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510(k) Data Aggregation

    K Number
    K182215
    Date Cleared
    2018-10-29

    (75 days)

    Product Code
    Regulation Number
    878.4630
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K050695 & K100378

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

    The ClearLink Controlled Phototherapy Equipment are medical ultraviolet devices, which are intended for use, by or under the direction of a physician, for therapeutic treatment for individuals who require ultraviolet radiation for diagnosed skin disorders. When equipped with blue lamps the ClearLink Controlled Phototherapy Equipment is intended for use for the treatment of mild to moderate acne vulgaris.

    Device Description

    The ClearLink Controlled Phototherapy Equipment are medical ultraviolet devices, which are intended for use, by or under the direction of a physician, for therapeutic treatment for individuals who require ultraviolet radiation for diagnosed skin disorders. The ClearLink Phototherapy Equipment delivers treatment, with Narrow Band UVB, Broad Band UVB and/or UVA ultraviolet light. Treatments are controlled through the ClearLink Software interface. Access to this interface and stored information is restricted to individuals who have been established by the physician as authorized operators. Authorized operators program treatments in joules based on established treatment protocols governed by the patient's skin type, condition, minimum erythemal dose (M.E.D.), and treatment frequency.

    AI/ML Overview

    The provided document is a 510(k) premarket notification for the "ClearLink Controlled Phototherapy Equipment." This type of submission focuses on demonstrating substantial equivalence to a legally marketed predicate device, rather than proving a device meets specific technical performance acceptance criteria through the kind of rigorous, independent study typically associated with AI/software as a medical device (SaMD).

    Therefore, this document does not contain the information requested regarding acceptance criteria and a study proving a device meets them in the context of an AI/SaMD. This device is a phototherapy unit, and its substantial equivalence is based on its construction, intended use, energy sources, and control system updates, rather than diagnostic performance metrics.

    Specifically, the document does not provide:

    • A table of acceptance criteria and reported device performance (in the sense of AI performance metrics like sensitivity, specificity, AUC).
    • Any details about a test set sample size, data provenance, or ground truth establishment by experts for diagnostic purposes.
    • Information on Multi-Reader Multi-Case (MRMC) studies or standalone algorithm performance.

    The "Performance Standards" section (page 6) explicitly states: "The ClearLink controlled phototherapy equipment performance data is the same as or very similar to that of the claimed predicate device. The ultraviolet light tubes and cabinet construction used in the production of the predicate device and the ClearLink controlled phototherapy equipment are the same. The only difference between the predicate flex devices and the link devices is the substitution of the link controller for the flex controller for actual entry of doses. The rest of the devices (materials, construction, treatment modality, patient safety, etc., remains exactly the same."

    This statement highlights that the performance here refers to the physical and functional constancy with the predicate device, not the diagnostic accuracy or efficacy evaluation of an AI component.

    In summary, none of the requested information regarding acceptance criteria, study design parameters (sample size, experts, ground truth, MRMC), or training set details for an AI/SaMD are present in this document because it is not an AI/SaMD submission.

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