(129 days)
The ComboCare 2000 is intended for the temporary relief of minor muscle and joint pain, promoting relaxation of muscle tissue, symptomatic relief and management of chronic intractable pain, and adjunctive relief of post-surgical or post-traumatic acute pain.
The ComboCare 2000 is intended for the temporary relief of minor muscle and joint pain, promoting relaxation of muscle tissue, symptomatic relief and management of chronic intractable pain, and adjunctive relief of post-surgical or post-traumatic acute pain.
The provided 510(k) summary for the ComboCare 2000 does not describe a study that establishes acceptance criteria through clinical evidence or performance metrics like accuracy, sensitivity, or specificity. Instead, it focuses on demonstrating substantial equivalence to predicate devices through technological characteristics and conformance to voluntary design standards.
Here's an analysis based on the provided text, addressing your points:
1. Table of Acceptance Criteria and Reported Device Performance
This information is not present in the provided document. The submission is for a device based on "non-heating lamps for adjunctive use in pain therapy" and TENS technology, which typically relies on established safety and performance profiles of equivalent predicate devices rather than novel performance criteria requiring a new clinical study with specific acceptance metrics.
The document discusses "design requirements" and "conformance with voluntary design standards" instead of measurable performance acceptance criteria for diagnostic or treatment effectiveness.
2. Sample Size Used for the Test Set and Data Provenance
- Test Set Sample Size: Not applicable/Not provided. No clinical or performance test set (in terms of patient data) is mentioned.
- Data Provenance: Not applicable/Not provided. The submission explicitly states: "Xanacare did not conduct, nor rely upon, clinical tests to determine substantial equivalence." Non-clinical testing for safety and design validation was performed.
3. Number of Experts Used to Establish Ground Truth and Their Qualifications
- Number of Experts: Not applicable/Not provided. Since no clinical performance study was conducted on patient data, there was no need for experts to establish ground truth for a test set.
4. Adjudication Method
- Adjudication Method: Not applicable/Not provided. No clinical performance study on patient data, hence no adjudication method.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
- MRMC Study: No. The document explicitly states: "Xanacare did not conduct, nor rely upon, clinical tests to determine substantial equivalence." Therefore, no MRMC study, and no effect size for human readers with and without AI assistance (as this is not an AI device).
6. If a Standalone (Algorithm Only) Performance Study Was Done
- Standalone Performance Study: No. This is not an algorithm-only device. The submission relies on substantial equivalence to predicate devices based on technological characteristics and safety standards.
7. The Type of Ground Truth Used
- Type of Ground Truth: Not applicable/Not provided in the context of clinical performance. The "ground truth" for this submission revolves around demonstrating that the device's technical specifications and safety features are equivalent to legally marketed predicate devices and conform to relevant electrical safety and medical device standards.
8. The Sample Size for the Training Set
- Training Set Sample Size: Not applicable/Not provided. This is not an AI/machine learning device that would require a training set.
9. How the Ground Truth for the Training Set Was Established
- Ground Truth for Training Set: Not applicable/Not provided.
Summary of the Study that Proves the Device Meets Acceptance Criteria:
The provided 510(k) summary indicates that the ComboCare 2000's acceptance for market clearance is not based on a clinical study demonstrating specific performance criteria (like accuracy or effectiveness compared to a ground truth) directly for its intended use.
Instead, the "study" that proves the device meets the criteria for market clearance (i.e., substantial equivalence) is:
- Non-clinical testing: Performed to "validate the design against the company's specified design requirements."
- Conformance to voluntary design standards: EN 60601-1 (General safety), EN 60601-1-2 (Electromagnetic compatibility), and EN 60601-2-10 (Nerve and muscle stimulators safety).
- Risk Management Program: Application of ISO 14971 to eliminate or mitigate known health hazards.
- Comparison of Technical Characteristics: A detailed comparison table (provided in the document) demonstrates that the ComboCare 2000's electrical power source, battery type, light characteristics (IR and Red LED), vibratory massage, and E-Stim/Micro-Current TENS parameters (max output current/voltage, pulse frequency/width, waveform) are either equivalent to or within the ranges of legally marketed predicate devices.
The FDA's decision to clear the device is based on this demonstration of substantial equivalence to existing predicate devices already on the market, rather than a de novo clinical trial proving efficacy or specific performance metrics. The underlying assumption is that if the new device is technologically similar and meets the same safety standards as cleared predicate devices, it is equally safe and effective for its stated indications for use.
§ 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).