K Number
K150043
Date Cleared
2015-08-14

(217 days)

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

The AD-2129A TENS device is intended for temporary relief of pain associated with sore and aching muscles due to strain from exercise or normal household and work activities. It is also intended for symptomatic relief and management of chronic, intractable pain and relief of pain associated with arthritis.

Device Description

The AD-2129A Transcutaneous Electrical Nerve Stimulator(TENS) is transcutaneous electrical nerve stimulator for relief of muscular pain and sold without prescription. The device consists of a microprocessor, buttons, electrical pads, and display. Keys can control the device to choose the operation modes, adjust pulse output strength, then the channel that effectively transfers your desired choice of programmed electrical pulses directly through electrode adhesive pads to the suggested area of the body where the electrodes are placed, causing minimal muscle stimulation. The LCD display can show user the mode and strength chosen and other information like date and time Self-adhesive electrodes are used in this devices, and they are intended for use as the disposable, conductive adhesive interface between the patient's skin and the Electrical Stimulator. The electrodes is for OTC use, and mainly consists of substrate and wire.

AI/ML Overview

The provided document is a 510(k) Premarket Notification for a Transcutaneous Electrical Nerve Stimulator (TENS) device, AD-2129A. It focuses on demonstrating substantial equivalence to predicate devices, rather than establishing de novo acceptance criteria and proving performance against them through a clinical study.

Therefore, the document does not report on acceptance criteria or a study designed to prove the device meets these criteria in the way one would for a novel AI/ML medical device or a device requiring clinical performance validation against specific metrics.

Instead, the document details:

  • Regulatory Substantial Equivalence: The primary goal is to show that the AD-2129A TENS device is substantially equivalent to legally marketed predicate TENS devices (Smart Relief K131159 and EasyStim TN28_OTC K140168).
  • Safety and Performance to Standards: The "Performance Summary" and "Non-clinical Testing Summary" sections confirm that the device conforms to relevant electrical safety, electromagnetic compatibility (EMC), and biocompatibility standards (e.g., IEC 60601-1, IEC 60601-2-10, IEC 60601-1-2, ISO 10993). These are general safety and performance standards for the device type, not specific outcome-based acceptance criteria for a novel technology.
  • Comparison Table: A detailed comparison table highlights similarities and differences between the subject device and the predicates regarding product name, regulatory information, intended use, physical characteristics, and electrical parameters.

To directly answer your request based on the provided document:

1. A table of acceptance criteria and the reported device performance:

The document does not present acceptance criteria in a quantitative, outcome-based manner for clinical efficacy or diagnostic accuracy, as would be expected for an AI/ML device. Instead, "acceptance criteria" are implied by adherence to recognized electrical, EMC, and biological safety standards.

Acceptance Criteria (Implied)Reported Device Performance
Compliance with IEC 60601-1 (Electrical Safety)"the device meet all the applicable requirements."
Compliance with IEC 60601-2-10 (Nerve & Muscle Stimulators Safety)"particular safety test has been performed... and the device meet all the applicable requirements."
Compliance with IEC 60601-1-2 (Electromagnetic Compatibility)"the test result show that, the device meet all the applicable requirements."
Compliance with ISO 10993-5 (In vitro cytotoxicity - Biocompatibility)"the result shows it meet the applicable requirements."
Compliance with ISO 10993-10 (Irritation & skin sensitization - Biocompatibility)"the result shows it meet the applicable requirements."
Substantial Equivalence to Predicate Devices"The new device AD-2129A TENS has the same intended use, design, technological characteristics as the predicate device K131159 and K140168."

2. Sample size used for the test set and the data provenance:

  • The document describes non-clinical bench testing (electrical safety, EMC, biocompatibility) rather than a clinical "test set" of patient data. Therefore, concepts like sample size for a test set and data provenance (country, retrospective/prospective) are not applicable in this context. The "sample" tested would be the physical device units and their components.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

  • Not applicable. Ground truth as typically understood for medical imaging or diagnostic AI (e.g., expert consensus on clinical findings) is not established here. The "ground truth" for the non-clinical tests is adherence to engineering and safety standards.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:

  • Not applicable. There is no expert adjudication process described, as clinical interpretation is not being evaluated.

5. 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 is a TENS device, not an AI-assisted diagnostic tool. No MRMC study was conducted or is relevant to this submission type.

6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

  • Not applicable. This is a physical medical device, not a software algorithm.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

  • The "ground truth" for this device's performance evaluation against standards is defined by the technical specifications and limits set by the referenced IEC and ISO standards for electrical safety, EMC, and biocompatibility.

8. The sample size for the training set:

  • Not applicable. This device does not involve machine learning or a "training set."

9. How the ground truth for the training set was established:

  • Not applicable. There is no training set for this device.

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

August 14, 2015

Andon Health Co., Ltd. Liu Yi President No. 3, Jin Ping Street, Ya An Road, Nankai District Tianjin, CN 300190

Re: K150043

Trade/Device Name: AD-2129A Transcutaneous Electrical Nerve Stimulators (TENS) Regulation Number: 21 CFR 882.5890 Regulation Name: Transcutaneous Electrical Nerve Stimulator for Pain Relief Regulatory Class: Class II Product Code: NUH, NYN Dated: July 14, 2015 Received: July 16, 2015

Dear Liu Yi:

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 devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in

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the quality systems (OS) 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" (21 CFR 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,

Michael J. Hoffmann -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) K150043

Device Name

AD-2129A Transcutaneous Electrical Nerve Stimulators (TENS)

Indications for Use (Describe)

The AD-2129A TENS device is intended for temporary relief of pain associated with sore and aching muscles due to strain from exercise or normal household and work activities. It is also intended for symptomatic relief and management of chronic, intractable pain and relief of pain associated with arthritis.

Type of Use (Select one or both, as applicable)
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Prescription Use (Part 21 CFR 801 Subpart D)

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

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510(k) Summary

This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirement of SMDA and 21 CFR 807.92.

1.0 submitter's information

Name:Andon Health Co., Ltd.
Address:No 3, Jinping Street Ya An Road, Nankai District, Tianjin,P.R. China
Phone number:86-22-6052 6161
Fax number:86-22-6052 6162
Contact:Liu Yi
Date of Application:1/7/2015

2.0 Device name

Classification Name: Stimulator, Nerve, Transcutaneous, Over-The-Counter Device name: Transcutaneous Electrical Nerve Stimulators (TENS) Model: AD-2129A

3.0 Classification

Production code: NUH, NYN Regulation number: 21 CFR 882.5890 Classification: II Panel: Neurology

4.0 Predicate device information

InformationPredicate 1Predicate 2
510(k) number:K131159K140168
ManufacturerChattem, Inc.EasyMed Instruments

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Co., Ltd.
Trade/Proprietary NameSmart ReliefEasyStim TN28_OTC
Classification NameTranscutaneous NerveStimulator.Transcutaneous NerveStimulator.
Regulation number882.589021 CFR 882.5890
ClassificationClass IIClass II
Product CodeNUH, NYNNUH

5.0 Intended use

The AD-2129A TENS device is intended for temporary relief of pain associated with sore and aching muscles due to strain from exercise or normal household and work activities, It is also intended for symptomatic relief and management of chronic, intractable pain and relief of pain associated with arthritis.

6.0 Device description

The AD-2129A Transcutaneous Electrical Nerve Stimulator(TENS) is transcutaneous electrical nerve stimulator for relief of muscular pain and sold without prescription.

The device consists of a microprocessor, buttons, electrical pads, and display. Keys can control the device to choose the operation modes, adjust pulse output strength, then the channel that effectively transfers your desired choice of programmed electrical pulses directly through electrode adhesive pads to the suggested area of the body where the electrodes are placed, causing minimal muscle stimulation. The LCD display can show user the mode and strength chosen and other information like date and time

Self-adhesive electrodes are used in this devices, and they are intended for use as the disposable, conductive adhesive interface between the patient's skin and the Electrical Stimulator. The electrodes is for OTC use, and mainly consists of substrate and wire.

7.0 Performance summary

TENS conforms to the following standards:

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  • · IEC 60601-1, Medical Electrical Equipment Part 1: General Requirements for Safety, 2005.
  • · IEC 60601-2-10, Medical electrical equipment Part 2: Particular requirements for the basic safety and essential performance of nerve and muscle stimulators
  • · IEC 60601-1-2, Medical Electrical Equipment Part 1-2: General Requirements for Safety - Collateral standard: Electromagnetic Compatibility - Requirements and Tests, 2007.
  • · ISO 10993: Biological evaluation of medical devices Part 1: Evaluation and testing within a risk management process.
  • · ISO 10993: Biological evaluation of medical devices Part 5: Test for in vitro cytotoxicity.
  • · ISO 10993: Biological evaluation of medical devices Part 10: Test for irritation and skin sensitization.

8.0 Non-clinical Testing Summary

The following testing was performed on the TENS devices in accordance with the requirements of the design control regulations and established quality assurance procedures.

(1) Biocompatibility of materials

When use the TENS device, one side of the electrode will contact the user, and the materials used on this side is tested according to ISO 10993-5 and ISO 10993-10, and the result shows it meet the applicable requirements.

(2) Electromagnetic Compatibility

Electromagnetic Compatibility test has been performed on the TENS devices according to the identical standard of IEC 60601-1-2, and the test result show that, the device meet all the applicable requirements.

(3) Electrical Safety Testing

Electrical Safety Test has been performed according to IEC 60601-1, and the test result shows that, the device meet all the applicable requirements. Also,

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particular safety test has been performed according to IEC 60601-2-10.

9.0 Comparison to the predicate device and the conclusion

The applicant device TENS is substantially equivalent to Smart Relief (K131159) and EasyStim TN28_OTC(K140168).

Similarities and differences comparison
CharacteristicsSubject devicePredicate device(1)Predicate device(2)
Product nameAD-2129A TENS deviceSmart ReliefEasyStim TN28_OTC
510(K)numberTo be assignedK131159K140168
Product codeNUH, NYNNUH, NYNNUH
Regulation No.21 CFR 882.589021 CFR 882.589021 CFR 882.5890
Intended useThe device is intendedfor temporary relief of painassociated with sore andaching muscles due tostrain from exercise ornormal household andwork activities, It is alsointended for symptomaticrelief and management ofchronic, intractable painand relief of painassociated with arthritis.To be used for temporaryrelief of pain associated withsore and aching musclesdue to strain from exerciseor normal household andwork activities.To be used for symptomaticrelief and management ofchronic, intractable pain andrelief of pain associated witharthritis.This device is intended forthe relief of pain associatedwith sore or aching musclesof the lower back, arms, orlegs due to strain fromexercise or normalhousehold and workactivities.
Presentation orOTCOTCOTCOTC
Environment ofuseHome useNot specifiedClinics, hospital and homeenvironments
Number ofOutputs mode818
Number ofOutputs212
WaveformMonophasic rectangularAsymmetrical BiphasicrectangularBiphasic rectangularMonophasic rectangular
Maximumoutputvoltage(max)500 Ω, 2 kΩ,and 10 kΩ500 Ω: 48V2 kΩ: 91.2V10 kΩ: 46VNot specified500 Ω: 68V2 kΩ: 102V10 kΩ: 110V
Maximum500 Ω: 96mA500 Ω: 133mA
OutputCurrent 500 Ω,2 kΩ, and 10kΩ2KΩ: 4.33mA10 kΩ:0.44 mANot specified2KΩ: 51mA10 kΩ:11 mA
MaximumPhase Charge,(μC) @ 500 Ω11.92uCNot specified20.02uC
MaximumAverageCurrent(500ohm)8.64mANot specified3.0375mA
MaximumCurrent Density,(mA/cm² @ 500 Ω)0.38mA/cm²Not specified0.188mA/cm²
MaximumAverage PowerDensity, (W/cm²@ 500 Ω1.62mW/cm²Not specified7.52mW/cm²
Frequency(Hz)2-125HZ1-100 Hz1-150Hz
PulseDuration(us)60-125Not specified10-250us, in steps of 50us
Burst ModeNoneNoneYes
Timerrange(min)15 minutes for allprogramsNot specified20min, 25min, 30min, 40mindepending on presetprogram
Indicationdisplay:-On/Off status-Output strength-Output mode-Time to cut-offNot specified-On/Off status-Low battery-Voltage/Current level-Output mode-Time to cut-off
Power Source4×1.5 size AAA3 V lithium battery2 Alkaline AA 1.5V (LR6)Batteries
Dimension140mm×63mm×30mm64mmX38mmX13mm66mm×136mm×30.7mm
Weight88g (exclude battery)20g146.5 grams
HousingMaterialsABSABSABS
MicroprocessorcontrolYesYesYes
AutomaticOverload tripNoNot specifiedYes
Automaticno-load tripYesNot specifiedYes
Automaticshut-offYesNot specifiedYes
User overridecontrolNoNot specifiedYes
Electrodecompliancewith 21 CFR898YesYesYes
Electrode cableYesNoYes

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The new device AD-2129A TENS has the same intended use, design, technological characteristics as the predicate device K131159 and K140168. Only pulse frequency, pulse strength and the appearance are different, but the Electrical Safety test and the EMC test in this submission provides demonstrated that these small differences do not raise any new questions of safety and effectiveness to the new devices.

§ 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).