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510(k) Data Aggregation
(58 days)
The FEATHER 01 02 03 04 (Model: 01) is an Over the-Counter (OTC) device intended for the use in treating wrinkles on the face.
FEATHER 01 02 03 04 (Models: 01) is an over-the-counter light emitting diode (LED) device that emits energy for use in dermatology for the treatment of wrinkles. The device works by simultaneously emitting 630nm±10nm, 660nm±10nm, 850nm±10nm wavelengths for the treatment of wrinkles. There is only one power/control key on the device, press and hold it for 1.5s to turn on or off the device. Short press the button to adjust the intensity, the white indicator light means the device is running, the flash quickly indicator light means the device is low on power, the slow flashes indicator light means the device is charging.
Based on the provided FDA 510(k) clearance letter for the FEATHER 01 02 03 04 (Model:01) device, here's a breakdown of the acceptance criteria and the study that proves the device meets them.
It's important to note that the provided document is a 510(k) summary, which generally focuses on substantial equivalence to predicate devices rather than detailed clinical trial results for effectiveness when non-clinical tests are deemed sufficient. For this specific device, the submission explicitly states that "Clinical testing was not needed for this 510(k). The non-clinical performance testing described above is sufficient to support that the device can be used safely and effectively." Therefore, the "study that proves the device meets the acceptance criteria" refers to the non-clinical testing, not a clinical trial demonstrating efficacy.
Acceptance Criteria and Reported Device Performance
Since no clinical efficacy study was conducted for this 510(k) submission, the "acceptance criteria" primarily relate to safety and performance characteristics that demonstrate substantial equivalence to predicate devices. The performance is assessed through non-clinical testing against recognized standards.
Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria Category | Specific Criteria (from relevant standards/comparisons) | Reported Device Performance (from non-clinical tests) |
---|---|---|
Electrical Safety | Compliance with IEC 60601-1 Ed 3.2, IEC 60601-1-11 Ed 2.1, IEC 60601-2-57 Ed 2.0, IEC 60601-2-83 Ed 1.1 | Test results are in compliance with the safety standards' requirements for IEC 60601 series. |
Electromagnetic Compatibility (EMC) | Compliance with IEC 60601-1-2 Ed 4.1 | Test results are in compliance with the safety standards' requirements for IEC 60601 series. |
Battery Safety | Compliance with IEC 62133-2 Ed 5.0 | Complied with IEC 62133-2's requirements. Test results are in compliance with the safety standards' requirements. |
Photobiological Safety | Compliance with IEC 62471 Ed 1.0 | Complied with IEC 62471. Test results are in compliance with the safety standards' requirements. |
Software Verification & Validation | Compliance with FDA Guidance for Software Contained in Medical Devices (Basic level concern) | Software verification and validation conducted, documentation provided as recommended. |
Usability | Compliance with IEC 62366-1 and IEC 60601-1-6 | Usability testing conducted, device complies with standards. |
Wavelengths for Wrinkle Treatment | Wavelengths within ranges demonstrated safe/effective by predicates/legally marketed devices (605nm | 630nm±10nm, 660nm±10nm, 850nm±10nm. These are "fully covered by the predicate devices" and "demonstrate that red light in 605nm |
Total Intensity (Irradiance) | Similar to predicate devices (e.g., 65-70 mW/cm²) | Max. 70 mW/cm², which is similar to predicate devices. |
Treatment Time | Similar to predicate devices (e.g., 3 minutes) | 3 minutes per treatment, same as predicate devices. |
Study Details (Non-Clinical Performance Testing)
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Sample Size Used for the Test Set and Data Provenance:
- Sample Size: Not specified in terms of number of devices tested. For non-clinical performance and safety testing against standards (e.g., IEC 60601 series), usually a sample of devices is tested to demonstrate consistent performance and compliance. The document does not provide specific numbers of units tested.
- Data Provenance: The testing appears to be conducted by the manufacturer or a third-party testing facility, as indicated by compliance reports against international standards (IEC).
- Retrospective or Prospective: This type of non-clinical testing is inherently prospective, as it involves newly manufactured devices undergoing specific tests to demonstrate compliance.
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Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications:
- Not applicable in the typical sense for this submission. Ground truth for non-clinical performance testing is established by compliance with objective, measurable engineering and safety standards (e.g., electrical parameters, light output, battery performance). These are verified by accredited testing labs or qualified in-house engineers, not typically "experts" in the clinical interpretation sense.
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Adjudication Method for the Test Set:
- Not applicable. Results are based on objective measurements against predefined thresholds specified in the engineering and safety standards. There's no subjective interpretation requiring adjudication.
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Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:
- No. The document explicitly states: "Clinical testing was not needed for this 510(k). The non-clinical performance testing described above is sufficient to support that the device can be used safely and effectively." Therefore, no MRMC study, AI assistance, or human reader improvement data is presented.
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Standalone (Algorithm Only) Performance:
- This is not an AI/algorithm-driven diagnostic or treatment device in the context of typical standalone performance studies. It is a light-emitting medical device. The "software" mentioned is for device operation (e.g., power control, intensity adjustment), and its validation ensures the proper functioning of the device, not an algorithm's performance in interpreting data or making clinical decisions.
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Type of Ground Truth Used:
- For safety and performance testing, the "ground truth" is defined by the requirements of the international consensus standards (e.g., IEC 60601-1, IEC 62471, IEC 62133-2) and the specifications of the predicate devices. The device is deemed "effective" (in the context of a 510(k) for this type of device) if it meets these safety and performance benchmarks and is substantially equivalent to legally marketed devices for its intended use. There is no pathology or outcomes data presented from a clinical study.
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Sample Size for the Training Set:
- Not applicable. This is not a machine learning or AI device that requires a "training set" of data for algorithm development. The testing described is for hardware and embedded software compliance.
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How the Ground Truth for the Training Set Was Established:
- Not applicable, as there is no training set for an AI/ML algorithm.
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