K Number
K060846
Date Cleared
2007-12-03

(615 days)

Product Code
Regulation Number
882.5890
Reference & Predicate Devices
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

To be used for temporary relief of pain associated with sore and aching muscles in the lower back due to strain from exercise or normal household work activities choose Manual modes 1, 2, 3, 4, 5, 6 or Auto 4

To be used for temporary relief of pain associated with sore and aching muscles in the upper extremities (arm) due to strain from exercise or normal household work activities choose Manual modes 1, 2, 3, 4, 5, 6 or Auto 1 or Auto 3

To be used for temporary relief of pain associated with sore and aching muscles in the lower extremities (leg) due to strain from exercise or normal household work activities choose Manual modes 1, 2, 6 or Auto1 or Auto 4

Used to stimulate healthy muscles in order to improve and facilitate muscle performance choose Manual Mode 1 or Auto Mode 2

Device Description

The T1040 is a portable; battery powered (4.5 VDC) multi function device offering both Transcutaneous Electrical Nerve Stimulator (TENS) and Powered Muscle Stimulator (PMS) qualities in one device.

Independent channel (two pads) that effectively transfers your desired choice of preprogrammed electrical pulses directly through electrode adhesive pads to the suggested area of the body where the electrodes are placed, causing minimal muscle contractions. A garment belt is used to hold the electrode pads to treat the lower back muscles. There are 10 modes of operation, 6 manual and 4 automatic.

AI/ML Overview

Here's a breakdown of the acceptance criteria and the study information for the T1040 device, extracted from the provided 510(k) submission:

Acceptance Criteria and Device Performance

The submission relies on demonstrating substantial equivalence to existing predicate devices rather than setting specific numerical acceptance criteria for clinical performance. The acceptance criteria essentially revolve around the T1040's technical specifications falling within the range of, or being comparable to, the predicate devices, and its safety being established.

Acceptance Criteria CategorySpecific Criteria (Implicit or Explicit in Submission)Reported Device Performance (T1040)
Electrical ParametersMax. Voltage, Max. Current, Pulse Width, Pulse Period, Max. Pulse Frequency, Max. Charge per Phase, Max. Current Density, Max. Average Power DensitySee Table 14 - Comparison Table (Provided in the original text)
Intended UseRelief of pain associated with sore/aching muscles (lower back, upper & lower extremities); Stimulation of healthy muscles to improve performance.Matches the stated intended uses of the predicate devices.
SafetyNo new safety issues compared to predicates; demonstrated safe for OTC use; compliance with electrical safety standards.No adverse events reported with over 300,000 units sold globally since 2002; compliance with AAMI NS-4, EN 60601-1, EN 60601-1-2.
EffectivenessEffectiveness for stated indications, generally supported by peer-reviewed literature on electrical stimulation.Effectiveness supported by peer-reviewed articles demonstrating electrical stimulation improves muscle performance and reduces pain.
Technological CharacteristicsSubstantially equivalent features, specifications, materials."Technological characteristics, features, specifications, materials and intended uses of the T1040 are substantially equivalent to the quoted predicate devices."
Regulatory ComplianceCompliance with applicable voluntary standards and FDA guidance for software.AAMI NS-4 1985, EN 60601-1, EN 60601-1-2, ISO 9001;2000, ISO 13485;2003; FDA Guidance for Software Contained in Medical Devices.

Table 14 - Comparison Table (from the original text, showing reported device performance and predicate performance for comparison)

QuantityT1040Bio-StimCompex5000Z
Max. Voltage over 10kΩ, V154.1132126.8/103.3226
Max. Current over 10kΩ, mA15.413.212.7/10.322.6
Max. Voltage over 2.2kΩ, V105.190167.8/153.5218
Max. Current over 2.2kΩ, mA47.84176.3/69.899
Max. Voltage over 500Ω, V40.729.548208
Max. Current over 500Ω, mA81.45996.1416
Pulse Width, µseconds21030 - 225270100
Pulse Period, msec4.1 - 5009 – 12.512510
Max. Pulse Frequency, Hz245110118120
Max. Charge per Phase over 500Ω,μC16.97.632.33.4
Max. Current Density over 500Ω,mA/cm²2.713.933.8416.64
Max. Average Power Density over500Ω, mW/cm²5.351.110.2

Study Details for T1040

The submission for T1040 primarily relies on demonstrating substantial equivalence to predicate devices through technical comparisons and a post-market safety record, rather than a specific clinical study with a defined test set, ground truth, or expert review for the T1040 itself.

  1. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective):

    • Test Set Sample Size: Not applicable in the traditional sense of a clinical trial's "test set" for performance evaluation. The submission refers to a post-market safety record as evidence of safety and effectiveness.
    • Data Provenance: The device has been sold in 20 countries since 2002. This is retrospective, real-world usage data.
  2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    • Not applicable. No "ground truth" was established by experts for a specific test set. The safety claim is based on the absence of reported adverse events from general public use over an extended period.
  3. Adjudication method (e.g. 2+1, 3+1, none) for the test set:

    • Not applicable. No formal adjudication of a test set occurred. The safety claim is based on passive surveillance (absence of adverse event reports).
  4. 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. This type of study (MRMC, AI-assisted) is not relevant to this device submission, which is for a Transcutaneous Electrical Nerve Stimulator (TENS) and Powered Muscle Stimulator (PMS) that does not involve "readers" or "AI assistance" in its operation or interpretation.
  5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

    • Not applicable. This device is not an algorithm, but a physical electrical stimulation device. Its performance is inherent in its electrical output and user interaction.
  6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

    • The primary "ground truth" for safety and effectiveness is implicit:
      • Safety: The absence of reported adverse events from over 300,000 units sold over 5 years. This acts as a real-world outcome indicator for safety.
      • Effectiveness: Reference to "a number of articles in peer-reviewed publications" demonstrating the general effectiveness of electrical stimulation for muscle performance and pain reduction. This is a scientific literature-based "ground truth" for the underlying technology, not the specific device.
  7. The sample size for the training set:

    • Not applicable. This device does not use machine learning or AI models that require a "training set."
  8. How the ground truth for the training set was established:

    • Not applicable. As no training set was used, no ground truth for it was established.

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510k: T1040 Endurance Therapeutics

K060846

510(k) Summary

This 510(k) summary is being submitted in accordance with 21 CFR 807.92(c)

1.0 Submitter's Name and Address:

Endurance Therapeutics 122B First Street, NE Dauphin, Manitoba Canada R7N 1B5

Contact Name: Brad Brezden 122B First Street, NE Dauphin, Manitoba Ph. / Fax 1-877-274-4962

DEC 0 3 2007

Date Prepared: August 27, 2007

2.0 Name of Device and Classifications

Trade/Device Name: T1040: Common Name: TENS Regulation Number: 21 CFR 882.5890 Transcutaneous Electrical Nerve Stimulator for Pain Relief Classification Name: Stimulator, Nerve, Transcutaneous, Over-the-Counter. Requlatory Class: Class II Product Code NUH, NGX, GZJ

3.0 Predicate Devices

K011880 Compex Sport K033122 Prizm Medical inc. K050174 Bio Stim Kit,

Sport Muscle Stimulator 5000Z OTC TENS Back Pain Relief System 21CFR890.5850 OTC 21CFR882,5890 OTC 21CFR882.5890 OTC

4.0 Device Description:

The T1040 is a portable; battery powered (4.5 VDC) multi function device offering both Transcutaneous Electrical Nerve Stimulator (TENS) and Powered Muscle Stimulator (PMS) qualities in one device.

Independent channel (two pads) that effectively transfers your desired choice of preprogrammed electrical pulses directly through electrode adhesive pads to the suggested area of the body where the electrodes are placed, causing minimal muscle contractions. A garment belt is used to hold the electrode pads to treat the lower back muscles. There are 10 modes of operation, 6 manual and 4 automatic.

{1}------------------------------------------------

QuantityT1040Bio-StimCompex5000Z
Max. Voltage over 10kΩ, V154.1132126.8/103.3226
Max. Current over 10kΩ, mA15.413.212.7/10.322.6
Max. Voltage over 2.2kΩ, V105.190167.8/153.5218
Max. Current over 2.2kΩ, mA47.84176.3/69.899
Max. Voltage over 500Ω, V40.729.548208
Max. Current over 500Ω, mA81.45996.1416
Pulse Width, µseconds21030 - 225270100
Pulse Period, msec4.1 - 5009 – 12.512510
Max. Pulse Frequency, Hz245110118120
Max. Charge per Phase over 500Ω,μC16.97.632.33.4
Max. Current Density over 500Ω,mA/cm²2.713.933.8416.64
Max. Average Power Density over500Ω, mW/cm²5.351.110.2

Table 14 - Comparison Table

Electrical Parameter Comparisons

Intended Use:

5.0

To be used for temporary relief of pain associated with sore and aching muscles in the lower back due to strain from exercise or normal household work activities choose Manual modes 1, 2, 3, 4, 5, 6 or Auto 4

To be used for temporary relief of pain associated with sore and aching muscles in the upper extremities (arm) due to strain from exercise or normal household work activities choose Manual modes 1, 2, 3, 4, 5, 6 or Auto 1 or Auto 3

To be used for temporary relief of pain associated with sore and aching muscles in the lower extremities (leg) due to strain from exercise or normal household work activities choose Manual modes 1, 2, 6 or Auto1 or Auto 4

ls intended to be used to stimulate healthy muscles in order to improve and facilitate muscle performance choose Manual Mode 1 or Auto Mode 2

6.0 Substantial Equivalence:

The electrical stimulation provided by the T1040 is substantially equivalent to that commonly employed by muscle stimulators and TENS devices that have been cleared for marketing without prescription labeling; i.e., for OTC sale. The pulses in the waveform combinations are restricted in amplitude and duration to values consistent with other devices quoted above.(see Appendix 4)

Technological characteristics, features, specifications, materials and intended uses of the T1040 are substantially equivalent to the quoted predicate devices.

The differences that exist between the devices are insignificant in the terms of safety or effectiveness.

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The T1040 has modes that offer substantially equivalent technical specifications, features and effective results as each of the predicates listed.

7.0 Non-Clinical Tests Performed:

Compliance to applicable voluntary standards includes AAMI NS-4 1985, as well as EN 60601-1, EN 60601-1-2, ISO 9001;2000 and ISO 13485;2003

In addition to the compliance of voluntary standards, the software verification has been carried out according to the FDA Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices.

8.0 Conclusion:

The electrical stimulation provided by the T1040 is similar to that commonly employed by muscle stimulators and TENS devices that have been cleared for marketing without prescription labeling.

The T1040 has the same intended uses and the similar technological characteristics as these OTC cleared predicates. Moreover, verification and validation tests contained in this submission demonstrate that the differences in the T1040 still maintain the same safety and effectiveness as that of the cleared devices.

In other words, those engineering differences do not: (1) affect the intended use or (2) alter the fundamental scientific technology of the device.

Concerns of safe and proper use of electrodes and electrode pad placements have been fully addressed by making the user conscious of the proper placement of electrodes and proper operations of the device through detail in the User's Instruction Manual.

We believe that there are no new safety or effectiveness issues concerning this device to be introduced.

The safety of the device, to be used for the proposed indications without medical prescription or supervision, is established by the fact that no adverse events have been reported since 2002 with over 300,000 units sold with out a prescription in 20 countries.

Over 300 000 units sold with no adverse effects reported, proves its specific technical, safety measures and features are safe and effective when used without medical supervision. An even greater and more detailed user instruction manual regarding safe operation and adhesive pad placements is proposed for the USA marketplace and consumers.

The effectiveness of the device for the proposed indications is supported by a number of articles in peer-reviewed publications, which demonstrate that electrical stimulation does improve muscle performance as well as temporary pain reduction.

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Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized caduceus symbol, which is often associated with healthcare. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular pattern around the caduceus.

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

DEC 0 3 2007

Endurance Therapeutics % Mr. Brad Brezden CEO 122 B - First Street, NE Dauphin, Manitoba, Canada R7N IBS

Re: K060846 Trade/Device Name: T1040 Regulation Number: 21 CFR 882.5890 Regulation Name: Transcutaneous electrical nerve stimulator for pain relief Regulatory Class: II Product Code: NUH, NGX Dated: August 27, 2007 Received: September 4, 2007

Dear Mr. Brezden:

We have reviewed your Section 510(k) premarket notification of intent to market the device we nave roviewed your becamed the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate for use bland in the encreations of the enactment date of the Medical Device Amendments, or to conimer of pror to may 2011-07-12) 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 r ou may, dierelove, mains 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 If your device 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 r tease of acrised and itermination that your device complies with other requirements of the Act that I Drivias Intact and regulations administered by other Federal agencies. You must or uny I 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 CI It rat 8077, accems (21 (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.

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Page 2 - Mr. Brad Brezden

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.

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 Center for Devices and Radiological Health's (CDRH's) Office of Compliance at (240) 276-0120. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding postmarket surveillance, please contact CDRH's Office of Surveillance and Biometric's (OSB's) Division of Postmarket Surveillance at (240) 276-3474. For questions regarding the reporting of device adverse events (Medical Device Reporting (MDR)), please contact the Division of Surveillance Systems at (240) 276-3464. 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 (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely yours,

Mark M. Millman

Mark N. Melkerson Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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13.0 Statement of Indication for Use

510(k) Number (if known): K060846

Device Name: T1040

Indications for Use:

To be used for temporary relief of pain associated with sore and aching muscles in the lower back due to strain from exercise or normal household work activities choose Manual modes 1, 2, 3, 4, 5, 6 or Auto 4

To be used for temporary relief of pain associated with sore and aching muscles in the upper extremities (arm) due to strain from exercise or normal household work activities choose Manual modes 1, 2, 3, 4, 5, 6 or Auto 1 or Auto 3

To be used for temporary relief of pain associated with sore and aching muscles in the lower extremities (leg) due to strain from exercise or normal household work activities choose Manual modes 1, 2, 6 or Auto1 or Auto 4

Used to stimulate healthy muscles in order to improve and facilitate muscle performance choose Manual Mode 1 or Auto Mode 2

Prescription Use (Part 21 CFR 801 Subpart D)

Over-The-Counter 1150 AND/OR (21 CFR 801 Subpart C

XX

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

Concurrence

Division of General. Restorative. and Neurological Devices

  1. Number Kolo yu

§ 882.5890 Transcutaneous electrical nerve stimulator for pain relief.

(a)
Identification. A transcutaneous electrical nerve stimulator for pain relief is a device used to apply an electrical current to electrodes on a patient's skin to treat pain.(b)
Classification. Class II (performance standards).