K Number
K033452
Device Name
CWAS 1000
Manufacturer
Date Cleared
2003-11-28

(29 days)

Product Code
Regulation Number
890.1375
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The CWAS 100 is a non-invasive, multi-modality physiologic monitoring device. The device measures several physiologic signals, and its software generates a report. The CWAS 100 measures the following physiologic signals: - Bilateral differences in surface EMG along the spine - Heart Rate - Skin temperature - Galvanic Skin Resistance - Body fat percentage in subjects eighteen years and older
Device Description
The CWAS 100 is a non-invasive, multi-modality physiologic monitoring device. The CWAS 100 contains the following five sensor types: (1) surface EMG, (2) IR Plethsmograph, (3), Skin temperature, (4) Galvanic Skin Resistance and (5) IR Body Composition Analyzer. Hardware: The CWAS 100 hardware consists of an instrument console and five different sensor types. All five sensor types plug directly into the front panel of the CWAS 100 Instrument Console. The CWAS 100 Console is powered via a UL2601 listed power supply. The Instrument Console is connected to a personal computer (IBM compatible) via an isolated USB port connection. Software: The CWAS 100 software displays real-time surface EMG, heart rate, skin temperature, Galvanic Skin Resistance, and Body Composition, allowing the user to ensure that readings are stable prior to data collection. The CWAS 100 software allows the user to: (1) enter patient information, (2) record surface EMG, heart rate, skin temperature, Galvanic Skin Resistance, and Body Composition, and (3) print out a data report which summarizes the results of the above sensors as well as blood pressure, vital lung capacity, and chest, leg and back strength, which are data provided by the user.
More Information

Not Found

No
The summary describes a device that collects and reports physiological data from multiple sensors. It does not mention any AI or ML algorithms being used for data analysis, interpretation, or report generation. The software appears to primarily display real-time data and generate a summary report based on direct sensor readings and user-provided data.

No

The device is described as a "physiologic monitoring device" that "measures several physiologic signals." Its function is to collect data and generate reports, rather than to administer therapy or treatment.

Yes

The device is described as a "multi-modality physiologic monitoring device" and measures several physiologic signals, generating a report. The measurements include bilateral differences in surface EMG, heart rate, skin temperature, and galvanic skin resistance, which are used to assess physiological states, indicating its use in diagnosis or monitoring for diagnostic purposes.

No

The device description explicitly states that the CWAS 100 contains hardware components, including an instrument console and five different sensor types. The software interacts with and processes data from this hardware.

Based on the provided information, the CWAS 100 is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • IVD Definition: An IVD device is used to examine specimens derived from the human body (like blood, urine, tissue) to provide information for diagnosis, monitoring, or screening.
  • CWAS 100 Function: The CWAS 100 is described as a "non-invasive, multi-modality physiologic monitoring device." It measures physiological signals directly from the body's surface (EMG, heart rate, skin temperature, galvanic skin resistance, body fat percentage). It does not analyze specimens taken from the body.

The device's function aligns with a general physiological monitoring device, not an IVD.

N/A

Intended Use / Indications for Use

The CWAS 100 is a non-invasive, multi-modality physiologic monitoring device. The device measures several physiologic signals, and its software generates a report.

The CWAS 100 measures the following physiologic signals:

  • Bilateral differences in surface EMG along the spine
  • Heart Rate
  • Skin temperature
  • Galvanic Skin Resistance
  • Body fat percentage in subjects eighteen years and older

Product codes

IKN

Device Description

The CWAS 100 is a non-invasive, multi-modality physiologic monitoring device. The CWAS 100 contains the following five sensor types: (1) surface EMG, (2) IR Plethsmograph, (3), Skin temperature, (4) Galvanic Skin Resistance and (5) IR Body Composition Analyzer.

Hardware
The CWAS 100 hardware consists of an instrument console and five different sensor types. All five sensor types plug directly into the front panel of the CWAS 100 Instrument Console. The CWAS 100 Console is powered via a UL2601 listed power supply. The Instrument Console is connected to a personal computer (IBM compatible) via an isolated USB port connection.

Software
The CWAS 100 software displays real-time surface EMG, heart rate, skin temperature, Galvanic Skin Resistance, and Body Composition, allowing the user to ensure that readings are stable prior to data collection. The CWAS 100 software allows the user to: (1) enter patient information, (2) record surface EMG, heart rate, skin temperature, Galvanic Skin Resistance, and Body Composition, and (3) print out a data report which summarizes the results of the above sensors as well as blood pressure, vital lung capacity, and chest, leg and back strength, which are data provided by the user.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Spine (for bilateral differences in surface EMG)

Indicated Patient Age Range

subjects eighteen years and older (for body fat percentage)

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies

Not Found

Key Metrics

Not Found

Predicate Device(s)

K023209, K914920, K963271

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 890.1375 Diagnostic electromyograph.

(a)
Identification. A diagnostic electromyograph is a device intended for medical purposes, such as to monitor and display the bioelectric signals produced by muscles, to stimulate peripheral nerves, and to monitor and display the electrical activity produced by nerves, for the diagnosis and prognosis of neuromuscular disease.(b)
Classification. Class II (performance standards).

0

Section 1: Device Name

Electromyograph, Diagnostic Common or Usual Name: Proprietary Model Name: CWAS 100 Electromyograph, Diagnostic Regulation Name: Regulation Number: 21 CFR 890.1375

Section 2: Indications for Use

The CWAS 100 is a non-invasive, multi-modality physiologic monitoring device. The device measures several physiologic signals, and its software generates a report.

The CWAS 100 measures the following physiologic signals:

  • 파 Bilateral differences in surface EMG along the spine
  • 체 Heart Rate
  • Skin temperature 보
  • 트 Galvanic Skin Resistance
  • Body fat percentage in subjects eighteen years and older

Device Description Section 3:

The CWAS 100 is a non-invasive, multi-modality physiologic monitoring device. The CWAS 100 contains the following five sensor types: (1) surface EMG, (2) IR Plethsmograph, (3), Skin temperature, (4) Galvanic Skin Resistance and (5) IR Body Composition Analyzer.

Hardware

The CWAS 100 hardware consists of an instrument console and five different sensor types. All five sensor types plug directly into the front panel of the CWAS 100 Instrument Console. The CWAS 100 Console is powered via a UL2601 listed power supply. The Instrument Console is connected to a personal computer (IBM compatible) via an isolated USB port connection.

Software

The CWAS 100 software displays real-time surface EMG, heart rate, skin temperature, Galvanic Skin Resistance, and Body Composition, allowing the user to ensure that readings are stable prior to data collection. The CWAS 100 software allows the user to: (1) enter patient information, (2) record surface EMG, heart rate, skin temperature, Galvanic Skin Resistance, and Body Composition, and (3) print out a data report which summarizes the results of the above sensors as well as blood pressure, vital lung capacity, and chest, leg and back strength, which are data provided by the user.

510(k) Summary Fasstech CWAS 100

1

K033452 20f6

Predicate Device Section 4:

The CWAS 100 is an expansion of the Insight Millennium III, a device that we have previously registered with FDA. The CWAS 100 differs from the Insight Millennium III in the following manners:

    1. Hardware: Addition of two new sensors, and the elimination of two previous sensors.
  • Software: The Insight Millennium III software has been modified to: (1) add the display and 2. reporting functionality for the two new CWAS 100 sensors, (2) remove the display and reporting functionality for the two eliminated Insight Millennium III sensors, and (3) add the functionality to have the user enter other physiologic data about the patient, and incorporate this information into the reporting function.

The balance of this section documents the substantial equivalence of CWAS 100 to the following three products:

ManufacturerPredicate Device Name510(k) Number
Insight Millennium IIIFasstechK023209
Biofeedback System/3DaviconK914920
Futrex 6100/XLFutrex, Inc.K963271

The CWAS 100 is equivalent to these legally marketed devices in the following ways:

  • The physical characteristics and electrical characteristics (performance characteristics) of the 트 CWAS 100 are equivalent to the Insight Millennium III. The only difference is the addition of two sensor types (Galvanic Skin Resistance and IR Body Composition Analyzer), and the elimination of two sensors that were part of the Insight Millennium III (Algometer and Inclinometer).
  • . The physical characteristics and electrical characteristics (performance characteristics) of the CWAS 100 Galvanic Skin Resistance sensor is equivalent to the Biofeedback System/3 Galvanic Skin Resistance sensor
  • 비 The CWAS 100 IR Body Composition Analyzer sensor is the Futrex 6100/XL sensor. This sensor is registered with FDA, and has been combined with the CWAS 100 for user convenience.

The CWAS 100 differs from these legally marketed devices in the following ways:

  • The device types listed above have been combined for reasons of user convenience. ■
  • 피 The CWAS 100 data report combines a variety of physiologic data for user convenience.

2

K033452 3of 6

Predicate Device Comparison Chart

| Component | Feature | CWAS 100 | Insight
Millennium III | Futrex 6100 | Biofeedback
System/3 |
|-----------------------------|--------------------------|--------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------|------------------------------------|-------------------------------------|
| Surface EMG | | Yes | Yes | N/A | N/A |
| | Calibrated Range | 0.1 - 999 uV | 0.1 – 999 uV | N/A | N/A |
| | Common Mode
Rejection | 150 dB | 150 dB | N/A | N/A |
| | Bandwidth | 20-500 Hz (50/60
Hz notch) | 20-500 Hz (50/60
Hz notch) | N/A | N/A |
| Skin
Temperature | | Yes | Yes | N/A | N/A |
| | Calibrated Range | 55°F - 120°F | 55°F - 120°F | | |
| | Accuracy | $\pm$ 0.2°F nominal | $\pm$ 0.2°F nominal | | |
| IR
Plethsmograph | | Yes | Yes | N/A | N/A |
| | Output Voltage | 5 - 50 mV, typical
at rest | 5 - 50 mV, typical
at rest | N/A | N/A |
| | Output Impedance | 1 kΩ, nominal | 1 kΩ, nominal | N/A | N/A |
| Instrument
Console | | | | | |
| | Output | Isolated USB | Isolated USB | N/A | N/A |
| | A/D converter | 16 bit, 16
channel | 16 bit, 16
channel | N/A | N/A |
| | Controls | None | None | N/A | N/A |
| | Indicators | Rear Panel:
Green LED
Power Indicator
Front Panel:
Green LED PC
connect Indicator | Rear Panel:
Green LED
Power Indicator
Front Panel:
Green LED PC
connect Indicator | N/A | N/A |
| | Power | 12 VDC, 28 W
converter,
internal. | 12 VDC, 28 W
converter,
internal. | N/A | N/A |
| | Physical | 3.5"H x
8.375"W x 9"D.
Weight 3 lbs. 11
oz | 3.5"H x
8.375"W x 9"D.
Weight 3 lbs. 11
oz | N/A | N/A |
| Range of Motion
Sensor | | No | Yes | N/A | N/A |
| Algometer | | No | Yes | | |
| IR Body | | Yes | N/A | Yes | N/A |
| Composition
Analyzer | | | | | |
| | Measurement
Method | Near Infrared
Photo Reflectance | N/A | Near Infrared
Photo Reflectance | N/A |
| | Transmitters | Sequenced IR
LEDs , > 750 nM | N/A | Sequenced IR
LEDs , > 750 nM | N/A |
| | Measurement
Range | 3% - 45% Body
Fat | N/A | 3% - 45% Body
Fat | N/A |
| Galvanic Skin
Resistance | | Yes | N/A | N/A | Yes |
| | Measurement
Method | Constant Current
Conductance | N/A | N/A | Constant Current
Conductance |
| | Sensor Type | 2 each 1x2 cm
gold-plated brass | N/A | N/A | 2 each 1.0 cm2
gold-plated brass |
| | Current Density | 1.5 uA per cm2 | N/A | N/A | 3.0 uA per cm2 |
| | Measurement
Range | 1-100 Siemens | N/A | N/A | 0.8 - 50 Siemens |
| | Filtering | 3 pole Low Pass
F0 at 6 Hz | N/A | N/A | 12 Hz low pass,
18dB/oct |
| | Output Format | Logarithmic 40
dB range | N/A | N/A | A.C. logarithmic |

:

510(k) Summary
Fasstech
CWAS 100

Page 4/7

3

K033452 4 of 6

Section 5: Performance Specification

The CWAS 100 specifications are summarized below:

EMG

Electrodes:

Calibrated Range: Input Bias Current: Differential Input Impedance: Common Mode Rejection: Bandwidth: Noise: Detector: Controls:

Temperature

Calibrated Range: Accuracy: Sensors:

Controls: Physical:

Size:

510(k) Summary Fasstech CWAS 100

4 ea. Smart Sensors with low-noise preamplifiers integral to electrode assemblies 0.1 – 999 uV Less than 2.0 Picoamperes Greater than 1,000,000 Megaohms 150 dB 20-500 Hz (50/60 Hz notch) Less than 0.1 uV (inputs shorted) Log power detector, 250 mS averaging filter. None

55°F - 120°F ±0.2ºF nominal Two thermopile, fixed 2.5" apart (center-tocenter) Enter button Case Material: Impact-resistant, Aluminum with 0.5" ABS Plastic Outer Ring. 5.5"L x 3.5"W x 2.5"H. Weight 15 oz.

Page 5/7

4

KD33452 5 of 6

IR Plethsmograph
Sensor TypeIR Plethsmograph (attached to finger with
Velcro)
Output Voltage:5 - 50 mV, typical at rest
Output Impedance:1 kΩ, nominal
Weight:28 grams
Sensor Size:15 x 15 x6.3 mm
Galvanic Skin Resistance
Measurement Method:Constant Current Conductance
Sensor Type:2 each 1x2 cm gold-plated brass
Current Density:1.5 uA per cm²
Measurement Range:1-100 Siemens
Filtering:3 pole Low Pass Fo at 6 Hz
Output Format:Logarithmic 40 dB range
Futrex IR Body Composition Analyzer
Measurement Method:Near Infrared Photo Reflectance
Sensor TypePin Photodiode
Transmitters:Sequenced IR LEDs , > 750 nM
Measurement Range:3% - 45% Body Fat
Dimensions:2.3" diameter, and 0.8" height
Instrument Console
Inputs:4 each EMG electrodes
1 each temperature sensor
1 each IR Plethsmograph sensor
1 each GSR sensor
1 each Futrex IR Body Composition sensor
Output:Isolated USB
A/D converter:16 bit, 16 channel
Controls:None
Indicators:Rear Panel: Green LED Power Indicator
Front Panel: Green LED PC connect Indicator
Power:12 VDC, 28 W converter, internal.
Physical:Case Material: Impact resistant, flame retardant
ABS.
3.5"H x 8.375"W x 9"D. Weight 3 lbs. 11 oz.

Section 6: Patient Safety

The CWAS 100 patient isolation is assured by the following two electrical isolation barriers:

  • Medical-Grade Universal Power Supply: This device is a UL2601 compliant AC line to 1. 12 VDC, 28 W converter. This internal power supply is partitioned from all other circuitry via an earthed steel chassis. The power supply accepts 85-264 VAC, and 47-63 Hz via a IEC 60320 fused input module.
    510(k) Summary Fasstech CWAS 100

Page 6/7

5

K03452 6 of b

This supply provides low-level isolated power to the Non-Patient Side of the CWAS 100 circuitry, as well as power to the DC-to-DC isolation converter that powers to the Patient Side (see #2 below).

  • DC-to-DC Patient Isolation Converter: This converter is a UL2601 compliant DC-to-DC 2. converter, and meets the dielectric withstand and leakage current requirements of the UL2601 standard for Patient Care Equipment with isolated patient leads.
    This converter supplies all power to patient-applied parts and related circuitry. Each of the direct patient-applied parts have individual current limiters for fault condition.

In addition, the Patient Side of the CWAS 100 is isolated from the host PC as follows:

  • Signals are converted from analog voltages to 16 bit 3. Optically Isolated Data Link: digital values by the analog-to-digital converter (ADC). The digital data is sent to and from the USB of the PC across an optically isolated data link.
    This optical link is UL2601 compliant, providing the dielectric withstand and low leakage current characteristics specified in UL2601.

Section 7: Conclusion

The CWAS 100 is substantially equivalent to the predicate devices. Furthermore, the device is safe and effective for its intended use.

510(k) Summary Fasstech CWAS 100

Page 7/7

6

Image /page/6/Picture/1 description: The image shows the seal of the Department of Health & Human Services - USA. The seal is circular, with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is an image of a stylized eagle with three human profiles incorporated into its design. The eagle's head is facing left, and the profiles are stacked on top of each other.

Public Health Service

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

NOV 2 8 2003

Fasstech c/o Mr. Ned Devine Entela, Inc. 3033 Madison Avenue S.E. Grand Rapids, Michigan 49548

Re: K033452

Trade/Device Name: CWAS 100 Regulation Number: 21 CFR 890.1375 Regulation Name: Diagnostic electromyograph Regulatory Class: II Product Code: IKN Dated: November 13, 2003 Received: November 14, 2003

Dear Mr. Devine:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food. Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

7

Page 2 - Mr. Ned Devine

This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Office of Compliance at (301) 594-4659. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html

Sincerely yours,

Sincerely yours,

Mark A. Millman

Celia M. Witten, Ph.D., M.D. Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

8

Page Lof 1

510(k) Number (if known): ____________________________________________________________________________________________________________________________________________________

Device Name: CWAS 100

Indications for Use:

The CWAS 100 is a non-invasive, multi-modality physiologic monitoring device. The device measures several physiologic signals, and its software generates a report.

The CWAS 100 measures the following physiologic signals:

  • Bilateral differences in surface EMG along the spine �
  • Heart Rate 트
  • 피 Skin temperature
  • Galvanic Skin Resistance 방
  • Body fat percentage in subjects eighteen years and older 트

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

R. Merle A. Milliken

ivision Sign-Off ivision of General, Restorative and Neurological Devices

510(k) Number K033452