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510(k) Data Aggregation

    K Number
    K230734
    Date Cleared
    2023-12-05

    (264 days)

    Product Code
    Regulation Number
    878.4550
    Reference & Predicate Devices
    Why did this record match?
    510k Summary Text (Full-text Search) :

    Imager Kit (MSI Kit) (300-00015), Multispectral Imager (MSI) (300-00009) Regulation Number: 21 CFR 878.4165
    |
    | Classification Regulation: | 21 CFR 878.4165
    |
    | Regulatory Number: | 878.4165

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

    The MSI is a handheld imaging tool that allows clinicians diagnosing and treating skin wounds to:
    · View and digitally record images of a wound.
    · Measure and digitally record the size of a wound.

    • · View and digitally record images of fluorescence emitted from a wound when exposed to an excitation light.
      · View and digitally record thermal images of a wound.
      The MSI does not diagnose or treat skin wounds.
    Device Description

    The MSI Kit includes the following: the MSI, a Universal Serial Bus (USB-C) cable, a wall adapter, and a carrying case.
    The MSI captures and processes optical data of an imaged wound. The MSI consists of three imaging modalities: white light, autofluorescence and thermal. The MSI has 395nm excitation LEDs for autofluorescence imaging, a sensor for measuring distance to the wound, and a thermal sensor for capturing temperature gradients.
    The MSI is powered by an onboard rechargeable battery and has a USB-C connection for uploading images to a computer. The manual provides users of the MSI with detailed instructions for proper use, maintenance, and storage.

    AI/ML Overview

    The provided text outlines the general safety and performance testing conducted for the Multispectral Imager Kit (MSI Kit) to establish its substantial equivalence to predicate devices, but it does not contain the specific acceptance criteria or detailed results of a study demonstrating the device meets those criteria.

    However, based on the information provided, here's a breakdown of what can be inferred and what is missing:

    Acceptance Criteria and Reported Device Performance:

    The document lists various performance tests, implying certain acceptance criteria for each, but the specific numerical targets or thresholds are not provided. The conclusion statement indicates that the clinical and non-clinical data "indicate that the MSI Kit is as safe and effective as the predicate devices," which serves as a general statement of meeting underlying acceptance criteria for equivalence.

    Missing information: The actual acceptance criteria (e.g., minimum accuracy for wound measurement, specific signal-to-noise ratio requirements for fluorescence imaging) and the quantitative results from the study demonstrating the device's performance against these criteria are not detailed in the provided text.


    Detailed Information based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    As noted above, specific acceptance criteria and detailed quantitative results are not provided in the document. The document lists the types of tests performed and generally states that the device's performance was evaluated, leading to a conclusion of safety and effectiveness comparable to predicate devices.

    Test TypeImplied Acceptance Criteria (General)Reported Device Performance (General)
    Reprocessing ValidationEffective cleaning and disinfectionValidated procedures provided in instructions for use.
    BiocompatibilitySafe for intact skin contact (user)Materials have a long history of safe use in medical devices, posing low biocompatibility risk.
    Software Verification & ValidationConforms to user needs and intended uses (IEC 62304, FDA Guidance)Unit tests, system-level verification (functional, traceability), and validation testing performed.
    CybersecurityRisks mitigated, acceptable cybersecurity threat risk (FDA Guidance)Cybersecurity information provided and risks mitigated.
    Electrical Safety (IEC 60601-1)Meets basic safety and essential performance requirementsDevice meets requirements.
    EMC Compatibility (IEC 60601-1-2)Meets electromagnetic disturbances requirementsDevice meets requirements.
    Light Sources/Laser Safety (IEC standards)Safe operation of LEDs and laserEvaluated in accordance with IEC 62471, IEC 60825-1, IEC 60601-2-57.
    Visualization Performance (Bench Studies)Acceptable image quality, accuracy, and consistencyImage field uniformity, distortion, field of view, magnification, geometric resolution, detection limits, linearity, SNR, thermal accuracy, wound measurement area, and comparison of fluorescence imaging with predicate all performed.
    Clinical Testing (Autofluorescence)Ability to detect autofluorescence signals consistent with indications for useClinical study demonstrated "quality and consistency of the MSI images for their intended use of visualizing wounds."

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

    • Test Set Sample Size: The document does not specify the sample size for any of the performance tests, including the clinical study.
    • Data Provenance:
      • Clinical Study: "A clinical study was conducted under anticipated conditions with anticipated users." The location (country of origin) is not specified, nor is whether it was retrospective or prospective. Given the phrasing "conducted," it implies a prospective study.
      • Bench Studies: Performed to verify various performance aspects. No information on data provenance other than being "bench studies."

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

    The document states that the MSI is "a handheld imaging tool that allows clinicians diagnosing and treating skin wounds to: ... View and digitally record images of fluorescence emitted from a wound when exposed to an excitation light," and that it "does not diagnose or treat skin wounds." The clinical study evaluated the "ability of the MSI to detect autofluorescence signals from tissues or structures consistent with the indications for use."

    This implies that the assessment of autofluorescence signals in wounds would typically require clinical experts. However, the document does not specify the number of experts or their qualifications used to establish ground truth for any test set.


    4. Adjudication method for the test set

    The document does not specify any adjudication method for establishing ground truth in the clinical study or any other performance testing.


    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

    The document does not mention a multi-reader, multi-case (MRMC) comparative effectiveness study, nor does it refer to AI assistance or human reader improvement with AI. The device is described as an "imaging tool" for clinicians, not as an AI-powered diagnostic aid that assists in interpretation.


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

    The device description focuses on its imaging capabilities and the output of images (white light, fluorescence, thermal) for clinician evaluation. None of the performance data sections suggest a standalone algorithm-only performance assessment where the device makes interpretations without human involvement. The indications for use specifically state it "does not diagnose or treat skin wounds" and provides images for clinicians.


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

    The document does not explicitly state the type of ground truth used in the clinical study. For "autofluorescence signals from tissues or structures consistent with the indications for use," the ground truth would likely involve a clinical assessment by wound care specialists or potentially correlated with wound characteristics that are known to exhibit certain autofluorescence, but this is not specified.


    8. The sample size for the training set

    The document does not mention a training set or its sample size. This suggests that the device's functionality does not rely on a machine learning model that requires a labeled training dataset in the way a diagnostic AI would. The device's operation, as described, appears to be based on capturing and processing optical and thermal data rather than learning from data.


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

    Since no training set is mentioned, there is no information on how ground truth for a training set was established.

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    K Number
    K191371
    Device Name
    MolecuLight i:X
    Manufacturer
    Date Cleared
    2019-12-04

    (196 days)

    Product Code
    Regulation Number
    878.4550
    Reference & Predicate Devices
    N/A
    Why did this record match?
    510k Summary Text (Full-text Search) :

    | 21 CFR 878.4550 | 21 CFR 878.4165

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

    The MolecuLight i:X is a handheld imaging tool that allows clinicians diagnosing and treating skin wounds, at the point of care, to

    • View and digitally record images of a wound, (i)
    • Measure and digitally record the size of a wound, and (ii)
    • View and digitally record images of fluorescence emitted from a wound when exposed to an excitation light. (iii)

    The fluorescence image, when used in combination with clinical signs and symptoms, has been shown to increase the likelihood that clinicians can identify wounds containing bacterial loads >104 CFU per gram as compared to examination of clinical signs and symptoms alone. The MolecuLight i:X device should not be used to rule-out the presence of bacteria in a wound.

    The MolecuLight i:X does not diagnose or treat skin wounds.

    Device Description

    The MolecuLight i:X Imaging Device is a handheld medical imaging device comprised of a high-resolution color LCD display and touch-sensitive screen with integrated optical and microelectronic components. Moleculight i:X uses its patented technology to enable real-time standard digital imaging and fluorescence imaging in wounds and surrounding healthy skin of patients as well as wound area measurements.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and the study that proves the MolecuLight i:X device meets them, based on the provided FDA 510(k) summary:

    1. Table of Acceptance Criteria and Reported Device Performance

    The core clinical claim for the MolecuLight i:X related to bacterial identification is: "The fluorescence image, when used in combination with clinical signs and symptoms, has been shown to increase the likelihood that clinicians can identify wounds containing bacterial loads >10^4 CFU per gram as compared to examination of clinical signs and symptoms alone."

    While the document doesn't explicitly state quantitative acceptance criteria in the "we will achieve X performance" format, the demonstrated performance serves as the evidence for meeting their stated claim. The crucial part of the performance is the improvement in identifying wounds with relevant bacterial loads.

    Acceptance Criteria (Implied by Clinical Claim and Study Results)

    Metric (vs. CSS alone)Acceptance Threshold (Implied)Reported Device Performance (CSS + iX vs. CSS)
    Sensitivity IncreaseIncrease in likelihood of identifying wounds with >10^4 CFU/g bacteriaCSS+iX: 60.98%
    CSS: 15.33%
    (~4x increase)
    Specificity ChangeMaintain acceptable specificity / avoid significant decrease in correctly ruling out bacteriaCSS+iX: 84.13%
    CSS: 93.65%
    (~9.5% decrease)
    False Positive Rate10^4 CFU/g, whose resulting bacterial load determined by conventional microbiological analysis was 10^4 CFU/g): n = 287
    *   Microbiology Negative (10^4 CFU/g) was "quantitative microbiological analysis," which is a lab-based, objective method, not dependent on expert consensus.
    

    4. Adjudication Method for the Test Set

    • The document does not describe an adjudication method for the clinical evaluation of CSS or the interpretation of MolecuLight i:X images. It compares these clinical assessments directly against the quantitative microbiological analysis. This suggests that individual clinicians' interpretations were the data points, rather than a consensus interpretation.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    • A formal MRMC study is not explicitly mentioned as having been performed. The study evaluates the likelihood that clinicians can identify wounds, comparing performance with and without the device. While it involves multiple clinicians, it's presented as a direct comparison of the combined CSS+iX approach versus CSS alone, rather than a statistical comparison of reader performance improvement.
    • Effect Size:
      • The sensitivity for identifying high bacterial loads increased from 15.33% (CSS alone) to 60.98% (CSS + iX). This is a substantial increase, making the device significantly more likely to flag relevant wounds.
      • The specificity decreased from 93.65% (CSS alone) to 84.13% (CSS + iX). This indicates a trade-off where more wounds were incorrectly identified as having high bacterial loads with the device, but the report explicitly states this increase in false positives was "10^4 CFU per gram). This is an objective and laboratory-confirmed ground truth, considered a strong reference standard for bacterial burden.

    8. Sample Size for the Training Set

    • The document does not specify a separate training set or its size. This is typical for a medical device that provides direct imaging for human interpretation, rather than a machine learning algorithm that is "trained" on data. The clinical study described here functions as the pivotal performance validation.

    9. How Ground Truth for the Training Set was Established

    • As no separate training set or AI/ML training is indicated, this point is not applicable. The ground truth for the clinical study was established by quantitative microbiological analysis of wound samples.
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    K Number
    DEN180008
    Device Name
    MolecuLight i:X
    Manufacturer
    Date Cleared
    2018-07-31

    (165 days)

    Product Code
    Regulation Number
    878.4165
    Type
    Direct
    Reference & Predicate Devices
    N/A
    Why did this record match?
    510k Summary Text (Full-text Search) :

    .

    NEW REGULATION NUMBER: 21 CFR 878.4165

    CLASSIFICATION: Class I (Exempt from premarket notification
    (Exempt from premarket notification, subject to the limitations in 878.9) Regulation Number: 21 CFR 878.4165

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

    The MolecuLight i:X is a handheld imaging tool that allows clinicians diagnosing and treating skin wounds, at the point of care, to

    • view and digitally record images of a wound, and (i)
    • view and digitally record images of fluorescence emitted from a wound (ii) when exposed to an excitation light.

    The MolecuLight i:X is for prescription use only.

    Device Description

    The MolecuLight i:X is a handheld, portable, and battery operated white light and fluorescence imaging tool. The MolecuLight i:X can (i) view and digitally record standard (ST) digital images of a wound.

    Standard digital images/video capture the appearance of the wound under illumination of broad band white light, like regular photography. This Standard Imaging Mode does not require contact with the patient and the distance between the device and wound is kept consistent (8 - 12 cm) between imaging sessions through the use of the built in range finder

    The MolecuLight i:X can also capture fluorescence features of wounds in real-time when used in Fluorescence Imaging Mode and it enables the user to document this fluorescence information. When the level of ambient light in the examination room is acceptable, an indicator light informs the user that fluorescence images (or videos) can be acquired. The distance between the device to the patient is maintained at 8 - 12 cm as guided by the range finder indicator light. The device has 450nm excitation light and is capable to detect fluorescence signals in 500-545 and 600-665nm wavelengths. The Moleculight i:X is not intended to quantify the fluorescence emitted from a wound.

    AI/ML Overview

    The MolecuLight i:X is a wound autofluorescence imaging device. The device is not intended to provide quantitative or diagnostic information, but rather to allow clinicians to view and digitally record images of wounds and fluorescence emitted from wounds.

    Here's an analysis of the acceptance criteria and the study proving the device meets them:

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

    Acceptance CriteriaReported Device Performance
    Fluorescence Detection Depth0.8 mm (achieved)
    Linear range, green, maximum illumination intensity1-88% of Full Scale Image Sensor Range (0-125 nM Quantum Dots)
    Linear range, green, minimum illumination intensity0-94% of Full Scale Image Sensor Range (0-250 nM Quantum Dots)
    Linear range, red, maximum illumination intensity3-90% of Full Scale Image Sensor Range (0.5-5.6 nM Quantum Dots)
    Linear range, red, minimum illumination intensity2-95% of Full Scale Image Sensor Range (0.5-7.7 nM Quantum Dots)
    Limits of detection, green, maximum illumination intensity20-111 nM Quantum Dots
    Limits of detection, green, minimum illumination intensity20-182 nM Quantum Dots
    Limits of detection, red, maximum illumination intensity0.7-4.6 nM Quantum Dots
    Limits of detection, red, minimum illumination intensity0.5-5.6 nM Quantum Dots
    Excitation Source Intensity Variation100% to 52% at corners (met specification requirements for uniformity)
    Fluorescence Imaging Signal-to-Noise Ratio (SNR) - Green (Max Illumination, min limit of detection)2.2 (met)
    Fluorescence Imaging Signal-to-Noise Ratio (SNR) - Green (Max Illumination, max limit of detection)8.5 (met)
    Fluorescence Imaging Signal-to-Noise Ratio (SNR) - Green (Min Illumination, min limit of detection)2.4 (met)
    Fluorescence Imaging Signal-to-Noise Ratio (SNR) - Green (Min Illumination, max limit of detection)8.3 (met)
    Fluorescence Imaging Signal-to-Noise Ratio (SNR) - Red (Max Illumination, min limit of detection)1.2 (met)
    Fluorescence Imaging Signal-to-Noise Ratio (SNR) - Red (Max Illumination, max limit of detection)7.8 (met)
    Fluorescence Imaging Signal-to-Noise Ratio (SNR) - Red (Min Illumination, min limit of detection)1.8 (met)
    Fluorescence Imaging Signal-to-Noise Ratio (SNR) - Red (Min Illumination, max limit of detection)6.3 (met)
    BiocompatibilityNo patient-contacting components (addressed)
    Shelf LifeGreater than 2 years (evaluated and determined)
    Reprocessing (Cleaning)
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