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510(k) Data Aggregation

    K Number
    K201801
    Manufacturer
    Date Cleared
    2021-01-29

    (213 days)

    Product Code
    Regulation Number
    878.4810
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K200331

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

    The Rapid Acoustic Pulse Device (RAP) is indicated for use as an accessory to the 1064 nm Q-Switched laser for black ink tattoo removal in Fitzpatrick Skin Type I-III patients. The RAP device is also indicated for short-term improvement in the appearance of cellulite.

    Device Description

    The Rapid Acoustic Pulse Device (RAP) is designed as an accessory to laser treatments to improve laser tattoo fading efficiency, as well as a standalone device to improve the appearance of cellulite. RAP uses repeated, rapidly rising acoustic waves, releasing pigment particles from the pigment laden macrophage (PLM) and dissipating the laser- induced whitening. This allows multiple laser passes in a single session, resulting in accelerated tattoo fading and fewer office visits to achieve sufficient tattoo fading. When used for improving the appearance of cellulite, the acoustic waves induce physical effects in the fibrous structures, such as the fibrous septa in the subcutaneous tissue.

    RAP is composed of three parts: the Console, the Hand Piece and the connecting Cable. The Console supplies saline to the Hand Piece to enable formation of the shock wave within the acoustic pulse chamber. The Hand Piece generates acoustic waves in the saline. The acoustic waves pass through the acoustically transparent Window and acoustic ultrasound gel or similar hydrogel pad, which when placed against the surface of the skin to be treated.

    The subject RAP device is almost identical to the previously cleared RAP device. The only hardware change to the device is the modified shape of the reflector that is part of the Hand Piece, so that the acoustic wave is less dispersed and penetrates deeper in the subcutaneous tissue where fibrous septa are located.

    AI/ML Overview

    The provided content describes the clearance of the Rapid Acoustic Pulse Device (RAP) by the FDA, including some information about a clinical study for cellulite improvement. However, it does not contain a comprehensive table of acceptance criteria or detailed results of a study designed specifically to prove the device meets these criteria in a structured format often seen in medical device submissions. The information provided is more of a summary for a 510(k) clearance.

    Based on the available text, I can extract and infer some information, but a complete answer to all your questions cannot be provided because the document focuses on regulatory clearance rather than a detailed scientific study publication with specific acceptance criteria and detailed performance metrics.

    Here's an attempt to answer your questions based on the provided text:

    Acceptance Criteria and Device Performance Study Summary

    The document describes the RAP device's safety and effectiveness for improving the appearance of cellulite, evaluated in a prospective multi-site trial. The primary analysis was conducted on 62 participants. While specific, quantitive acceptance criteria (e.g., "X% of patients must show Y improvement") are not explicitly stated, the FDA's acceptance of the 510(k) implies that the demonstrated safety and effectiveness were deemed sufficient for substantial equivalence.

    1. A table of acceptance criteria and the reported device performance

    As mentioned, explicit, numerical acceptance criteria for effectiveness are not present in the document. The general acceptance criteria for FDA 510(k) clearance revolve around demonstrating substantial equivalence to a predicate device, which includes equivalent safety and effectiveness. The reported performance relates to the "temporary improvement in the appearance of cellulite" and a favorable safety profile.

    Acceptance Criteria (Inferred from regulatory context)Reported Device Performance (from Clinical Study)
    Safety: Device must be safe for its intended use; adverse events expected to be minimal, transient, and manageable.All adverse events categorized as mild or moderate, transient, resolved without intervention. No serious or severe AEs. No participants stopped treatment due to AEs. Average pain rating 2.4 (0-10 scale).
    Effectiveness: Device must demonstrate temporary improvement in the appearance of cellulite. (Specific quantitative target not provided)Effectiveness assessed by blinded independent reviewers using Cellulite Severity Scale (CSS) and Global Aesthetic Improvement Scale (GAIS) based on serial clinical photographs. (Specific outcome percentages/scores not reported in this document).
    Tolerability: Treatment should be tolerable for patients.Participants found RAP treatment tolerable (average pain 2.4/10). Participants generally satisfied with treatment and results.
    Substantial Equivalence: Demonstrate technological characteristics and performance that do not raise new questions of safety or effectiveness compared to predicate devices.Nonclinical testing demonstrated device performs to specifications and functions as intended, with a favorable safety profile. Clinical testing confirmed differences in technology from predicate do not adversely impact performance.

    2. Sample size used for the test set and the data provenance

    • Sample Size (Test Set): 62 participants (from an initial enrollment of 67) for the primary analysis.
    • Data Provenance: Prospective, multi-site trial conducted at 4 sites in the United States.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    The document states: "Photographs were assessed by blinded independent reviewers to identify pre-treatment images when compared to post treatment images and to grade the pre-treatment and post-treatment images using the CSS and improvement using the Global Aesthetic Improvement Scale (GAIS)."

    • Number of Experts: Not specified. It mentions "independent reviewers" (plural), suggesting more than one, but the exact number is not provided.
    • Qualifications of Experts: Not specified. They are simply referred to as "blinded independent reviewers." Their specific medical background (e.g., dermatologists, plastic surgeons, radiologists) and years of experience are not detailed in this document.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    The adjudication method for the reviewers is not explicitly stated in the provided text. It simply says "assessed by blinded independent reviewers."

    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 comparing human readers with and without AI assistance was not conducted or described. This device is a physical medical device (Rapid Acoustic Pulse Device), not an AI diagnostic algorithm for image interpretation.

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

    • This question is not applicable. The device is a physical medical device, not an AI algorithm.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    • The "ground truth" for effectiveness in cellulite improvement was established via expert assessment of clinical photographs using validated scales (CSS and GAIS) by "blinded independent reviewers."
    • For safety, it was based on adverse event reporting via physician examination and patient tolerability/satisfaction.

    8. The sample size for the training set

    • This question is not applicable. The device is a physical medical device, not an AI algorithm that requires a training set. The study described is a clinical trial to evaluate the device's performance directly.

    9. How the ground truth for the training set was established

    • This question is not applicable as there is no AI algorithm training set mentioned.
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