDry System is a microwave device designed to heat tissue located at the dermal- hypodermal interface where the axillary sweat glands reside using a surface contact applicator. The miraDry System consists of: the MD4000-MC Console; the MD4000-HP miraDry Handpiece; and a disposable, sterile MD4000-BT miraDry bioTip that snaps onto the Handpiece to provide a sterile protective cover. As described in K103014, the miraDry System also includes Class I components/accessories. The MD4000-TS template system is a reguired component for the miraDry treatment as well as the MD4000-PK priming kit. The MD4000-PK priming kit is required when the system is initially set up at a user facility. Optional accessories include an Armrest and disposable ice packs. The MD4000-MC Console is a software-driven device which contains circuit boards, a microwave generator, integrated vacuum and cooling systems, and an integrated touch-screen user interface. The non-invasive miraDry Handpiece is specifically designed to deliver microwave energy to the skin at specified frequency and power levels. The proximal end of the Handpiece has a cable bundle and a console connector that supplies the energy and cooling to the Handpiece. The distal end has a sterile, disposable barrier, the miraDry bioTip, which contacts the patient. The technological characteristics and the principles of operation for the MD4000 miraDry System are the same as the predicate miraDry System.

    AI/ML Overview

    This 510(k) summary describes a modified version of the miraDry System, which is a microwave device for treating primary axillary hyperhidrosis. The submission (K131162) concerns the substantial equivalence of the modified device to a predicate device (K103014).

    Based on the provided text, the submission focuses on demonstrating that the modified miraDry System is substantially equivalent to its predicate, rather than presenting a study that establishes new acceptance criteria or proves the device meets entirely new performance metrics. The core argument for substantial equivalence is that the modifications do not raise new questions of safety or effectiveness.

    Therefore, the structure of the acceptance criteria and study proving it are presented as conformance to existing standards and equivalence to the predicate.

    Here's a breakdown of the information as requested, though some categories may not be directly applicable due to the nature of a substantial equivalence submission for device modification:


    Acceptance Criteria and Device Performance (Based on Substantial Equivalence and Standards Conformance)

    Acceptance Criteria CategorySpecific Criteria / RequirementReported Device Performance (Modified miraDry System, K131162)
    Indications for UseIdentical to predicate device (K103014)"The miraDry System bears the following Indications for Use statement that is identical to the FDA authorized indications for use for the predicate." (Intended Use section)
    Technological CharacteristicsEquivalent to predicate device (K103014)"The technological characteristics and the principles of operation for the MD4000 miraDry System are the same as the predicate miraDry System." (Device Description Section)
    Safety Standards ConformanceConformance to relevant IEC 60601 series standardsIEC 60601-1:2005 + A1:2012 (Medical Electrical Equipment - General Requirements for Safety)
    IEC 60601-1-2:2007 (Medical Electrical Equipment - Electromagnetic Compatibility)
    IEC 60601-1-6:2010 (Medical Electrical Equipment - Usability)
    IEC 60601-2-6:2012 (Medical Electrical Equipment - Particular Requirements for the Safety of Microwave Therapy Equipment) (All found in "Testing" section)
    Material Safety/BiocompatibilityMeet strict design requirements for durability and biocompatibility"All materials used in the manufacture of the modified miraDry System have been demonstrated to meet strict design requirements, including requirements for durability and biocompatibility, and are therefore suitable for use..." (Materials section)
    No New Questions of Safety or EffectivenessModifications do not introduce new safety or effectiveness concerns compared to predicate"Based on the risk assessment of the modifications, bench testing and pre-clinical testing were performed to ensure continued conformance to all product specifications, and equivalence to the predicate device." (Testing section)
    "There are no changes in materials that raise questions of safety or effectiveness." (Materials section)

    Study Details Demonstrating Substantial Equivalence

    The provided text describes the rationale and testing performed to demonstrate substantial equivalence for a modification to an already cleared device, rather than a de novo clinical study proving the primary efficacy of the miraDry system itself.

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

      • The document mentions "bench testing and pre-clinical testing" for the modifications. However, specific sample sizes for these tests are not provided within this 510(k) summary.
      • Data provenance: Not explicitly stated, but the testing would typically be conducted by the manufacturer, Miramar Labs, Inc. The nature of the testing (bench and pre-clinical) suggests laboratory/engineering data rather than human clinical trial data for direct performance comparison in patients.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

      • Not applicable in the context of this 510(k) summary. "Ground truth" in the clinical sense (e.g., disease diagnosis) is not established by a panel of experts for this substantial equivalence submission. The "truth" here is the conformance to engineering standards and equivalence to the predicate, which is evaluated by the submitter and FDA.
    3. Adjudication method (e.g., 2+1, 3+1, none) for the test set:

      • Not applicable. Adjudication methods are typically used in clinical studies involving interpretation of medical images or patient outcomes. The testing described here is focused on engineering and functional performance.
    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, an MRMC study was not done. This device is an electrosurgical cutting and coagulation device (microwave therapy for hyperhidrosis), not an AI-based diagnostic imaging tool that would typically undergo MRMC studies.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

      • Not applicable. This device is a physical system that requires human operation. The concept of "standalone algorithm" does not apply to this type of medical device.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

      • For the "bench testing and pre-clinical testing" conducted for the modifications, the 'ground truth' would be defined by engineering specifications, design requirements, and established performance parameters of the predicate device. These would be used to verify that the modified device performs as expected and similarly to the original. For the safety standards, the 'ground truth' is compliance with the requirements outlined in the cited IEC standards.
    7. The sample size for the training set:

      • Not applicable. This device does not employ machine learning or AI algorithms that require a "training set" in the conventional sense.
    8. How the ground truth for the training set was established:

      • Not applicable. (See point 7).

    Summary of the Study for this 510(k):

    The core "study" for K131162 is a technical and risk assessment to demonstrate substantial equivalence of a modified miraDry System to its predicate (K103014). This involved:

    • Comparison of Indications for Use: Showing identity to the predicate.
    • Comparison of Technological Characteristics: Demonstrating they are the same as the predicate.
    • Bench Testing and Pre-clinical Testing: Performed to ensure the modified aspects (e.g., new materials for durability, functional changes) continue to conform to product specifications and maintain equivalence to the predicate. This testing addressed potential risks associated with the modifications.
    • Conformance to International Electrotechnical Commission (IEC) Standards: The device was tested and found to conform to multiple IEC 60601 series standards related to general safety, electromagnetic compatibility, usability, and specific requirements for microwave therapy equipment.

    The conclusion drawn from these activities is that the device "is substantially equivalent to the predicate device... The indications for use and technological characteristics are equivalent; therefore, the miraDry System is substantially equivalent to the predicate device."

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    K Number
    K103014
    Device Name
    MIRADRY SYSTEM
    Manufacturer
    Date Cleared
    2011-01-28

    (107 days)

    Product Code
    Regulation Number
    878.4400
    Reference & Predicate Devices
    Why did this record match?
    Product Code :

    OUB

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

    The miraDry System is indicated for use in the treatment of primary axillary hyperhidrosis.

    Note: The miraDry System is not indicated for treating hyperhidrosis related to other body areas or generalized hyperhidrosis.

    Device Description

    The miraDry System is a microwave device designed to heat tissue located at the dermal- hypodermal interface where the sweat glands reside using a surface contact applicator. The miraDry System consists of: the DTS3000 Console: the miraDry Handpiece; and a disposable, sterile miraDry bioTip that snaps onto the Handpiece to provide a sterile protective cover.

    The DTS3000 Console is a software-driven device which contains circuit boards, a microwave generator, integrated vacuum and cooling systems, and an integrated touch-screen user interface.

    The non-invasive miraDry Handpiece is specifically designed to deliver microwave energy to the skin at specified frequency and power levels. The proximal end of the Handpiece has a cable bundle and console connector that supplies the energy and cooling to the Handpiece. The distal end has a sterile, disposable barrier, the miraDry bioTip, that contacts the patient.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and the study details for the miraDry System, based on the provided 510(k) summary:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Implied)Reported Device Performance
    Safety: Device is safe for treating primary axillary hyperhidrosis.Adverse events were generally mild in severity. All but one (persistent hyperhidrosis on the face) resolved.
    Efficacy: Device effectively reduces sweat in primary axillary hyperhidrosis.A statistically significant difference in sweat reduction efficacy was demonstrated between treated subjects and sham-treated subjects.
    Biocompatibility: Patient-contacting materials are biocompatible.Patient-contacting materials have been demonstrated to be biocompatible.
    Conformance to Standards: Conforms to applicable electrical and medical device safety standards.Conforms to IEC 60601-1, IEC 60601-1-2, IEC 60601-1-4, IEC 60601-1-6, IEC 60601-2-2, and IEC 60601-2-6.
    Equivalence to Predicate Device: Thermal zones created are similar to the predicate device.Animal testing demonstrated that thermal zones created with the predicate device were similar to those created with the miraDry System.

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

    • Sample Size: 120 subjects with primary axillary hyperhidrosis.
      • Treated subjects (n=81)
      • Sham-treated subjects (n=39)
    • Data Provenance: The document does not explicitly state the country of origin. The study was a "randomized, blinded study," which generally indicates a prospective design.

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

    The document does not provide information on specific experts or their qualifications used to establish ground truth for the test set.

    4. Adjudication Method for the Test Set

    The document does not specify an adjudication method.

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

    No. The study was a comparison between the device treatment and a sham treatment, not a comparison of human readers with and without AI assistance.

    6. Standalone (Algorithm Only) Performance Study

    Yes, implicitly. The clinical study evaluated the device's performance (efficacy and safety) as a standalone treatment against a sham control, without human intervention in the device's core treatment mechanism beyond its operation by a clinician.

    7. Type of Ground Truth Used

    The ground truth for the test set was based on sweat reduction efficacy as the primary endpoint. While not explicitly stated as "expert consensus," the measurement of sweat reduction would typically involve standardized clinical assessment methods to objectively quantify sweat output.

    8. Sample Size for the Training Set

    The document does not mention a "training set" in the context of an algorithm or AI. The miraDry system is described as a microwave device, not a machine learning algorithm that requires a training set. The "training" here refers to the device's design and engineering. However, the animal testing and conformance to standards could be seen as part of the "development" or "validation" phase before clinical human trials.

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

    As the miraDry system is a physical device, not an AI algorithm, the concept of a "training set" and "ground truth for the training set" as it applies to AI is not directly relevant. The "ground truth" for the device's design and development (which could be loosely analogous to a training phase) was established through:

    • Product and animal testing: To ensure conformance to product specifications and equivalence to the predicate device.
    • Animal testing: Specifically demonstrated that thermal zones created were similar to the predicate device.
    • Conformance to international electrical and medical device standards.
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