(270 days)
To be used in adults only for temporary relief of pain associated with sore and aching muscles in the upper extremities (arms), lower extremities (legs), and lower back due to strain from exercise or normal household and work activities.
TANYX® is based on TENS medical technology. The product is to reduce or eliminate pain through the emission of controlled and focused electrical signals. It is a disposable device, designed to be sold directly to consumers for the temporary relief of pain. TANYX® adheres to a person's skin and emits either a fixed or modulated electrical signal through a grid of integrated electrodes. It is a product which is characterized as portable, inexpensive, disposable, and (compared to other TENS-based products) easy to handle and operate. No medical supervision is required.
Here's an analysis of the provided 510(k) summary for the Tanyx device, focusing on acceptance criteria and the study proving it meets those criteria, based only on the provided text:
Important Note: The provided document is a 510(k) summary for a Transcutaneous Electrical Nerve Stimulator (TENS) device. These submissions typically focus on demonstrating substantial equivalence to a predicate device, rather than proving novel clinical efficacy against specific, quantitative acceptance criteria through a full clinical trial. The "study" mentioned here is primarily non-clinical testing for safety parameters and a usability study. There is no information about a clinical trial or performance metrics like accuracy, sensitivity, or specificity that would typically be found in an AI/Software as a Medical Device (SaMD) submission.
Acceptance Criteria and Device Performance for Tanyx®
1. Table of Acceptance Criteria (Safety Parameters) and Reported Device Performance
The acceptance criteria are generally understood to be compliance with established safety standards for TENS devices, as demonstrated by comparison to a legally marketed predicate device and adherence to relevant ISO and IEC standards. The "performance" here refers to the device's electrical characteristics and its ability to pass specific safety tests.
| Characteristic | Acceptance Criteria (Predicate / Industry Standard) | Tanyx® Reported Performance |
|---|---|---|
| Non-Clinical Performance | ||
| Biocompatibility (ISO 10993-1) | Passed | Passed |
| Biocompatibility (ISO 10993-5:2009) | Not specified (for predicate) | Passed |
| Biocompatibility (ISO 10993-10:2010) | Not specified (for predicate) | Passed |
| Device Safety (IEC 60601-1) | Passed | Passed |
| Device Safety (IEC 60601-2-10) | Passed | Passed |
| Hazard Analysis (ISO 14971:2007) | Not specified (for predicate) | Passed |
| Electrical Parameters (Safety & Efficacy Range) | In range for indicated use, under established limits | In range for indicated use, under established limits |
| Maximum Output Voltage (500 ohm) | 35.4 V (Predicate) | 47.6 Vpp |
| Maximum Output Voltage (2k ohm) | 46.7 V (Predicate) | 64.0 Vpp |
| Maximum Output Voltage (10k ohm) | 50.8 V (Predicate) | 72.8 Vpp |
| Frequency (Hz) | 0-100 Hz (Predicate) | 55 Hz (± 3%) |
| Maximum Output Current (500 ohm) | 4.4 mA (Predicate) | 95.2 mApp |
| Maximum Output Current (2k ohm) | 1.7 mA (Predicate) | 29.1 mApp |
| Maximum Output Current (10k ohm) | 0.4 mA (Predicate) | 7.9 mApp |
| Maximum Average Current | 3.5mA (Predicate) ; under established limits | 6.02mA |
| Maximum Current Density | 0.095mA/Cm² (Predicate) ; under maximum limits | 0.12mA/Cm² |
| Maximum Average Power Density | 89mW/Cm² (Predicate) ; under maximum limits | 98mW/Cm² |
| Maximum Phase Charge (500 ohm) | 1.33 µC (Predicate) ; under established limits | 0.19 µC |
| Usability | Users able to use device correctly and safely | Users able to use device correctly and safely |
2. Sample Size Used for the Test Set and Data Provenance
- Non-Clinical Performance Data (Safety Standards Compliance): The sample size refers to the number of devices or components tested to ISO and IEC standards. This information is not explicitly stated in the provided text. It's typically part of detailed test reports referenced by the submission but not included in summary. The provenance is likely lab testing conducted by the manufacturer or a certified testing facility.
- Usability Study: The sample size for the usability study is not explicitly stated. The provenance is a "usability study was conducted," implying it was conducted by or for Medecell.
- Electrical Parameters: These are measurements of the device's electrical output. The sample size is not stated, but typically involves testing multiple units to ensure consistency. The data provenance is from a company named "No Risk" from Brazil, resulting in the report R120331 - Medecell - Stimulator - Tanyx - parameters - 12042710.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
This type of information (experts, ground truth for a test set) is generally applicable to AI/SaMD devices where expert annotation or pathology defines the "truth" for evaluating algorithmic performance. For this TENS device, the "ground truth" for non-clinical testing is adherence to established engineering, electrical, and safety standards (e.g., ISO, IEC). The experts would be the engineers and technicians involved in performing and verifying these tests, but their specific number and qualifications are not mentioned in the summary. For the usability study, there's no mention of experts establishing ground truth; the ground truth is simply whether users could operate the device correctly and safely.
4. Adjudication Method for the Test Set
Again, this is highly relevant for AI/SaMD. For the non-clinical tests described, adjudication methods typically refer to peer review of test plans, results, and adherence to standard protocols within the testing facility. This information is not provided in the summary. For the usability study, no adjudication method is described beyond the conclusion that "users were able to use the device correctly and safely."
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done, and the effect size of how much human readers improve with AI vs without AI assistance
No. An MRMC study is not mentioned. This type of study assesses how human interpretation (e.g., of images) changes with or without AI assistance, which is not applicable to a TENS device. The Tanyx device itself is the therapy, not an aid to interpretation.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done
No. This question is also highly relevant for AI/SaMD. Tanyx is a hardware device (TENS) that delivers electrical stimulation for pain relief; it does not have a standalone algorithm in the sense of a diagnostic or interpretive AI. Its "performance" is its electrical output and safe operation.
7. The Type of Ground Truth Used
- Non-Clinical Performance (Safety): The ground truth for electrical parameters and safety tests (biocompatibility, electrical safety, hazard analysis) is defined by compliance with internationally recognized standards (ISO 10993, IEC 60601, ISO 14971) and comparison to the electrical output ranges of a legally marketed predicate device (Model PM3030).
- Usability: The ground truth for the usability study is whether users could operate the device as intended and safely, as observed during the study.
8. The Sample Size for the Training Set
This question is applicable to machine learning algorithms. Since Tanyx is a TENS device and not an AI/ML algorithm, there is no training set in this context. The device's 'design' is based on established TENS medical technology and engineering principles, not on learning from a data set.
9. How the Ground Truth for the Training Set Was Established
As there is no training set for this type of device, this question is not applicable.
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K23866
510(k) Summary
Date of Submission: November 28, 2012
Submitter: Medecell US, Inc. 4901 Boulder Lane Hoffman Estates, IL 60010-5842 +1-847-323-5599 Phone: Robert Da Rocha, International Director Contact Person:
Subject Device:
Tanyx® Proprietary Name: Stimulator, Nerve, Transcutaneous, Over-The-Counter Classification Name: Regulation: 882.5899 Product Code: nuh
SEP 1.3 2013
Predicate Devices:
| Name of device | Model PM3030 |
|---|---|
| Manufacturer: | Omron Health Care |
| K number: | K110068 |
| Product Code: | NUH |
Device Description:
TANYX® is based on TENS medical technology. The product is to reduce or eliminate pain through the emission of controlled and focused electrical signals. It is a disposable device, designed to be sold directly to consumers for the temporary relief of pain. TANYX® adheres to a person's skin and emits either a fixed or modulated electrical signal through a grid of integrated electrodes. It is a product which is characterized as portable, inexpensive, disposable, and (compared to other TENS-based products) easy to handle and operate. No medical supervision is required.
Intended Uses:
"To be used in adults only for temporary relief of pain associated with sore and aching muscles in the upper extremities (arms), lower extremities (legs), and lower back due to strain from exercise or normal household and work activities."
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Summary of Technological Characteristics:
| Model PM3030 | TANYX® | |
|---|---|---|
| Manufacturer: Omron Healthcare, Inc. | Manufacturer: Medecell do Brasil | |
| K110068 | ||
| Indications for Use | This device is intended for the relief of painassociated with sore or aching muscles of thelower back, arms, or legs due to strain fromexercise or normal household and workactivities. | To be used for temporary relief of painassociated with sore and aching muscles in theupper extremities (arms), lower extremities(legs), and lower back due to strain from exerciseor normal household and work activities. |
| Patient Population | Adults | Adults |
| Prescriptive or OTC | OTC | OTC |
| Environment Of use | Clinics, hospital and home environments | Clinics, hospital and home environments |
| Number Of Output modes | 3 | 6 |
| Number of output channels | 1 | 1 |
| Waveform | Biphasic | Monophasic |
| Shape | Rectangular | Rectangular |
| Maximum Output Voltage(max) | ||
| 500 ohm | 35.4 V | 47.6 Vpp |
| 2k ohm | 46.7 V | 64.0 Vpp |
| 10k ohm | 50.8 V | 72.8 Vpp |
| Frequency (Hz) | 0-100 Hz | 55 Hz |
| Maximum Output Current(max) | ||
| 500 ohm | 4.4 mA | 95.2 mApp |
| 2k ohm | 1.7 mA | 29.1 mApp |
| 10k ohmn | 0.4 mA | 7.9 mApp |
| Maximum Average Current | 3.5mA | 6.02mA |
| Maximum Current Density | 0.095mA/Cm² | 0.12mA/Cm² |
| Maximum Average PowerDensity | 89mW/Cm² | 98mW/Cm² |
| Maximum Phase charge (500ohm) | 1.33 µC | 0.19 µC |
| Burst Mode | none | yes |
| Timer range (min) | 15 minutes | No |
| Dimensions | 55 mm x 95 mm x 19mm | 153mm x 51mm x 8.2mm |
| Weight | 60 grams | 30 grams |
| Material | Acrylonitrile Butadiene Styrene (ABS) | Acrylonitrile Butadiene Styrene (ABS) andPolypropylene (PP) |
| Microprocessor control | Yes | yes |
| Automatic Overload trip | Yes | No |
| Automatic no-load trip | Yes | Yes |
| Automatic shut-off | Yes | No |
| User control | Power On/Off button | Power On/Off and Intensity buttons |
| Electrode cable | Yes | No |
. .
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Differences between Tanyx and Predicate Device
Tanyx is viewed as substantially equivalent to the predicate device because the stimulation parameters are all in the same range for the intended use. The device includes a wide variation in terms of Current, Voltage Amplitude and Waveform, the basic parameters, without sacrificing biological effects. Maximum Output Current differences between Tanyx and the predicate device are due to different measurement methods. Tanyx was measured using a peak-to-peak value and predicate device uses RMS value, but both devices are in the same range of safety and efficacy. Other measurement differences are not significant from the predicated device. Operation and mechanical design don't show significant differences.
Non-Clinical Performance Data:
| Characteristic | Predicate | Subject |
|---|---|---|
| Biocompatibility | ||
| ISO 10993-1 | Passed | Passed |
| ISO 10993-5:2009 | Not specified | Passed |
| ISO 10993-10:2010 | Not specified | Passed |
| Device Safety | ||
| IEC 60601-1 | Passed | Passed |
| IEC 60601-2-10 | Passed | Passed |
| Hazard Analysis | ||
| ISO 14971:2007 | Not Specified | Passed |
Risk Analysis Method:
The hazard analysis for the device was conducted according to EN ISO 14971:2007. The device was found to adequately minimize the risks for shock and burn as identified by FDA.
Usability Study:
A usability study was conducted and showed that users were able to use the device correctly and safely.
Conclusion:
Tanyx® is substantially equivalent to a legally marketed device. Although it has some technological characteristics that differ from that of predicate, TENS current state of art support that stimulation parameters of both devices are in the same range for the intended biological effects and practical use and raises no new questions of safety and effectiveness.
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Summary of substantial equivalence
.
| Model PM3030 | TANYX® | |
|---|---|---|
| Manufacturer: Omron Healthcare, Inc. | Manufacturer: Medecell do Brasil | |
| K110068 | ||
| Indications for Use | This device is intended for the relief ofpain associated with sore or achingmuscles of the lower back, arms, orlegs due to strain from exercise ornormal household and work activities. | To be used for temporary relief of painassociated with sore and aching musclesin the upper extremities (arms), lowerextremities (legs), and lower back due tostrain from exercise or normal householdand work activities. |
| Patient Population | Adults | Adults |
| Prescriptive or OTC | OTC | OTC |
| Environment Of use | Clinics, hospital and homeenvironments | Clinics, hospital and home environments |
| Number Of Output modes | 3 | 6 |
| Number of output channels | 1 | 1 |
| Waveform | Biphasic | Monophasic |
| Shape | Rectangular | Rectangular |
| Maximum Output Voltage(max) | ||
| 500 ohm | 35.4 V | 47.6 Vpp |
| 2k ohm | 46.7 V | 64.0 Vpp |
| 10k ohm | 50.8 V | 72.8 Vpp |
| Frequency (Hz) | 0-100 Hz | 55 Hz |
| Maximum Output Current(max) | ||
| 500 ohm | 4.4 mA | 95.2 mApp |
| 2k ohm | 1.7 mA | 29.1 mApp |
| 10k ohmn | 0.4 mA | 7.9 mApp |
| Maximum Average Current | 3.5mA | 6.02mA |
| Maximum Current Density | 0.095mA/Cm² | 0.12mA/Cm² |
| Maximum Average PowerDensity | 89mW/Cm² | 98mW/Cm² |
| Maximum Phase charge(500 ohm) | 1.33 µC | 0.19 μC |
| Burst Mode | none | yes |
| Timer range (min) | 15 minutes | No |
| Dimensions | 55 mm x 95 mm x 19mm | 153mm x 51mm x 8.2mm |
| Weight | 60 grams | 30 grams |
| Material | Acrylonitrile Butadiene Styrene (ABS) | Acrylonitrile Butadiene Styrene (ABS) andPolypropylene (PP) |
| Microprocessor control | Yes | yes |
| Automatic Overload trip | Yes | No |
| Automatic no-load trip | Yes | Yes |
| Automatic shut-off | Yes | No |
| User control | Power On/Off button | Power On/Off and Intensity buttons |
| Electrode cable | Yes | No |
·
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Qur product Tanyx was tested by the company "No Risk" from Brazil resulting the report R120331 - Medecell - Stimulator - Tanyx - parameters - 12042710 . The numbers collected from this document demonstrate that Tanyx is in accordance to the limits established to the safety of the differences between Tanyx and the other device, we believe do not raise any new question regarding safety and effectiveness because both are under the established limits.
In reference to the MAXIMUM OUTPUT VOLTAGE, our product have numbers under established limits within industry standards and the differences between the devices do not raise any new question of safety and effectiveness.
Regarding the MAXIMUM OUTPUT CURRENT, Tanyx again have our numbers under the established limits and the differences between the devices do not raise any new question of safety and effectiveness because both products are in accordance to industry standards.
Referent to the MAXIMUM PHASE CHARGE, the number for Tanyx is over the established limit and again, the difference between the devices do not raise any question regarding safety and effectiveness because both are under limits.
Regarding the MAXIMUM CURRENT DENSITY of Tanyx, the product is under the maximum limits and because of this do not raise any new question of safety and effectiveness. The differences between the devices do not raise any new question too, because both are under the maximum limits established.
In reference to MAXIMUM AVERAGE CURRENT, Tanyx is under the established maximum limits. The differences between the products do not raise new questions of safety and effectiveness because, as Tanyx, the other device is under the maximum limits.
Regarding MAXIMLUMN AVERAGE POWER DENSITY, the product is under the maximum limits and because of this do not raise any new question of safety and effectiveness. The differences between the devices do not raise any new question too, because both are under the maximum limits established.
In reference to Frequency (Hz) Tanyx has a 55 Hz (this number may vary ± 3%) and this frequency do not raise any new question of effectiveness and safety because it is tested and the differences between the devices to not raise any question two because they are under the limits of patient safety.
Tanyx is viewed as substantially equivalent to the predicate device because the stimulation parameters are all in the same range for the intended use. The device includes a wide variation in terms of Current, Voltage Amplitude and Waveform, the basic parameters, without sacrificing biological effects. Maximum Output Current differences between Tanyx and the predicate device are due to different methods. Tanyx was measured using a peak-to-peak value and predicate device uses RMS value, but both devices are
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in the same range of safety and efficacy. Other measurement differences are not significant from the predicated device. Operation and mechanical design don´t show significant differences.
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Image /page/6/Picture/0 description: The image shows the logo for the Department of Health & Human Services USA. The logo is a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" around the perimeter. Inside the circle is an abstract symbol that resembles a stylized caduceus, a symbol often associated with medicine and healthcare. The image is in black and white.
DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
September 13, 2013
Medecell c/o Rhonda Alexander, M.S., M.P.A. Registrar Corp 144 Research Drive Hampton. VA 23666
Re: K123866
Trade/Device Name: Tanyx® Regulation Number: 21 CFR 882.5890 Regulation Name: Transcutaneous electrical nerve stimulator for pain relief Regulatory Class: Class II Product Code: NUH Dated: July 23, 2013 Received: July 24, 2013
Dear Ms. Alexander:
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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to 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); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set
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Page 2 - Ms. Rhonda Alexander
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.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Small Manufacturers, International and Consumer Assistance at its tollfree number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
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) 796-7100 or at its Internet address http://www.fdagov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely vours.
Joyce M. Whang -S
Victor Krauthamer, Ph.D. for Acting Director Division of Neurological and Physical Medicine Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Indications for Use
510(k) Number (if known): K123866
Device Name: Tanyx®
Indications For Use:
To be used in adults only for temporary relief of pain associated with sore and aching muscles in the upper extremities (arms), lower extremities (legs), and lower back due to strain from exercise or normal household and work activities.
Prescription Use (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use __ × (21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED) ·
Concurrence of Center for Devices and Radiological Health (CDRH)
Joyce M. Whang -S
§ 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).