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510(k) Data Aggregation

    K Number
    K232415
    Manufacturer
    Date Cleared
    2024-08-21

    (376 days)

    Product Code
    Regulation Number
    882.5870
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K191435, K202274

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

    This system is indicated for pain management in adults who have severe intractable chronic pain of peripheral nerve origin, as the sole mitigating agent, or as an adjunct to other modes of therapy used in a multidisciplinary approach. The system is not intended to treat pain in the craniofacial region.

    The trial devices are solely used for trial stimulation (no longer than 30 days) to determine efficacy before recommendation for a permanent (long term) device.

    Device Description

    The Nalu Neurostimulation System for Peripheral Nerve Stimulation (also referred to as the "Nalu System") is used for peripheral nerve stimulation to provide therapeutic relief for chronic, intractable pain of peripheral nerve origin. The Nalu System incorporates a miniature implantable pulse generator, powered by an externally worn Therapy Disc device. The Nalu Neurostimulation therapy utilizes pulsed electrical current to create an energy field that acts on the peripheral nerves to inhibit the transmission of pain signals to the brain. The Nalu System may be implanted following a successful trial period using the Nalu Neurostimulation trial system. The Nalu System is comprised of 5 elements: Nalu Implantable Pulse Generator, Leads, Surgical and Trial Tools, Externally worn Therapy Disc, and Clinician Programmer and Remote Control.

    AI/ML Overview

    This document describes a 510(k) premarket notification for the Nalu Neurostimulation System for Peripheral Nerve Stimulation. The submission aims to establish substantial equivalence to a previously cleared predicate device (K183579), primarily focusing on an update to the device's Magnetic Resonance (MR) Conditional Labeling to include full body scans.

    Based on the provided text, there is no acceptance criteria table or specific study performance data for a device meeting acceptance criteria in the traditional sense of an AI/ML model for diagnostic or predictive purposes. This document is a regulatory submission for a physical medical device (implantable neurostimulator) and its associated external components and software, not an AI/ML diagnostic software. The "performance" discussed here relates to the safety and functionality of the device itself, particularly its compatibility with MRI, rather than the accuracy of a diagnostic algorithm.

    Therefore, many of the requested elements (e.g., sample size for test set, data provenance, number of experts for ground truth, adjudication method, MRMC study, standalone performance, training set details) are not applicable to this type of medical device submission.

    However, I can extract the relevant information regarding the device's "performance" as presented in the context of this 510(k) submission, specifically concerning the MRI compatibility, as this is the primary change necessitating the resubmission.


    Summary of Acceptance Criteria and Device (MRI) Performance:

    Since this is not an AI/ML diagnostic device, the "acceptance criteria" are not framed in terms of metrics like accuracy, sensitivity, or specificity. Instead, they are related to established safety standards for medical devices, particularly regarding MRI compatibility. The "device performance" refers to the results of testing performed to ensure these safety standards are met.

    1. Table of Acceptance Criteria and Reported Device Performance (Focusing on MRI Compatibility):

    Acceptance Criteria CategorySpecific Criteria (Implicitly based on standards)Reported Device Performance / Assessment
    Magnetic Resonance (MR) Safety and Compatibility for Full Body ScansConformance to MR Conditional Labeling for full body scans.Testing included in this submission demonstrates the safety and compatibility of the Nalu System for PNS in the Magnetic Resonance (MR) Environment for full body.
    Magnetically Induced Displacement ForceMeet limits defined in ASTM F2052-15Testing performed to standard.
    Magnetically Induced TorqueMeet limits defined in ASTM F2213-17Testing performed to standard.
    MR Image ArtifactsMeet limits defined in ASTM F2119-2013Testing performed to standard.
    Safety of Active Implantable Medical Device in MRIConformance to ISO/TS 10974Testing performed to standard.
    General Device Safety and PerformanceConformance to ISO 14708 (Parts 1 & 3)Testing performed to standard.
    Design ControlsAdherence to 21 CFR 820.30Nalu follows these procedures.
    Risk ManagementAdherence to ISO 14971Nalu follows these procedures.
    Quality Management SystemAdherence to ISO 13485:2016Nalu follows these procedures.
    BiocompatibilityDemonstrated through testing.Testing performed.
    SterilizationDemonstrated through testing.Testing performed.
    Human Factors and UsabilityDemonstrated through testing.Testing performed.
    Functional SpecificationDevice meets user needs.Validation and performance testing demonstrate this.
    Substantial EquivalenceIdentical indications for use, performance, and technological characteristics to predicate.Stated as "identical" and "no differences that would impact safety or effectiveness." The only noted difference is the updated MR Conditional Labeling, which is supported by new testing.

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

    • Sample Size: The document does not specify the sample sizes used for the engineering tests (e.g., number of devices tested for MRI compatibility, displacement, torque, or artifacts). These are typically bench tests on physical units, not clinical data sets.
    • Data Provenance: Not applicable in the context of clinical data. The tests are laboratory-based, non-clinical performance and bench testing.

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

    • Not Applicable. This is not a study assessing the performance of a diagnostic algorithm where expert ground truth is established for medical images. The "ground truth" for this device's performance relies on engineering measurements and adherence to international and national standards (e.g., ISO, ASTM) for device safety and functionality.

    4. Adjudication Method for the Test Set:

    • Not Applicable. As there are no human readers or diagnostic interpretations involved in the "test set" (which consists of physical device tests), no adjudication method is necessary.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done:

    • No. This type of study is typically done for diagnostic imaging devices or AI tools that assist human readers. This submission is for an implantable neurostimulation system, not a diagnostic imaging or AI assistance tool.

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

    • Not Applicable. There is no "algorithm only" performance being evaluated in this submission in the context of diagnostic AI. The device's functionality (e.g., electrical stimulation parameters) and safety (e.g., MRI compatibility) are evaluated.

    7. The Type of Ground Truth Used:

    • The "ground truth" for the device's safety and performance is established through adherence to recognized international and national consensus standards (e.g., ISO/TS 10974, ISO 14708, ASTM F2052-15, ASTM F2213-17, ASTM F2119-2013) and engineering verification and validation testing. It is not based on expert consensus on medical image interpretations or clinical outcomes data in the context of diagnostic accuracy.

    8. The Sample Size for the Training Set:

    • Not Applicable. This is not an AI/ML device that requires a training set of data.

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

    • Not Applicable. (See point 8).
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    K Number
    K201618
    Manufacturer
    Date Cleared
    2020-07-15

    (30 days)

    Product Code
    Regulation Number
    882.5880
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K183579, K191435

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

    Spinal Cord Stimulation (SCS)

    This system is indicated as the sole mitigating agent, or as an adjunct to other modes of therapy used in a multidisciplinary approach for chronic, intractable pain of the trunk and/or limbs, including unilateral or bilateral pain.

    The trial devices are solely used for trial stimulation (no longer than 30 days) to determine efficacy before recommendation for a permanent (long term) device.

    Peripheral Nerve Stimulation (PNS)

    This system is indicated for pain management in adults who have severe intractable chronic pain of peripheral nerve origin, as the sole mitigating agent, or as an adjunct to other modes of therapy used in a multidisciplinary approach. The system is not intended to treat pain in the craniofacial region.

    The trial devices are solely used for trial stimulation (no longer than 30 days) to determine efficacy before recommendation for a permanent (long term) device.

    Device Description

    The Nalu Neurostimulation system has been cleared by the FDA for spinal cord stimulation (SCS; K183047) and peripheral nerve stimulation (PNS; K183579, and K191435) to provide therapeutic relief for chronic, intractable pain of the trunk and/or limbs including unilateral, bilateral nerve pain. The Nalu Neurostimulation therapy utilizes pulsed electrical current to create an energy field that acts on nerves in the spinal cord or peripheral nerve to inhibit the transmission of pain signals to the brain. The Nalu System is implanted only following a successful trial period using the Nalu Neurostimulation trial system.

    The Nalu Neurostimulation system consists of five components. The implantable pulse generator (IPG) provides electrical stimulation pulses that are transmitted through the leads, to the desired location, either on the spinal cord or peripheral nerve site. The leads are implantable and designed to deliver electrical pulses to the nerves via an array of four or eight cylindrical electrodes at the distal end. The Trial Therapy Disc or the Therapy Disc houses the battery and electronics for RF power and controls the IPG for therapy delivery via the remote programmer. Implantation of the Nalu IPG and lead components for Spinal Cord Stimulation (SCS) or Peripheral Nerve Stimulation (PNS) is performed via standard surgical tools and techniques, as described in (K183047, K183579, and K191435).

    AI/ML Overview

    The Nalu Neurostimulation System is a non-AI device, and the provided documentation is a 510(k) submission for substantial equivalence. Therefore, the questions related to AI/algorithm performance, ground truth, training sets, and expert adjudication are not applicable here.

    The document discusses the Nalu Neurostimulation System, which is an implantable neurostimulation device for pain relief.

    Here's the information extracted based on the provided text, focusing on the device's characteristics and the justification for substantial equivalence, which is the "study" in this context:

    1. Table of Acceptance Criteria and Reported Device Performance

    The FDA 510(k) process for substantial equivalence does not typically present a formal "acceptance criteria table" in the same way clinical trials for new devices might. Instead, it relies on demonstrating that the new device is as safe and effective as a legally marketed predicate device. The "performance" in this context refers to the device's technical specifications and intended clinical outcomes, which are asserted to be equivalent to the predicate.

    For the Nalu Neurostimulation System (Subject Device), the performance is demonstrated by its substantial equivalence to the predicate and reference devices (K183047, K183579, K191435). The key "acceptance criteria" here implicitly are that the device meets the same safety and effectiveness profiles as the predicate.

    Feature / CriterionPredicate Device (K183047) Performance (for SCS) / Ref. Devices (K183579, K191435) Performance (for PNS)Subject Device Performance (Nalu Neurostimulation System)Technological Differences
    Intended UseStimulation of spinal cord/peripheral nerve for chronic, intractable pain.Stimulation of spinal cord/peripheral nerve for chronic, intractable pain.Same
    Indications for Use (SCS)As sole or adjunct agent for chronic, intractable trunk/limb pain (unilateral/bilateral). Trial use
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