K Number
K140168
Device Name
EASYSTIM TN28_OTC
Date Cleared
2014-08-28

(217 days)

Product Code
Regulation Number
882.5890
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
EasyStim TN28 OTC is intended for the relief of pain associated with sore or aching muscles of the lower back, arms, or legs due to strain from exercise or normal household and work activities.
Device Description
EasyStim TN28 OTC is a portable, battery powered T.E.N.S. device for pain relief intended for over-the-counter use. There are totally eight (8) modes that are intended for application to the following areas: Shoulder/ Arm, Lower Back and Leg/Foot. The accessories include electrode cable and electrodes pads which are placed on the specific body part. Generally, the electrodes are connected to the device through electrode cable. The device produces either a fixed or modulated electrical signal through electrodes normally placed on a patient's skin over the area of pain. Since the device is battery powered, there is no connection to AC mains supply.
More Information

No
The description focuses on standard TENS technology with pre-set modes and does not mention any adaptive or learning capabilities.

Yes
The device is intended for the "relief of pain associated with sore or aching muscles," which is a therapeutic purpose. It also falls under the category of T.E.N.S. devices, which are commonly used for pain therapy.

No
Explanation: The device is intended for pain relief and described as a T.E.N.S. device, which are therapeutic devices, not diagnostic devices. Its intended use focuses on symptom relief rather than the identification or measurement of a condition.

No

The device description explicitly states it is a "portable, battery powered T.E.N.S. device" and mentions accessories like "electrode cable and electrodes pads," indicating it includes hardware components beyond just software.

Based on the provided information, the EasyStim TN28 OTC device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In vitro diagnostics are tests performed on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections.
  • Device Function: The EasyStim TN28 OTC is a T.E.N.S. (Transcutaneous Electrical Nerve Stimulation) device. It applies electrical signals to the skin to relieve pain. This is a physical therapy method, not a diagnostic test performed on a biological sample.
  • Intended Use: The intended use is for pain relief, not for diagnosing any condition.
  • Device Description: The description clearly outlines the device's function as applying electrical signals through electrodes placed on the skin. There is no mention of analyzing biological samples.

Therefore, the EasyStim TN28 OTC falls under the category of a therapeutic device, not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

EasyStim TN28 OTC is intended for the relief of pain associated with sore or aching muscles of the lower back, arms, or legs due to strain from exercise or normal household and work activities.

Product codes

NUH

Device Description

EasyStim TN28 OTC is a portable, battery powered T.E.N.S. device for pain relief intended for over-the-counter use.

There are totally eight (8) modes that are intended for application to the following areas: Shoulder/ Arm, Lower Back and Leg/Foot.

The accessories include electrode cable and electrodes pads which are placed on the specific body part. Generally, the electrodes are connected to the device through electrode cable. The device produces either a fixed or modulated electrical signal through electrodes normally placed on a patient's skin over the area of pain.

Since the device is battery powered, there is no connection to AC mains supply.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

lower back, arms, or legs (Shoulder/ Arm, Lower Back and Leg/Foot)

Indicated Patient Age Range

Adult

Intended User / Care Setting

Environment of Use: Clinics, hospital and home environments

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 (study type, sample size, AUC, MRMC, standalone performance, key results)

PERFORMANCE TESTS:
AAMI/ANSI ES60601-1:2005/(R)2012 And A1:2012,, C1:2009/(R)2012 And A2:2010/(R)2012 (Consolidated Text) Medical Electrical Equipment - Part 1: General Requirements For Basic Safety And Essential Performance (IEC 60601-1:2005, Mod). (General I (QS/RM))

IEC 60601-1-2 Medical Electrical Equipment-Part 1-2: General Requirements for Safety-Collateral Standard: Electromagnetic Compatibility- Requirements and Tests(Ed.3) (General)

IEC 60601-1-11 (Edition1.0 2010-04), Medical Electrical Equipment - Part 1-11: General Requirements For Basic Safety And Essential Performance - Collateral Standard: Requirements For Medical Electrical Equipment And Medical Electrical Systems Used In The Home Healthcare Environment [Including: Technical Corrigendum 1(2011)]. (General I (QS/RM))

IEC 60601-1-6 Medical Electrical Equipment-Part 1-6: General Requirements for Basic Safety and Essential Performance- Collateral Standard: Usability: 2010

IEC 62304 ED.1.0, Medical devices software life cycle processes (Software/ Informatics)

ISO 14971: Medical devices-Application of risk management to medical devices. (General)

IEC 60601-2-10 Edition 2.0 2012-06, Medical Electrical Equipment -- Part 2-10: Particular Requirements For The Basic Safety And Essential Performance Of Nerve And Muscle Stimulators. (Neurology)

USABILITY STUDY:
A usability study was conducted and showed that users were able to use the device correctly and safety.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s)

K110068, K040253

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 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).

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Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of the department's name encircling a stylized emblem. The emblem features three human profiles facing right, layered to create a sense of depth and unity. The profiles are rendered in a simple, elegant style.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

August 28, 2014

Easymed Instruments Co., Ltd Mr. Jeffery Wu (Wu Tingjie) General Manager 5/F - 6/F, Block A, Gupo Gongmao Building, Fengxin Road, Fengxiang Industrial District, Daliang, 528300 Shunde, Foshan, Guangdong, CHINA

Re: K140168

Trade/Device Name: EasyStim TN28 OTC Regulation Number: 21 CFR 882.5890 Regulation Name: Stimulator, Nerve, Transcutaneous, Over-The-Counter Regulatory Class: Class II Product Code: NUH Dated: May 22, 2014 Received: June 02, 2014

Dear Mr. Tingjie Wu:

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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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 Industry and Consumer Education at its toll-free 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 Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours,

Felipe Aguel -S

for

Carlos L. Peña, PhD, MS 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) K140168

Device Name EasyStim TN28 OTC

Indications for Use (Describe)

EasyStim TN28 OTC is intended for the relief of pain associated with sore or aching muscles of the lower back, arms, or legs due to strain from exercise or normal household and work activities.

Type of Use (Select one or both, as applicable)

_ Prescription Use (Part 21 CFR 801 Subpart D)

Over-The-Counter Use (21 CFR 801 Subpart C)

PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON A SEPARATE PAGE IF NEEDED.

FOR FDA USE ONLY

Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)

Date: 2014.08.28 17:19:10 -04'00'

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

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Image /page/3/Picture/0 description: The image shows the logo for Easymed. The logo is in blue and has a registered trademark symbol. Below the logo is the text "Easy for the relief of your suffering".

510(k) Summary

Date of submission prepared: 5th December 2013

Submitter:EasyMed Instruments Co., Ltd.
Address:5/F – 6/F, Block A, Gupo Gongmao Building, Fengxin Road,
Fengxiang Industrial District, Daliang, 528300 Shunde, Foshan,
Guangdong, CHINA
Tel :+86 757 2809 1300
Fax :+86 757 2772 7868
E-Mail :jeffery@easymed.com.cn
  • Official Contact: Jeffery Wu (Wu Tingjie)
    Address of the manufacturing facility: The same as above

SUBMITTED DEVICE:

Generic Name:Transcutaneous Electrical Nerve Stimulator (T.E.N.S.)
Proprietary or Trade Name:EasyStim TN28_OTC
Common/Usual Name:Stimulator, nerve, transcutaneous, over-the-counter
Classification Name:Stimulator, nerve, transcutaneous, over-the-counter
21 CFR 882.5890
Product Code:NUH
Device Panel:Neurology
Device Classification:Class II

PREDICATE DEVICES:

Device Name:Model PM3030
Manufacturer:Omron Healthcare, Inc.
510(k) Number:K110068
Product Code:NUH

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Image /page/4/Picture/0 description: The image features the word "Easymed" in a large, blue, sans-serif font. A thin black line is located directly underneath the word. Below the line, the phrase "Easy for the relief of your suffering" is written in a smaller, blue font.

Device Name: EasyMed TN-28C T.E.N.S. Unit EasyMed Instrument Co., Ltd Manufacturer: 510(k) Number: K040253 GZJ Product Code:

INDICATIONS FOR USE:

This device is intended for the relief of pain associated with sore or aching muscles of the lower back, arms, or legs due to strain from exercise or normal household and work activities.

DEVICE DESCRIPTION:

EasyStim TN28 OTC is a portable, battery powered T.E.N.S. device for pain relief intended for over-the-counter use.

There are totally eight (8) modes that are intended for application to the following areas: Shoulder/ Arm, Lower Back and Leg/Foot.

The accessories include electrode cable and electrodes pads which are placed on the specific body part. Generally, the electrodes are connected to the device through electrode cable. The device produces either a fixed or modulated electrical signal through electrodes normally placed on a patient's skin over the area of pain.

Since the device is battery powered, there is no connection to AC mains supply.

ENVIRONMENT OF USE: Clinics, hospital and home environments

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Image /page/5/Picture/0 description: The image shows the brand name "Easymed" in a large, bold, blue font. A thin black line is placed directly underneath the brand name. Below the line, the text "Easy for the relief of your suffering" is written in a smaller, blue font.

SUMMARY OF SUBSTANTIAL EQUIVALENCE

AttributeNew DevicePredicate Device (1)Predicate Device (2)
Product NameEasyStim TN28_OTCModel PM3030EasyMed TN-28C
T.E.N.S. Unit
510(K) number(to be assigned)K110068K040253
Product CodeNUHNUHGZJ
Regulation No.21 CFR 882.589021 CFR 882.589021 CFR 882.5890
Indications for UseThis device is intended
for the relief of pain
associated with sore or
aching muscles of the
lower back, arms, or legs
due to strain from
exercise or normal
household and work
activities.This device is
intended for the relief
of pain associated
with sore or aching
muscles of the lower
back, arms, or legs
due to strain from
exercise or normal
household and work
activities.This T.E.N.S. system is
used to provide
symptomatic pain relief
for chronic, acute or post
operative pain.
Patient PopulationAdultAdultNot specified
Prescriptive or OTCOTCOTCPrescription
Environment of useClinics, hospital and
home environmentsClinics, hospital and
home environmentsNot specified
Number of output
modes835
Number of output
channels212
WaveformBiphasic rectangular
Monophasic rectangularBiphasic rectangular
Monophasic
rectangularSymmetrical Bi-phasic
rectangular
Asymmetrical Bi-phasic
rectangular
Monophasic rectangular
Maximum Output
Voltage(max)
500 ohm
2k ohm
10k ohm68V
102V
110V35.6V
46.4V
50.4V74.4V
109V
116V
Maximum Output
Current(max)
500 ohm
2k ohm133mA
51mA
11mA69.8mA
23.2mA145mA
54.5mA
11.6mA
10k ohm5.04mA
Maximum Phase charge (500 ohm)20.02μC7.12μC21.62μC
Maximum Average Current (500 ohm)3.0375mA0.528mA3.243mA
Maximum Current Density (500 ohm)0.188mA/cm²0.0084mA/cm²0.20mA/cm²
Maximum Average Power Density (500 ohm)7.52mW/ cm²0.202mW/cm²8.764mW/cm²
Frequency (Hz)From 1Hz to 150HzFrom 1Hz to 110 HzFrom 1Hz to 150Hz
Pulse Duration (μs)50-250μs, in steps of 50μs1-100μs50-250μs, in steps of 50μs
Burst ModeYesNoneYes
Timer range(min)20min, 25min, 30min, 40min depending on preset program15 minutes for all programsContinuous, 15min, 30min, 45min, 60min, 90min selectable
Indication display
-On/Off statusYesYesYes
-Low batteryYesNoYes
-Voltage/Current levelYesYesYes
-Output modeYesYesYes
-Time to cut-offYesNoYes
Power Source2 Alkaline AA 1.5V (LR6) Batteries2 AAA Batteries2 Alkaline AA 1.5V (LR6) Batteries
Dimensions (mm)66×136×30.755 x95 x 1966×136×30.7
Weight146.5 grams60 grams146.5 grams
Housing materialABSABSABS
Microprocessor controlYesYesYes
Automatic Overload tripYesYesYes
Automatic no-load tripYesYesYes
Automatic shut-offYesYesYes
User override controlYesPower On/Off buttonYes
Electrode compliance with 21 CFR 898YesYesYes
Electrode cableYesYesYes

Add: 5/F-6/F, Gupo Gongmao Building, Fengxin Road, Fengxiang Industrial District, Da Liang, 528300 ShunDe, GuangDong, China 86-757-28091300

б

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EasyMed Instruments Co., Ltd

Easy for the relief of your suffering

Add: 5/F-6/F, Gupo Gongmao Building, Fengxin Road, Fengxiang Industrial District, Da Liang, 528300 ShunDe, GuangDong, China Tel: 86-757-28091300 Fax: 86-757-27727868

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Image /page/7/Picture/0 description: The image shows the word "Easymed" in blue font with a black line underneath. The word is written in a sans-serif font, and the "y" extends below the line. There is a registered trademark symbol in the upper right corner of the image.

Easy for the relief of vour sufferin

DIFFERENCES BETWEEN NEW DEVICE AND PREDICATE DEVICES

The technical characteristics of EasyStim TN28 OTC are similar to those of the predicate devices in design, energy source, intended use and function. Like the predicate device Model PM3030 (K110068) and EasyMed TN-28C T.E.N.S. Unit (K040253), the EasyStim TN28 OTC is a device used to apply an electrical current to electrodes on a patient's skin to relieve pain.

The stimulation parameters of new device EasyStim TN28_OTC are all in the same range of those of predicate device TN-28C(K040253) and similar to those of Model PM3030 (K110068). Furthermore, the designed circuitry of new device EasyStim TN28 OTC is very similar to the marketed device TN-28C (K040253), they are of similar circuit diagrams, similar working principle, and same plastic housing.

Some output characteristics of EasyStim TN28 OTC are different from those of Model PM3030 (K110068). However, the maximum phase charge (the charge delivered per pulse) of EasyStim TN28 OTC is 20.02µC, which is less than 25µC. On the other hand, the maximum average power density of EasyStim TN28 OTC is 0.00752W/cm², which is also less than 0.25W/cm². Furthermore, the frequency range of EasyStim TN28 OTC is from 1Hz to 150Hz, which is same as TN-28C(K040253) but different from Model PM3030 (K110068). But it needs 20 steps to reach up to the maximum output frequency (150Hz). Therefore, the differences between EasyStim TN28 OTC and Model PM3030 (K110068) are insignificant in terms of safety.

The EasyStim TN28 OTC is viewed as substantially equivalent to the predicate devices because: the electrical stimulation provided by the EasyStim TN28_OTC is substantially equivalent to that commonly employed by TENS devices that have been cleared for marketing without prescription labeling, i.e. for OTC use. The waveform combinations are restricted in amplitude and duration to values consistent with other cleared devices.

Technological characteristics, features, specifications, materials and intended uses of the EasyStim TN28 OTC are substantially equivalent to the predicate devices. The differences that exist between EasyStim TN28_OTC and predicate devices are insignificant in the terms of safety or effectiveness.

PERFORMANCE TESTS:

AAMI/ANSI ES60601-1:2005/(R)2012 And A1:2012,, C1:2009/(R)2012 And A2:2010/(R)2012 (Consolidated Text) Medical Electrical Equipment - Part 1: General Requirements For Basic Safety And Essential Performance (IEC 60601-1:2005, Mod). (General I (QS/RM))

IEC 60601-1-2 Medical Electrical Equipment-Part 1-2: General Requirements for Safety-Collateral Standard: Electromagnetic Compatibility- Requirements and Tests(Ed.3) (General)

Add: 5/F-6/F, Gupo Gongmao Building, Fengxin Road, Fengxiang Industrial District, Da Liang, 528300 ShunDe, GuangDong, China

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Image /page/8/Picture/0 description: The image shows the word "Easymed" in a blue, sans-serif font. The word is underlined with a thin, black line. There is a small, circled "R" symbol in the upper right corner of the image, indicating that the word is a registered trademark. The background of the image is white.

Easy for the relief of vour sufferir

EasyMed Instruments Co., Ltd

IEC 60601-1-11 (Edition1.0 2010-04), Medical Electrical Equipment - Part 1-11: General Requirements For Basic Safety And Essential Performance - Collateral Standard: Requirements For Medical Electrical Equipment And Medical Electrical Systems Used In The Home Healthcare Environment [Including: Technical Corrigendum 1(2011)]. (General I (QS/RM))

IEC 60601-1-6 Medical Electrical Equipment-Part 1-6: General Requirements for Basic Safety and Essential Performance- Collateral Standard: Usability: 2010

IEC 62304 ED.1.0, Medical devices software life cycle processes (Software/ Informatics)

ISO 14971: Medical devices-Application of risk management to medical devices. (General)

IEC 60601-2-10 Edition 2.0 2012-06, Medical Electrical Equipment -- Part 2-10: Particular Requirements For The Basic Safety And Essential Performance Of Nerve And Muscle Stimulators. (Neurology)

USABILITY STUDY:

A usability study was conducted and showed that users were able to use the device correctly and safety.

CONCLUSION:

The new device EasyStim TN28 OTC has the same indications for use and similar technological characteristics as the predicate devices Model PM3030 (K110068) and TN-28C (K040253). The stimulation parameters of new device EasyStim TN28 OTC are all in the same range of those of predicate devices. Thus, the new device EasyStim TN28 OTC is substantially equivalent to the predicate devices and any differences between the devices do not pose any new questions of safety and effectiveness.

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