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510(k) Data Aggregation
(108 days)
Germantown, WI 53022
Re: K173934
Trade/Device Name: Reza Band, Reflux Band Regulation Number: 21 CFR 874.5900
| External upper esophageal sphincter (UES) compression device (21 CFR 874.5900
The Reza Band and the Reflux Band are for people 18 years and older to reduce the symptoms of laryngopharyngeal reflux (LPR) disease by reducing the regurgitation of stomach contents from passing through the upper esophageal sphincter. The devices are worn by the user while sleeping.
The Reza Band and Reflux Band are proposed for over the counter (OTC) use.
The proposed devices are non-invasive and non-sterile worn by the user while sleeping. As with the predicate device (Reza Band), the proposed Reza Band and Reflux Band were designed as a treatment for LPR symptoms.
The mode of operation of these devices is to provide slight external pressure, typically in a range of 20-30 mmHg, at the cricoid cartilage region. This external pressure increases the luminal pressure within the upper esophageal sphincter (UES). It has been shown that when the UES is subjected to the increased external pressure, it reduces stomach contents from coming up into the larynx, pharynx and lungs.
The user positions the device around their neck. For the Reflux Band, the user uses an application (App) installed on an iOS or Android mobile device to fit the Reflux Band to the desired externally applied pressure. The electronics of the Reflux Band have been incorporated into its cushion (SmartCushion) so that the Reflux Band can interact with the App. For the Reza Band, the user utilizes the accessories External Manometer and Pressure Sensor to properly fit the device. A typical range is also 20-30mmHg of applied pressure.
The components of the Reflux Band and Reflux Band are identical of a Cushion, Comfort Band, Frame, Comfort Dial and Clasp.
The provided text describes the Reza Band and Reflux Band, external upper esophageal sphincter (UES) compression devices, and their substantial equivalence to a predicate device for the reduction of laryngopharyngeal reflux (LPR) symptoms. The document is a 510(k) summary, which focuses on demonstrating substantial equivalence rather than presenting detailed acceptance criteria and studies in the format requested.
Therefore, the available information is insufficient to fully complete the requested table and details regarding acceptance criteria and performance data as per your prompt. However, I can extract what is explicitly stated in the document.
Here's a summary of the available information and an explanation of what is missing based on your request:
1. Table of acceptance criteria and the reported device performance:
The document does not explicitly state acceptance criteria in terms of numerical thresholds for outcomes. Instead, it mentions various tests performed and concludes substantial equivalence.
Acceptance Criteria (Implied) | Reported Device Performance |
---|---|
Non-Clinical Performance: | |
Electrical Safety (IEC 60601-1 compliance) | Tested to IEC 60601-1 (Compliance implies meeting the safety standards) |
Electromagnetic Compatibility (IEC 60601-1-2 compliance) | Tested to IEC 60601-1-2 (Compliance implies meeting the EMC standards) |
Software Functionality (Software Verification and Validation) | Software Verification and Validation performed (Successful completion implies software functions as intended) |
Manometer Accuracy (Bench Testing) | Bench Testing for Manometer Accuracy performed (Successful completion implies manometer provides accurate pressure readings) |
Device Stability (Shelf Life Testing) | Shelf Life Testing performed (Successful completion implies device maintains its properties over its designated shelf life) |
Clinical Performance: | |
Usability for OTC use | Usability testing performed (Successful usability suggests users can properly operate the device without medical supervision) |
User Comprehension of LPR symptoms (Reflux Symptom Index - RSI) | Comprehension testing of a tool commonly used for the population with LPR symptoms is the Reflux Symptom Index (RSI) (Successful comprehension suggests users can understand and report their symptoms using the common tool, supporting proper self-assessment and device usage in an OTC setting, and presumably demonstrating the device's ability to reduce symptoms as measured by this index). The document mentions "comprehension testing of a tool" which implies testing if users can understand symptoms measurement, not necessarily a direct measure of device effectiveness via RSI reduction in a clinical trial. However, the overall conclusion of "substantial equivalence" and "can be used safely and effectively as OTC devices" suggests that the clinical tests supported the device's ability to reduce LPR symptoms. |
Missing Information:
The document does not provide specific numerical acceptance criteria (e.g., "RSI score reduction by X points" or "accuracy of manometer within +/- Y mmHg"). The "Reported Device Performance" column above is based on the implication of successfully performing the tests mentioned, rather than specific quantitative results.
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective):
- Sample Size for Test Set: Not explicitly stated for either usability testing or comprehension testing.
- Data Provenance: Not explicitly stated (e.g., country of origin, retrospective/prospective).
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience):
This information is not provided. For non-clinical tests like electrical safety or bench testing, "ground truth" is typically established by engineering standards and measurement equipment. For clinical/usability tests, the "experts" or evaluators are not described.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
This information is not provided.
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 type of study is not relevant to the device described (an external UES compression device) which is not an AI-powered diagnostic or interpretive tool. Therefore, no MRMC study or AI assistance effect size is mentioned.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
This concept is not applicable to the device described as it is a physical, user-operated device, not a standalone algorithm. The "software" mentioned for the Reflux Band (an app) supports device fitting, not a standalone diagnostic interpretation.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc):
- For non-clinical tests (IEC standards, bench testing, shelf life): Ground truth is typically derived from established engineering and safety standards, validated measurement equipment, and defined material properties.
- For usability and comprehension testing: Ground truth would likely be based on expert observation of user interaction, user feedback, and pre-defined criteria for successful task completion or correct understanding. The mention of the Reflux Symptom Index (RSI) suggests that symptom reduction, as reported by patients using this validated tool, would be a key outcome for efficacy (though the text only mentions comprehension of the tool, not direct efficacy results). However, specific details on how "ground truth" for efficacy was established for substantial equivalence are not provided in this summary.
8. The sample size for the training set:
This device is not an AI/machine learning model that typically relies on a "training set" in the computational sense. Therefore, this concept is not applicable to the information provided.
9. How the ground truth for the training set was established:
As mentioned above, the concept of a "training set" with associated ground truth is not applicable to this physical device submission.
Conclusion based on provided text:
The provided document is a 510(k) summary focused on demonstrating "substantial equivalence" of the Reza Band and Reflux Band to a predicate device (Reza Band, DEN130046). It lists various non-clinical and clinical tests performed, but it does not provide the detailed quantitative acceptance criteria, specific performance metrics, sample sizes, expert qualifications, or adjudication methods that would typically be found in a comprehensive study report. The intent of a 510(k) summary is to summarize findings that support a claim of substantial equivalence for regulatory purposes, rather than being a full scientific publication of detailed study results.
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(477 days)
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NEW REGULATION NUMBER: 874.5900
CLASSIFICATION: CLASS II
PRODUCT CODE: PKA
BACKGROUND
PKA Device Type: External Upper Esophageal Sphincter Compression Device Class: II Regulation: 21 CFR 874.5900
The Reza Band® UES Assist Device is indicated for patients 18 years and older to reduce the symptoms of larvngopharyngeal reflux (LPR) disease by reducing the regurgitation of stomach contents from passing through the upper esophageal sphincter. The device is worn by the patient when sleeping.
The Reza Band® UES Assist Device (Reza Band) (Figure 1) is a non-invasive, non-sterile device worn by the patient and is designed to provide a set pressure (20-30 mm Hg) on the cricoid cartilage, which increases the luminal pressure within the upper esophageal sphincter (UES). The patient wears the Reza Band after being fit by the physician (Figure 2).
The Reza Band has 5 main components:
- Frame
- Cushion
- Comfort Band
- Clasp
- Comfort Dial
The Reza Band® External Manometer (External Manometer) is a hand-held device and is connected to the Reza Band® Pressure Sensor (Pressure Sensor). It is used by the treating physician, is powered by a AAA battery and displays the pressure being applied to the cricoid cartilage region by the Reza Band in millimeters of Mercury (mm Hg) as the Reza Band® is being fitted (Figure 3).
The Pressure Sensor connected to the External Manometer is regulated as a miniature pressure transducer (21 CFR Part 890.1615) which is Class I exempt. The Pressure Sensor and the External Manometer were assessed to ensure that the Reza Band® was accurately applying the specified pressure.
The Reza Band® Upper Esophageal Sphincter (UES) Assist Device did not undergo a study that assessed its performance against specific, pre-defined acceptance criteria with a quantifiable metric (e.g., accuracy, sensitivity, specificity). Instead, the studies focused on demonstrating the safety and effectiveness of the device.
Here's a breakdown of the requested information based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
As mentioned, there isn't a direct table of "acceptance criteria" where a specific quantitative metric (like accuracy or AUC) is listed alongside a target value and then the device's performance against that target for a classification task. The studies provided focus on demonstrating safety and symptomatic improvement.
Bench Test Acceptance Criteria and Results (from Table 2):
Test | Acceptance Criteria (Implicit) | Reported Device Performance |
---|---|---|
Reza Band Neck Ring Lifetime Test | Retention of intended functionality over 6-month use period. | All established acceptance criteria were met. |
Reza Band Mechanical Test | - Comfort Band: No significant change in length after pull testing. |
- Frame Pusher: No damage/failures; Comfort Dial functions as intended after pull testing.
- Frame Body: No failure, damage, or deformation after force application. | - Comfort Band: Length not significantly different after being pulled.
- Frame Pusher: No damage or failures; Comfort Dial continued to function.
- Frame Body: Did not fail; no damage noted after being subjected to force. |
| Reza Band Accelerated Aging Shelf Life Testing | Retention of intended functionality over simulated 6-month shelf life. | With the exception of observations regarding Frame Body magnets (rationale provided), acceptance criteria were met. |
| Reza Band, External Manometer and Pressure Sensor Shipping Test | Withstand damage and retain intended functionality after simulated shipping conditions. | Demonstrated continued functionality and conformance with specifications. |
| External Manometer Pressure Measurement Accuracy Testing | Pressure measurement accuracy within design specifications. | Within (b)(4) mmHg as specified over the (b)(4) range. |
| External Manometer Life Test | Maintain functionality over its intended 600-use lifetime. | All established acceptance criteria were met following (b)(4) (in excess of 600-use requirement). |
Clinical Study Effectiveness Endpoint (from Study #1):
Acceptance Criteria (Implicit) | Reported Device Performance |
---|---|
Primary Effectiveness Endpoint: Percent reduction in Reflux Symptom Index (RSI) from Baseline to Visit 3 (Week 4) | - Mean % change in RSI from Baseline to Visit 3: -54.3% (p25%): |
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