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510(k) Data Aggregation
(85 days)
Hair Growth Device is indicated to promote hair growth in females with androgenetic alopecia who have Ludwig-Savin Classifications of I-II, in males with androgenetic alopecia who have Norwood-Hamilton Classifications of IIa-V and for both, Fitzpatrick Classification of Skin Phototypes I to IV.
The product is composed of main unit, USB cable, and silicone pad. The main unit consists of laser diodes that are spread throughout the helmet. Low-energy laser therapy (LLLT) is a safe and effective treatment for androgenic alopecia (AGA). The Hair Growth Device employs intelligent LLLT technology, utilizing a 650 nm, 5-milliwatt low-energy laser that penetrates the scalp surface to a depth of 3-5 mm, reaching the hair follicles. Hair Growth Device is a small over-the-counter, portable, noninvasive, low-level laser device intended to treat Androgenetic Alopecia (Hair Loss) and to promote hair growth in Males and Females. The product uses diode lasers to cover the entire area of the head that is normally covered with hair, and this unique design allows the treatment of the entire scalp without manual movement. Hair Growth Device consists of main unit, USB cable and silicone strap and no communication function. The device will then turn on and you'll hear an audible beep.
This FDA 510(k) clearance letter is for a medical device (Hair Growth Device) rather than a software algorithm used for interpretation/diagnosis. As such, the information typically requested for AI-powered diagnostic devices (e.g., test set sample size, expert qualifications, adjudication methods, MRMC studies, ground truth types for training/test sets, etc.) is not applicable or present in this document.
The document primarily focuses on demonstrating substantial equivalence to predicate devices through technical specifications and non-clinical testing. It explicitly states, "No clinical test data was used to support the decision of substantial equivalence."
Therefore, I cannot provide the requested information about acceptance criteria for an AI algorithm's performance or details about a study proving such performance, as this document does not pertain to such a device or study.
However, I can extract the general acceptance criteria and the type of study performed to prove substantial equivalence based on the provided text, recognizing these are not related to AI performance.
Based on the provided FDA 510(k) clearance letter for the Hair Growth Device:
1. Table of Acceptance Criteria and Reported Device Performance:
Acceptance Criteria Category | Reported Device Performance (Summary) |
---|---|
Safety | Complies with IEC 60601-1, IEC 60601-1-2, IEC 60825-1, IEC 60601-1-11, ISO 10993-5, ISO 10993-10 (electromagnetic compatibility, electrical safety, laser safety, biocompatibility). Differences in physical parameters (dimensions, weight, operating/storage environment) do not affect safety. |
Effectiveness (Substantial Equivalence) | Energy and power parameters' range of subject device can be covered by predicate device's range; very similar. Differences in "Amounts of Laser Lamp", "Treatment Time", "Treatment Area", "Irradiance", and "Fluence" will not raise any safety or effectiveness issue. |
Performance (Non-Clinical) | Meets requirements of predefined acceptance criteria for: |
- Product service life
- Software validation
- Biocompatibility evaluation
- Electromagnetic compatibility and electrical safety
- Safety of laser products
- Performance test |
Regarding the study that proves the device meets the acceptance criteria (note: this is a substantial equivalence study, not an AI performance study):
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Sample size used for the test set and the data provenance: Not applicable. No clinical test set or patient data was used. The study primarily relies on comparison to predicate devices and non-clinical engineering tests.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. No clinical test set requiring expert ground truth was used for this substantial equivalence determination.
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Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable. No clinical test set requiring adjudication was used.
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If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance: Not applicable. This device is not an AI-powered diagnostic tool, and no MRMC study was conducted.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable. This is not an AI algorithm. The device operates independently (Over-The-Counter).
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.): Not applicable to an AI context. For substantial equivalence, the "ground truth" is established by compliance with recognized standards (e.g., IEC, ISO) and comparison to legally marketed predicate devices that have established safety and effectiveness.
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The sample size for the training set: Not applicable. This is not an AI algorithm, so there is no training set in the machine learning sense.
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How the ground truth for the training set was established: Not applicable. No AI training set.
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(90 days)
MEN - The GroWell BT Hair Growth System ("GroWell") is designed to promote hair growth in males with androgenetic alopecia who have Norwood Hamilton Classifications of Ila to V. WOMEN - The GroWell is designed to promote hair growth in females with androgenetic alopecia who have Ludwig-Savin classifications of I-II. The GroWell is approved for Fitzpatrick skin types I-IV.
The GroWell BT Hair Growth System consists of 24 proprietary red light diode lasers and 39 proprietary red light super-luminescent diodes configured in a flexible panel which is inserted in an adult, baseball-style cap. The GroWell contains 655nm laser and LED diodes, which generates light after being excited by the internal power supply, the light is controlled and output by the control device, and directly and effectively irradiated to the treatment site, so as to achieve therapeutic effect. The GroWell's conbination of diode lasers and non-laser LED's provides for a full coverage of the head: i.e, the scalp area roughly from the top of the head to the top of the ears. The GroWell session will be "paused" and the light array will automatically turn off if the user removes the GroWell during use, and will resume when it is replaced on the 25 minute session, the lights will turn off and the GroWell will emit two audible beeps to signal that the therapy is complete.
The provided text is a 510(k) summary for the GroWell BT Hair Growth System. It states that non-clinical testing was conducted, but explicitly mentions no clinical data was used for performance verification. Therefore, it is impossible to infer acceptance criteria or details about a study proving the device meets those criteria from the provided document.
The document lists standards that the device complies with, but these cover general safety, electromagnetic compatibility, and biocompatibility, not performance related to hair growth efficacy.
Here's a breakdown of why the requested information cannot be provided from the text and what can be extracted:
Information NOT available in the provided text:
- A table of acceptance criteria and the reported device performance: The document states "The clinical test is not applicable, there's no clinical data." This means there were no clinical performance acceptance criteria established or met.
- Sample sized used for the test set and the data provenance: Not applicable as there was no clinical test set.
- Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable.
- Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable.
- If a multi reader multi case (MRMC) comparative effectiveness study was done: Not applicable.
- If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable.
- The type of ground truth used (expert consensus, pathology, outcomes data, etc.): Not applicable.
- The sample size for the training set: Not applicable.
- How the ground truth for the training set was established: Not applicable.
What can be extracted from the text regarding device verification:
The document states: "Non-clinical testing have been conducted to verify that the GroWell meets all design specifications which supports the conclusion that it's substantially equivalent to the predicate demonstrate that the subject device complies with the following standards:"
These standards relate to safety and electrical performance, not efficacy of hair growth.
- IEC 60601-1 Edition 3.2 2020-08: Medical electrical equipment - Part 1: General requirements for basic safety and essential performance.
- IEC 60601-1-2 Edition 4.1 2020-09: Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances - Requirements and tests.
- IEC 60601-1-11 Edition 2.1 2020-07: Medical electrical equipment - Part 1-11: General requirements for basic safety and essential performance - Collateral - Requirements for medical electrical equipment and medical electrical systems used in the home healthcare environment.
- IEC 62471 First edition 2006-07: Photobiological safety of lamps and lamp systems.
- IEC 60825-1: 2014: Safety of laser products - Part 1: Equipment classification, and requirements.
- Biocompatibility: Evaluated as per ISO 10993-1 Fifth edition 2018-08, and tested as per ISO 10993-5 Third edition 2009-06-01, ISO 10993-10 Fourth edition 2021-11 and ISO 10993-23 First edition 2021-01.
- Software evaluation: As per FDA guidance "Content of Premarket Submissions for Device Software Functions."
The conclusion provided is based on "analysis and tests" (referring to the non-clinical tests listed) and suggests substantial equivalence to predicate devices because of similar indications for use and technological characteristics (light source, design, wavelength, energy per diode). The differences noted (power supply, number of diodes, dimensions, and weight) were deemed not to raise safety or effectiveness issues due to compliance with international standards and core function (light output) not being affected.
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(90 days)
The ID-510 iRestore Elite is indicated to promote hair growth in males who have Norwood-Hamilton Classifications of IIa-V, and in females with androgenetic alopecia who have Ludwig-Savin Classifications of I-II, and in both, Fitzpatrick Classification of Skin Phototypes I to IV.
The ID-510 iRestore Elite is a low-level laser/light system operating at 680 ± 10, 655 ± 10, and 625± 10 nanometers. The physical configuration is that of a helmet containing an inner and outer liner, stabilized with a silicone pad lined fixation ring. The device helmet is constructed of an ABS type plastic. The system operates on line voltage at 100 or 240 volts. The helmet's inner liner permits full adjustment to any heads of non-toxic silicone pads. The helmet contains 300 units of five-millwatt-diode lasers and 200 units of fivemilliwatt, super luminescent diodes, that emit red light. This system delivers fixed laser emission levels, measured to be 2500 total millwatts per 12 minute treatment session, which cannot be altered by the operator.
The provided text describes a 510(k) premarket notification for the ID-510 iRestore Elite device, which is an infrared lamp for promoting hair growth. The document focuses on demonstrating substantial equivalence to a predicate device (ID-500 iRestore Hair Growth System) rather than providing specific acceptance criteria and detailed study results for the ID-510 iRestore Elite itself.
The document lists non-clinical performance data (e.g., cytotoxicity, electrical safety, software verification) that were performed to support substantial equivalence. However, it does not detail a clinical study with acceptance criteria for device performance based on hair growth outcomes in human subjects, nor does it refer to an AI algorithm that would typically have the detailed study requirements you've requested.
Therefore, I cannot provide the information you asked for regarding:
- A table of acceptance criteria and reported device performance related to hair growth.
- Sample size used for a test set, data provenance, or expert involvement for ground truth, as these typically relate to the validation of a diagnostic or AI-driven device's performance.
- Number of experts, their qualifications, or adjudication methods for establishing ground truth on a test set.
- MRMC comparative effectiveness study results or effect sizes for human readers with/without AI assistance.
- Standalone (algorithm-only) performance.
- Detailed type of ground truth beyond the general claim of "safety and effectiveness" through non-clinical tests.
- Sample size for the training set or how ground truth for a training set was established, as this implies a machine learning model, which is not described.
The information provided solely pertains to the non-clinical tests performed to demonstrate the ID-510 iRestore Elite's safety and effectiveness for substantial equivalence, not its direct clinical efficacy against quantified hair growth metrics under specific acceptance criteria.
The document states:
- "To demonstrate safety and effectiveness of ID-510 iRestore Elite and to show substantial equivalence to the predicate device, Remax Medi-Tech (Shenzhen) Corporation completed the following non-clinical tests."
- "Results confirm that the design inputs and performance specifications for the device are met."
- "The ID-510 iRestore Elite passed the testing in accordance with internal requirements, and international standards shown below, supporting its safety and effectiveness, and its substantial equivalence to the predicate device:"
The tests listed are:
- Cytotoxicity testing per ISO 10993-5: Passed
- Sensitization testing per ISO 10993-10: Passed
- Electrical safety testing per ANSI AMMI 60601-1: Passed
- Electromagnetic Disturbance (EMC) testing per IEC 60601-1-2: Passed
- Software verification and validation per FDA Guidance: Compliant
- Lifetime Testing: Supports lifetime of five years
- Transportation Testing per ASTM D4169: Demonstrates package integrity maintained
This means the acceptance criteria detailed are for these non-clinical engineering and biocompatibility tests, not for a clinical outcome like hair growth percentage or density, and there is no mention of an AI component requiring a "test set" or "training set" in the context of machine learning.
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(89 days)
ID-500 iRestore Hair Growth System: iRestore Hair Growth System, ID-500, is indicated to treat androgenetic alopecia for men and women. It is designed to promote hair growth in males who have Norwood-Hamilton Classifications of IIa to V and in females who have Ludgwig-Savin Classifications of I to II. All users should also have Fitzpatrick Skin Types I to IV.
The ID-500 iRestore Hair Growth System are two low-level laser/light systems operating at different wavelengths. The ID-500 iRestore Hair Growth System consists of laser and LED operating at 655 ± 10 nanometers. The physical configuration of the device is that of a helmet containing an inner and outer liner, stabilized with a silicone pad lined fixation ring. The systems operate on line voltage at 100 or 240 volts. The helmet's inner liner permits full adjustment to any head shape by means of non-toxic silicone pad. The helmet contains 5-millwatt-diode lasers and 5-milliwatt, super luminescent diodes, that emit red light.
The provided text describes the ID-500 iRestore Hair Growth System and its substantial equivalence to a predicate device, the iRestore Professional 282. However, it does not include detailed acceptance criteria for a device performance study in terms of clinical outcomes (e.g., hair count increase) or a study proving the device meets those clinical criteria. Instead, the document focuses on non-clinical performance data demonstrating safety and electrical/laser compliance.
Therefore, many of the requested elements for a clinical performance study (like sample size for test sets, data provenance, expert ground truth, MRMC study, standalone performance, training set details) are not available in this document.
Here's a breakdown of what can be extracted and what cannot:
1. Table of acceptance criteria and reported device performance:
The document primarily discusses acceptance criteria related to safety and engineering standards, not clinical efficacy.
Acceptance Criteria (Non-Clinical) | Reported Device Performance |
---|---|
Cytotoxicity testing per ISO 10993-5 | Passed |
Irritation testing per ISO 10993-10 | Passed |
Sensitization testing per ISO 10993-10 | Passed |
Electrical safety testing per ANSI AAMI ES60601-1:2005((R)2012 and A1:2012, C1:2009/(R)2012 and A2:2010/(R)2012 | Passed |
Electromagnetic Disturbance (EMD) testing per IEC 60601-1-2 | Passed |
Home used environment testing per IEC 60601-1-11 | Passed |
Laser safety testing per IEC 60825-1 | Passed |
Software verification and validation per FDA Guidance | Compliant |
Product life time testing | Supports life time of 5 years |
Transportation testing per ASTM D4169-16 | Demonstrates package integrity maintained |
2. Sample size used for the test set and the data provenance:
This information is not provided as there is no description of a clinical performance study with a test set of human subjects. The "test set" here refers to the samples used in the non-clinical tests (e.g., cytotoxicity tests would use cell cultures or animal models, electrical safety tests would use the device itself). The document does not specify details about these samples.
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 there is no mention of a human-centric performance study where experts would establish a ground truth for clinical outcomes like hair growth. The "ground truth" for the non-clinical tests would be defined by the standards themselves (e.g., a cytotoxicity assay result being below a certain threshold).
4. Adjudication method for the test set:
This information is not applicable for the same reasons as above.
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 described is a low-level laser/light therapy system for hair growth, not an AI-powered diagnostic tool requiring human reader interpretation.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
This information is not applicable as the device is not an algorithm.
7. The type of ground truth used:
For the non-clinical tests, the "ground truth" is defined by the harmonized standards (ISO, ANSI, IEC, ASTM) and FDA guidance documents that the device was tested against. For example:
- Safety standards: Passing specific thresholds for electrical leakage, laser emission limits, or biocompatibility responses.
- Software compliance: Adherence to defined software development and validation practices.
- Lifetime/Transportation: Meeting predefined engineering specifications for durability and package integrity.
8. The sample size for the training set:
This information is not applicable as the device is a hardware product, not a machine learning algorithm that requires a training set.
9. How the ground truth for the training set was established:
This information is not applicable for the same reason as above.
Summary of the Study:
The document describes a non-clinical performance study focused on demonstrating the safety and engineering compliance of the ID-500 iRestore Hair Growth System. The study involved testing the device against various national and international standards related to biocompatibility, electrical safety, electromagnetic compatibility, home use environment, laser safety, software validation, product lifetime, and transportation durability. The results of these tests confirmed that the device met the design inputs and performance specifications required by these standards, supporting its safety and effectiveness from an engineering and manufacturing perspective, and its substantial equivalence to the predicate device. No clinical efficacy study or AI-related performance study is detailed in this document.
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