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510(k) Data Aggregation
(86 days)
The PicoWay laser system is indicated for the following at the specified wavelength:
532nm: Removal of tattoos for Fitzpatrick skin types I-III to treat the following tattoo colors: red, yellow and orange.
785nm: Removal of tattoos for Fitzpatrick skin types II-IV to treat the following tattoo colors: green and blue.
1064nm: Removal of tattoos for all skin types (Fitzpatrick I-VI) to treat the following tattoo colors: black, brown, green, blue and purple.
The PicoWay laser system is also indicated for benign pigmented lesions removal for Fitzpatrick Skin Types I-IV.
The Resolve handpiece (1064 nm) is also indicated for the treatment of acne scars in Fitzpatrick Skin Types II-V.
The Resolve handpieces are also indicated for treatment of wrinkles in Fitzpatrick Skin Types I-IV.
The PicoWay Laser System is a solid state laser capable of delivering energy at wavelengths of 1064 nm, 785 nm, or 532 nm at short durations of 240–750 picoseconds (ps) at repetition rates up to 10 Hz (1064 nm, 532 nm) or 5 Hz (785 nm). The device system is comprised of a system console, an articulated arm, and an attached handpiece. The laser output at each wavelength is generated within the laser chassis and delivered to the skin through an articulated arm delivery system terminated by a handpiece. The light-weight and ergonomic handpieces allow the spot size on the skin to be easily adjusted. A range of spot sizes is available for the PicoWay System (up to 10 mm). The system includes an internal calibration port with an internal meter located on the control panel of the system console, which is used to verify the transmission of the articulated arm. The PicoWay system control panel enables the user to select the desired energy density level and repetition rate. The control panel is also used to obtain feedback from the system, such as the number of pulses delivered or spot size selected.
The provided text describes the FDA 510(k) summary for the PicoWay Laser System, primarily focusing on its expansion of indications for use to include the treatment of wrinkles.
Here's an analysis of the acceptance criteria and the study that proves the device meets them, based on the provided text:
Device: PicoWay Laser System
Expanded Indication: Treatment of wrinkles using the Resolve handpieces (532nm or 1064nm wavelengths)
Acceptance Criteria and Reported Device Performance
Acceptance Criteria (Primary Endpoint Criterion) | Reported Device Performance |
---|---|
80% of treated areas showing improvement in wrinkles appearance, as assessed by the correct identification of the post-treatment photograph and assessment of at least one Elastosis Score unit. | 82% of treated areas showed improvement in wrinkles appearance (exceeding the primary endpoint criterion). |
Additional findings: |
- Investigator assessments: 92% improvement rate at 12-week follow-up.
- Mean elastosis score improvement: 1.44 ± 0.83.
- Investigator satisfaction rate: 88%.
- Subjects' satisfaction rate: 74% at the last visit.
- Very positive safety profile with no adverse events (though 2 subjects reporting severe pain were counted as AEs out of caution, but resolved next day without intervention).
- Anticipated treatment responses (erythema, edema, tingling, crusting, acne breakout) observed and resolved within days without medical intervention.
- Most subjects reported low levels of pain during treatment and discomfort in the week following treatment, indicating good tolerability. |
Study Details:
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Sample Size and Data Provenance:
- Test Set Sample Size: A total of 74 subjects were enrolled, and 72 subjects were treated.
- Data Provenance: The study was a "multicenter study conducted at 4 sites in the United States." The data is prospective.
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Number and Qualifications of Experts for Ground Truth:
- Number of Experts: Two blinded evaluators.
- Qualifications: Not explicitly stated beyond "blinded evaluators." It's common in dermatology/cosmetic studies for these to be board-certified dermatologists or plastic surgeons, but the document does not specify.
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Adjudication Method for the Test Set:
- The assessment was performed by "2 blinded evaluators." The text implicitly suggests consensus or independent agreement was sought for the "correct identification of the post treatment photograph and assessment of at least one Elastosis Score unit." However, a formal adjudication process like 2+1 or 3+1 is not explicitly described. It simply states "as assessed by 2 blinded evaluators," implying their combined assessment formed the ground truth for the primary endpoint.
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Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:
- No MRMC study was conducted for human readers with and without AI assistance. This device is a laser system, not an AI diagnostic tool that assists human readers. The clinical study was a direct evaluation of the device's effect on wrinkles.
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Standalone Performance (Algorithm Only):
- N/A. This is a hardware device (laser system) used for treatment, not an algorithm for diagnosis or image analysis. The "performance" here refers to the clinical efficacy and safety of the physical device.
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Type of Ground Truth Used:
- The ground truth for the primary endpoint was established by expert assessment ("2 blinded evaluators") based on "correct identification of the post treatment photograph and assessment of at least one Elastosis Score unit." This is a subjective, observer-reported outcome measure in a clinical setting.
- Additional ground truth indicators included investigator assessments, subject satisfaction, and adverse event reporting.
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Sample Size for the Training Set:
- N/A. This is a medical device (laser system), not a machine learning algorithm that requires a separate training set. The study describes a clinical trial evaluating the device's performance directly on human subjects.
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How the Ground Truth for the Training Set Was Established:
- N/A. (See point 7).
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(125 days)
The PicoWay laser system is indicated for the following at the specified wavelength:
532nm: Removal of tattoos for Fitzpatrick skin types I-III to treat the following tattoo colors: red, yellow and orange.
785nm: Removal of tattoos for Fitzpatrick skin types II-IV to treat the following tattoo colors: green and blue.
1064nm: Removal of tattoos for all skin types (Fitzpatrick I-VI) to treat the following tattoo colors: black, brown, green, blue and purple.
The PicoWay laser system is also indicated for benign pigmented lesions removal for Fitzpatrick Skin Types I-V.
The PicoWay Laser System is a solid state laser capable of delivering energy at wavelengths of 1064 nm, 785 nm, or 532 nm at short durations of 240-750 picoseconds (ps) at repetition rates up to 10 Hz (1064 nm, 532 nm) or 5 Hz (785 nm). The device system is comprised of a system console, an articulated arm, and an attached Handpiece. The laser output at each wavelength is generated within the laser chassis and delivered to the skin through an articulated arm delivery system terminated by a Handpiece. The light-weight and ergonomic Handpieces allow the spot size on the skin to be easily adjusted. A range of spot sizes is available for the PicoWay System (up to 10 mm). The system includes an internal calibration port with an internal meter located on the control panel of the system console, which is used to verify the transmission of the laser beam into the articulated arm. The PicoWay system control panel enables the user to select the desired energy density level and repetition rate. The control panel is also used to obtain feedback from the system, such as the number of pulses delivered or spot size selected.
Here's an analysis of the acceptance criteria and study detailed in the provided text, formatted as requested:
Acceptance Criteria and Device Performance Study for PicoWay Laser System
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly state formal "acceptance criteria" for the clinical study. Instead, it reports specific outcomes and compares them to expectations based on predicate devices. I have inferred the implied performance goals based on the reported favorable safety profile and substantial clearance for tattoo removal, aligning with the "perfoRMS as intended" declaration.
Acceptance Criterion (Inferred) | Reported Device Performance |
---|---|
Favorable Safety Profile | No device-related serious adverse events. Mild erythema, edema, and pinpoint bleeding observed (anticipated responses). None to moderate discomfort/pain, consistent with predicate. No adverse events in additional Resolve handpiece studies (114 subjects). |
Substantial Clearance of Blue and Green Tattoos (785nm) | 100% of tattoos correctly identified as pre/post-treatment by 3 blinded reviewers. 83% of blue/green tattoos demonstrated at least 50% clearance compared to baseline after only 2 treatments. Investigator assessment: 83% (15/18) of blue/green tattoos achieved substantial to complete clearance. |
Equivalent Performance to Predicate Devices (Safety & Efficacy) | Study results did not present any new types of safety questions compared to predicate devices. Histological evaluation shows effects on treated area using picosecond laser energy with Resolve handpieces are equivalent between PicoWay and PicoSure devices. |
Electrical Safety & EMC Conformance | Conforms to IEC 60601-1, IEC 60601-1-2, IEC 62366, IEC 60601-1-6, IEC 60601-2-22, and IEC 60825-1. |
Biocompatibility | Established per ISO 10993 guidelines (based on predicate). |
Software Verification & Validation | Testing results found acceptable for software release. |
Bench Testing (Energy Measurements) | Met specifications. |
Bench Testing (Resolve Handpiece efficacy)* | Clears pigment particles similarly to previously cleared Zoom handpiece. 100 pulses of PicoWay 785nm resulted in greater ink clearance than 200 pulses of another legally marketed device. Achieved ink particle fracturing/de-aggregating pigment particles in a substantially equivalent manner to other systems. |
Note: The bench testing on Resolve handpiece efficacy is an important performance indicator, even if not phrased as a "criterion" in the same way as safety or clinical clearance percentages.
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: 15 subjects (22 tattoos).
- Data Provenance: The document does not explicitly state the country of origin. It describes the study as a "single arm, self-controlled study," implying it was a prospective clinical trial conducted specifically for this submission.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
- Number of Experts: 3 blinded reviewers.
- Qualifications of Experts: Not specified. The document only states "independent review by 3 blinded reviewers."
4. Adjudication Method for the Test Set
- Method: Not explicitly described as part of an adjudication process in the traditional sense for determining "ground truth." The reviewers "correctly identified the pre and post treatment for all (100%) of the tattoos," suggesting their role was to evaluate the visibility of change rather than to establish a definitive, gold-standard diagnosis or measurement. The percentage clearance was likely based on a subjective rating scale or objective measurement method applied to the images, with the reviewers' agreement confirming the detectability of this change.
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 study was done. This study evaluated the performance of the device itself (PicoWay Laser System) and not an AI-assisted diagnostic tool or human reader performance.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not applicable. This device is a laser system, not an algorithm. The clinical study evaluated the device's efficacy and safety on patients, not its performance as a standalone diagnostic tool.
7. The Type of Ground Truth Used
- For Tattoo Clearance: The "ground truth" for tattoo clearance appears to be a combination of:
- Blinded Expert Assessment: Independent review by 3 blinded reviewers who confirmed identify pre/post-treatment images.
- Quantitative/Semi-Quantitative Clinical Assessment: "At least 50% clearance compared to baseline" (how this was measured isn't detailed, but implies a scoring system).
- Investigator Assessment: "Substantial to complete clearance" assessed by the clinical investigators.
- For Safety: Clinical observation of adverse events and patient discomfort.
- For Technological Equivalence: Histological evaluation.
8. The Sample Size for the Training Set
- Not applicable. The document describes clinical studies conducted to evaluate the device, not to train a machine learning model.
9. How the Ground Truth for the Training Set Was Established
- Not applicable. As no training set for an AI/algorithm is discussed, this question is not relevant.
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(84 days)
The PicoWay Laser System is indicated for the following at the specified wavelength:
532nm: Removal of tattoos for Fitzpatrick skin types I-III to treat the following tattoo colors: red, yellow and orange.
1064nm: Removal of tattoos for all skin types (Fitzpatrick I-VI) to treat the following tattoo colors: black, brown, green, blue and purple.
The PicoWay Laser System is also indicated for benign pigmented lesions removal for Fitzpatrick Skin Types I-V.
The PicoWay Laser System is a solid state laser capable of delivering energy at wavelengths of 1064 nm or 532 nm at short durations of 240-750 picoseconds (ps) at repetition rates up to 10 Hz. The device system is comprised of a system console, an articulated arm, and an attached handpiece. The laser output at each wavelength is generated within the laser chassis and delivered to the skin through an articulated arm delivery system terminated by a zoom handpiece (HP). The light-weight and ergonomic zoom handpiece allows the skin to be easily adjusted from 2 mm to 10 mm in steps of 1 mm. The system includes an internal calibration port with an internal meter located on the control panel of the system console, which is used to verify the transmission of the laser beam into the articulated arm. The PicoWay system control panel enables the user to select the desired energy density (fluence) level and repetition rate. The control panel is also used to obtain feedback from the system, such as the number of pulses delivered or spot size selected.
The provided FDA 510(k) summary for the PicoWay Laser System includes information regarding acceptance criteria and a clinical study to demonstrate its performance.
Here's a breakdown of the requested information:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria (Endpoint Threshold) | Reported Device Performance (PicoWay Laser System) |
---|---|
50% or more tattoo clearance after up to 3 treatments, based on blinded, independent review. (Endpoint threshold: 85% of treated tattoos) | 86% of the treated tattoos achieved 50% or more clearance after up to 3 treatments. |
Favorable safety profile (no device-related serious adverse events). | No device-related serious adverse events reported. Mild adverse events all resolved. |
Consistency with results of prior PicoWay studies. | Results of blinded review and investigator review were consistent with prior PicoWay studies. |
(Secondary Efficacy Endpoint) At least 50% tattoo clearance after up to 3 treatments, based on investigator assessment. | 97% of subjects achieved at least 50% tattoo clearance after up to 3 treatments. |
2. Sample Size Used for the Test Set and Data Provenance
- Test Set Sample Size: 60 subjects (69 tattoos/pigmented lesions).
- Data Provenance: The document does not explicitly state the country of origin. It indicates it was a "single arm, self-controlled study." It is a prospective clinical study as it was conducted to evaluate the safety and effectiveness of the device.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
- Number of Experts: The document states "blinded, independent review," implying at least one, and likely more, independent experts. The exact number of experts is not specified.
- Qualifications of Experts: The qualifications of the experts are not explicitly stated, beyond being "independent reviewers."
4. Adjudication Method for the Test Set
- The document mentions "blinded, independent review." It does not specify a formal adjudication method like "2+1" or "3+1" for discrepancies. It's implied that their assessment directly formed the basis for the primary endpoint.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done
- No, an MRMC comparative effectiveness study involving human readers with and without AI assistance was not done. This study focuses solely on the performance of the PicoWay Laser System for tattoo and benign pigmented lesion removal.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done
- This is not applicable as the PicoWay Laser System is a physical medical device (laser system), not an AI algorithm. Its performance is directly tied to its physical operation and the human operator's use of it.
7. The Type of Ground Truth Used
- Expert Consensus/Clinical Assessment: The primary endpoint was determined by "blinded, independent review" of tattoo clearance, and a secondary endpoint was based on "investigator assessment." This indicates the ground truth was established through expert clinical evaluation.
8. The Sample Size for the Training Set
- The document does not mention a "training set" in the context of an algorithm or AI. This study is a clinical trial evaluating a physical medical device. The "training set" concept is not relevant here.
9. How the Ground Truth for the Training Set was established
- Not applicable, as there is no "training set" for this device.
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(177 days)
The XP1000 RF device is indicated for temporary reduction in circumference of the abdomen.
The XP1000 RF is indicated for temporary reduction in circumference of the abdomen.
The XP1000 RF system is designed for temporary reduction in circumference of the abdomen by means of high-frequency electromagnetic field. The multi-jointed arm firmly supports the applicator during treatment. Large knobs lock and unlock the joints to make positioning the applicators to the patient quick, easy and secure. The control unit consists of the control system and the electronic system. The control system contains the main microcomputer and software for control of the entire equipment; the electronic system contains the complete electromagnetic field generation. Easy-to-use color touch screen allows for maximum operator comfort. A large control knob is provided to increase and decrease output power. The XP1000 RF system is placed in a specially designed cart, the shape of which provides maximum operator comfort and easy movement of the device in the office. The XP1000 RF consists of the following main components: microprocessor-driven control unit, high-frequency electromagnetic energy generator, user interface with 8.4" color touch screen, applicator on a multi-jointed arm.
The document describes the XP1000 RF device, which is an electrosurgical cutting and coagulation device and accessories indicated for the temporary reduction of abdominal circumference.
Here's an analysis of the acceptance criteria and the study that proves the device meets them:
1. Table of Acceptance Criteria and Reported Device Performance:
Acceptance Criteria (Primary Efficacy Outcome Measure) | Reported Device Performance (XP1000 RF Treatment Group) |
---|---|
≥3 cm waist circumferential reduction in more than 80% of subjects. | Achieved ≥3 cm waist circumferential reduction in more than 80% of subjects. |
Mean circumferential reduction of XP1000 RF Treatment Group ≥1 cm than the mean circumferential reduction of the Placebo Group at the 30-day Follow Up evaluation point. | The mean circumferential reduction was ≥1 cm than the mean circumferential reduction of the Placebo Group at the 30-day Follow Up evaluation point. |
Acceptance Criteria (Secondary Objective - Safety) | Reported Device Performance |
Absence of adverse events (AE) associated with the treatment procedure. | No adverse events were recorded. |
2. Sample Size Used for the Test Set and Data Provenance:
- Sample Size (Test Set): 60 subjects (40 in the XP1000 RF Treatment Group and 20 in the Sham/Placebo Group). All but one subject completed the study.
- Data Provenance: The document does not specify the country of origin of the data. The study was a "double-blinded study," indicating it was a prospective clinical trial.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications:
The document does not explicitly state the number of experts used to establish ground truth or their specific qualifications for assessing the waist circumference measurements. However, in clinical trials involving objective measurements like waist circumference, the "ground truth" is typically established by trained clinical staff following a standardized measurement protocol rather than a panel of experts. The data appears to be quantitative measurements.
4. Adjudication Method for the Test Set:
The document does not specify an adjudication method like 2+1 or 3+1. Given that the primary outcome is a quantitative measurement (waist circumference reduction) and it was a double-blinded study, it's highly probable that measurements were taken by trained personnel, and statistical analysis was used to compare the groups. Adjudication methods are more commonly used for subjective assessments.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done:
No, an MRMC comparative effectiveness study was not done. The study described is a clinical trial comparing a treatment group to a placebo group in terms of an objective physical measurement (waist circumference reduction).
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done:
This question is not applicable to the XP1000 RF device. The device is a physical medical device (electrosurgical cutting and coagulation device) that performs a physical intervention on a patient, not an AI algorithm. The study assesses the device's clinical efficacy in reducing abdominal circumference in human subjects.
7. The Type of Ground Truth Used:
The ground truth used was objective quantitative measurements of waist circumference. These measurements were taken at baseline and at 30-day and 90-day follow-up evaluations.
8. The Sample Size for the Training Set:
This question is not applicable. The XP1000 RF is a physical medical device, not an AI algorithm that requires a training set in the typical sense of machine learning. The clinical study described is for validating the device's effectiveness and safety, not for training a model.
9. How the Ground Truth for the Training Set Was Established:
This question is not applicable for the reasons stated in point 8.
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(66 days)
The PicoWay Laser System is indicated for the following at the specified wavelength:
532nm; Removal of tattoos for Fitzpatrick skin types I-III to treat the following tattoo colors: red, yellow and orange.
1064nm: Removal of tattoos for all skin types (Fitzpatrick I-VI) to treat the following tattoo colors: black, brown, green, blue and purple.
The PicoWay Laser System is also indicated for benign pigmented lesions removal for Fitzpatrick Skin Types I-IV.
The PicoWay Laser System is a solid state laser capable of delivering energy at wavelengths of 1064 nm or 532 nm at short durations less than or equal to 900 picoseconds (ps) at repetition rates up to 5 Hz. The device system is comprised of a system console, an articulated arm, and an attached handpiece. The laser output at each wavelength is generated within the laser chassis and delivered to the skin through an articulated arm delivery system terminated by a zoom handpiece (HP). The light-weight and ergonomic zoom handpiece allows the spot size on the skin to be easily adjusted from 3 mm to 6 mm in steps of 1 mm. The system includes an internal calibration port with an internal meter located on the control panel of the system console, which is used to verify the transmission of the laser beam into the articulated arm. The PicoWay system control panel enables the user to select the desired energy density (fluence) level and repetition rate. The control panel is also used to obtain feedback from the system, such as the number of pulses delivered or spot size selected.
The PicoWay Laser System was evaluated for its safety and effectiveness in the removal of benign pigmented lesions.
1. Table of Acceptance Criteria and Reported Device Performance:
Criteria | Acceptance Criteria | Reported Device Performance |
---|---|---|
Primary Efficacy Endpoint: | More than 70% of treated pigmented lesions achieve 50% or more clearance at the primary endpoint visit. | Successfully met. The clinical study demonstrated that more than 70% of the treated pigmented lesions achieved 50% or more clearance at the primary endpoint visit, based on blinded, independent review. Additional statistical analyses supported the robustness of these results. |
Investigator Assessments of Clearance: | Substantial degree of pigmented lesions clearance. | Successfully met. Consistent with the primary endpoint, investigator assessments similarly demonstrated a substantial degree of pigmented lesions clearance. |
Subject Pain Assessment: | Generally considered low pain. | Successfully met. Subject assessments confirmed that the device treatment was generally considered low pain. |
Subject Satisfaction: | Trended towards overall satisfaction with treatment. | Successfully met. Available satisfaction data from subjects trended towards overall satisfaction with treatment. |
Device-Related Serious Adverse Events (SAEs): | No device-related serious adverse events. | Successfully met. No device-related serious adverse events were reported. There were no deaths and no withdrawals due to adverse events. |
Adverse Events (AEs): | Number and severity of AEs should be acceptable and resolve/improve. | Successfully met. Out of 107 treatments, only 3 adverse events were reported for 2 subjects. These events were not severe and resolved or improved during the study. Anticipated treatment-associated responses did not present new safety questions compared to predicate devices. |
Overall Safety and Effectiveness: | Favorable safety and effectiveness profile similar to predicate devices. | Successfully met. The study demonstrated a strong safety profile and clinical performance comparable to predicate devices, supporting the conclusion of similar safety and effectiveness. |
2. Sample size used for the test set and the data provenance:
- Test Set Sample Size: 26 subjects (29 lesions)
- Data Provenance: Retrospective or prospective is not explicitly stated, but the study is described as a "single arm, prospective, self-controlled multicenter study," indicating a prospective design for data collection. The country of origin of the data is not specified.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- The document mentions "blinded, independent review" for assessing lesion clearance. However, the exact number of experts and their specific qualifications (e.g., radiologist with X years of experience) are not provided.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- The document states "blinded, independent review." It does not specify a particular adjudication method like 2+1 or 3+1.
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 involving human readers with and without AI assistance was not done. This study solely evaluated the performance of the PicoWay Laser System as a standalone treatment device.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
- Yes, a standalone study was done. The clinical study evaluated the PicoWay Laser System's performance as a treatment device, not as an AI algorithm assisting human readers. The "algorithm" in this context refers to the laser system's operating parameters and its direct effect on the lesions.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- The ground truth for efficacy was primarily based on blinded, independent review of lesion clearance, which implies expert assessment.
- For safety, the ground truth was based on the occurrence and severity of adverse events and their resolution, which is outcomes data gathered from clinical observations.
8. The sample size for the training set:
- The document does not mention a training set as this is a clinical study for a medical device (laser system), not an AI algorithm requiring a machine learning training phase. The device itself is the "intervention" being tested.
9. How the ground truth for the training set was established:
- As there is no mention of a training set for an AI algorithm, this question is not applicable.
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