(145 days)
Not Found
No
The summary describes a standard TENS/PMS device with pre-set modes and electrical stimulation, with no mention of adaptive algorithms, learning capabilities, or any terms associated with AI/ML. The performance studies focus on electrical safety, EMC, biocompatibility, and software validation according to standard medical device guidance, not AI/ML specific validation.
Yes
The device is indicated for temporary relief of pain (TENS mode) and improvement/strengthening of muscles (PMS mode), both of which are therapeutic purposes.
No.
The device is described as a muscle stimulation and pain relief system, not a diagnostic device.
No
The device description explicitly mentions hardware components such as electrode pads, a support belt, snap cables, and a battery, indicating it is not a software-only device.
Based on the provided information, this device is not an IVD (In Vitro Diagnostic).
Here's why:
- IVD Definition: In Vitro Diagnostics are medical devices used to perform tests on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections.
- Device Function: The 2-in-1 Abdominal Muscle Training & Back Pain Relief System uses electrical stimulation applied to the skin (transcutaneous) to relieve pain and stimulate muscles. It does not analyze any samples taken from the body.
- Intended Use: The intended uses described are for pain relief and muscle conditioning, which are physical effects on the body, not diagnostic testing of biological samples.
Therefore, this device falls under the category of a physical therapy or muscle stimulation device, not an In Vitro Diagnostic.
N/A
Intended Use / Indications for Use
The 2-in-1 Abdominal Muscle Training & Back Pain Relief System has two modes of stimulation; a transcutaneous electrical nerve stimulation (TENS) BP-313 mode and a powered muscle stimulation (PMS) TS-212 mode.
The TENS (BP-313 Mode) is indicated for temporary relief of pain associated with sore and aching muscles in the waist. back, arm, leg due to strain from exercise or normal household and work activities.
The PMS (TS-212 Mode) is indicated for the improvement of abdominal muscle tone, for strengthening of abdominal muscles and for the development of a firmer abdomen. This system is intended to stimulate healthy muscles in order to improve and facilitate muscle performance.
Product codes (comma separated list FDA assigned to the subject device)
NUH, NGX
Device Description
2-in-1 Abdominal Muscle Training & Back Pain Relief System is a portable multifunctional device, offering both Transcutaneous Electronic Nerve Stimulator (TENS) and Powered Muscle Stimulator (PMS) qualities.
2-in-1 Abdominal Muscle Training & Back Pain Relief System has 12 operation modes, which can give certain electrical pulse through 4 of electrode pads placed on the skin to help users to enjoy body stimulation.
The support belt which fastens around your waist provides appropriate stimulation position for a quick and easy exercise for users of all different waist sizes. The adhesive pads adhere to the belt to conduct the signal from the unit to your abdominal muscles. Snap cables are for connecting the stimulator and the support belt. Each unit comes with one battery (6F22/1604) so you can start exercising right away.
TS-212:
Its technology allows you to exercise ALL of the abdominal muscles using a simple belt. A signal is sent from the belt to the nerves which control the muscles. These nerves are stimulated in the area where they are most concentrated using the model of TS-212, causing a deep, comfortable contraction of the muscles of the abdomen.
You will feel a mild pulsing sensation, followed by some tightening of the skin and muscle between the pads. The muscles should contract smoothly, hold themselves in a tensed position for a few seconds and then gently relax again. If you feel a sharp prickling sensation or no feeling you should refer to the trouble shooting guide it may be that the pads are positioned directly over your hip bones and need repositioning. Once the problem is solved, just continue with your exercise.
BP-313:
The main function of pain relief comes from the continuous stimulation pulse generated from the dual channel stimulator. We cannot ensure that the pain relief is 100% effective for everyone. However, when used according to our instruction, it can be a safe, non-invasive lower back pain reliever.
Transcutaneous Electrical Nerve Stimulation (TENS) relieves pain by sending small electrical impulses through electrodes placed on the skin to underlying nerve fibers. TENS is believed to work by two different mechanisms. First, electrical stimulation of the nerve fibers can block a pain signal from being carried to the brain. If the signal is blocked, pain is not perceived. Secondly, the body has its own mechanism for suppressing pain. It does this by releasing natural chemicals called endorphins in the brain which act as analgesics. TENS may activate this mechanism.
Mentions image processing
Not Found
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
Not Found
Anatomical Site
Waist, back, arm, leg, abdomen
Indicated Patient Age Range
Not Found
Intended User / Care Setting
Not Found
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)
2-in-1 Abdominal Muscle Training & Back Pain Relief System has been evaluated the safety and performance by lab bench testing as following:
- Electrical safety test according to IEC 60601-1 and IEC 60601-2-10 standards .
- Electromagnetic compatibility test according to IEC 60601-1-2 standard
- Biocompatibility test according to ISO 10993-5 and ISO 10993-10 standards
- Software verification and validation test according to the requirements of the FDA "Guidance for Pre Market Submissions and for Software Contained in Medical Devices"
- The waveform test report has also been conducted to verify the output specifications of the device according to Guidance for Transcutaneous Electrical Nerve Stimulator for Pain Relief Intended for Over the Counter Use and Guidance for Powered Muscle Stimulator for Muscle Conditioning
Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)
Not Found
Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.
Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.
Not Found
Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).
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).
0
Image /page/0/Picture/1 description: The image shows a logo with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around a circular seal. Inside the seal is a stylized image of three human profiles facing to the right. The profiles are stacked on top of each other, creating a sense of depth and unity. The logo is simple and professional, conveying a sense of authority and trustworthiness.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
December 23, 2015
Tohkai Precision Electrical Manufactory (Shenzhen) Limited c/o Ms. Cecilia Ceng Guangzhou GLOMED Biological Technology Co., Ltd. Suite 306. Kecheng Mansion No. 121 Science Road Guangzhou Science Park Guangzhou, Guangdong, 510663 China
Re: K152128
Trade Name: 2-in-1 Abdominal Muscle Training & Back Pain Relief System Regulation Number: 21 CFR 882.5890 Regulation Name: Transcutaneous electrical nerve stimulator for pain relief Regulatory Class: Class II Product Code: NUH, NGX Dated: November 18, 2015 Received: November 23, 2015
Dear Ms. Ceng:
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 27f 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
1
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 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/Resourcesfor You/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.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely yours,
William J. Heetderks -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
2
Indications for Use
510(k) Number (if known) K152128
Device Name
2-in-1 Abdominal Muscle Training & Back Pain Relief System
Indications for Use (Describe)
The 2-in-1 Abdominal Muscle Training & Back Pain Relief System has two modes of stimulation; a transcutaneous electrical nerve stimulation (TENS) BP-313 mode and a powered muscle stimulation (PMS) TS-212 mode.
The TENS (BP-313 Mode) is indicated for temporary relief of pain associated with sore and aching muscles in the waist. back, arm, leg due to strain from exercise or normal household and work activities.
The PMS (TS-212 Mode) is indicated for the improvement of abdominal muscle tone, for strengthening of abdominal muscles and for the development of a firmer abdomen. This system is intended to stimulate healthy muscles in order to improve and facilitate muscle performance.
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) |
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3
Tohkai Precision Electrical Manufactory (Shenzhen) Limited Sponsor: Subject Device: 2-in-1 Abdominal Muscle Training & Back Pain Relief System
510 (k) Summary
Chapter 5. 510(k) Summary
510(k) Summary
This summary of 510(K) safety and effectiveness information is being submitted in accordance with the requirement of 21 CFR 807.92.
1. 510 (k) submitter
- Company Name: Tohkai Precision Electrical Manufactory (Shenzhen) Limited
- Establishment Registration Number: Applying
- Address: No.3 Alley 1,Second Industrial Park, Jia Zi Tang, GongMing Office. GuangMing New ● Developed Area. ShenZhen.
- Postal Code: 518132
- Phone: 0755-27173101
- Fax: 0755-27173105
- Contact Person (including title): Yuk Wing Li (General Manager)
- E-mail: tohkaip@globalsoures.com
2. Application Correspondent
- Contact Person: Ms. Cecilia Ceng / Mr. Tim Wong
- Guangzhou GLOMED Biological Technology Co., Ltd. ●
- Tel: +86-20-61099984
- Email: regulatory@glomed-info.com
3. Subject Device Information:
- Common Name: Electronic Stimulator
- Trade Name: 2-in-1 Abdominal Muscle Training & Back Pain Relief System
- . Classification Name: Stimulator, Nerve, Transcutaneous, Muscle, Powered, For Muscle Conditioning, Over-The-Counter
- Review Panel: Neurology & Physical Medicine
- Product Code: NUH, NGX +
- . Regulation Number: 882.5890, 890.5850
- Regulation Class: II
4. Predicate Device Information
| | LETO ENTERPRISES
INCORPORATION | Endurance Therapeutics | Shenzhen OSTO
Technology Company
Limited |
|-----------------------------|------------------------------------|------------------------|------------------------------------------------------------------|
| Sponsor | | | |
| Device
Name and
Model | X2ABS Dual Channel
Fitness Belt | TI040 | Health Expert
Electronic
Stimulator
Model: AST-300C and |
4
| Sponsor: | Tohkai Precision Electrical Manufactory (Shenzhen) Limited |
|---|---|
| Subject Device: | 2-in-1 Abdominal Muscle Training & Back Pain Relief System |
| AST-300D | |||
|---|---|---|---|
| 510(k) | |||
| Number | K102295 | K060846 | K133929 |
| Product | |||
| Code | NGX | NGX, NUH, GZJ | NUH, NGX |
| Regulation | |||
| Number | 890.5850 | 882.5890 | 882.5890, 890.5850 |
| Regulation | |||
| Class | II | II | II |
Device Description 5.
2-in-1 Abdominal Muscle Training & Back Pain Relief System is a portable multifunctional device, offering both Transcutaneous Electronic Nerve Stimulator (TENS) and Powered Muscle Stimulator (PMS) qualities.
2-in-1 Abdominal Muscle Training & Back Pain Relief System has 12 operation modes, which can give certain electrical pulse through 4 of electrode pads placed on the skin to help users to enjoy body stimulation.
The support belt which fastens around your waist provides appropriate stimulation position for a quick and easy exercise for users of all different waist sizes. The adhesive pads adhere to the belt to conduct the signal from the unit to your abdominal muscles. Snap cables are for connecting the stimulator and the support belt. Each unit comes with one battery (6F22/1604) so you can start exercising right away.
TS-212:
Its technology allows you to exercise ALL of the abdominal muscles using a simple belt. A signal is sent from the belt to the nerves which control the muscles. These nerves are stimulated in the area where they are most concentrated using the model of TS-212, causing a deep, comfortable contraction of the muscles of the abdomen.
You will feel a mild pulsing sensation, followed by some tightening of the skin and muscle between the pads. The muscles should contract smoothly, hold themselves in a tensed position for a few seconds and then gently relax again. If you feel a sharp prickling sensation or no feeling you should refer to the trouble shooting guide it may be that the pads are positioned directly over your hip bones and need repositioning. Once the problem is solved, just continue with your exercise.
BP-313:
The main function of pain relief comes from the continuous stimulation pulse generated from the dual channel stimulator. We cannot ensure that the pain relief is 100% effective for everyone. However, when used according to our instruction, it can be a safe, non-invasive lower back pain reliever.
Transcutaneous Electrical Nerve Stimulation (TENS) relieves pain by sending small electrical impulses through electrodes placed on the skin to underlying nerve fibers. TENS is believed to work by two different mechanisms. First, electrical stimulation of the nerve fibers can block a pain signal from
5
| Sponsor: | Tohkai Precision Electrical Manufactory (Shenzhen) Limited |
|---|---|
| Subject Device: | 2-in-1 Abdominal Muscle Training & Back Pain Relief System |
being carried to the brain. If the signal is blocked, pain is not perceived. Secondly, the body has its own mechanism for suppressing pain. It does this by releasing natural chemicals called endorphins in the brain which act as analgesics. TENS may activate this mechanism.
Intended Use 6.
The 2-in-1 Abdominal Muscle Training & Back Pain Relief System has two intended uses; The powered muscle stimulation (PMS) Mode (TS-212) is intended to deliver electrical stimulation to the muscles of the abdomen.
The transcutaneous electrical nerve stimulation TENS Mode (BP-313) is intended to deliver electrical stimulation to the peripheral nerves of the body.
7. Indications for Use
The 2-in-1 Abdominal Muscle Training & Back Pain Relief System has two modes of stimulation; a transcutaneous electrical nerve stimulation (TENS) BP-313 mode and a powered muscle stimulation (PMS) TS-212 mode.
The TENS(BP-313 Mode) is indicated for temporary relief of pain associated with sore and aching muscles in the waist, back, arm, leg due to strain from exercise or normal household and work activities.
THE PMS (TS-212 Mode) is indicated for the improvement of abdominal muscle tone, for strengthening of abdominal muscles and for the development of a firmer abdomen. This system is intended to stimulate healthy muscles in order to improve and facilitate muscle performance.
8. Design
2-in-1 Abdominal Muscle Training & Back Pain Relief System is a portable multifunctional device, offering both Transcutaneous Electronic Nerve Stimulator (TENS) and Powered Muscle Stimulator (PMS) qualities. 2-in-1 Abdominal Muscle Training & Back Pain Relief System has 12 operation modes, which can give certain electrical pulse through 4 electrode pads placed on the skin to help users to enjoy body stimulation. It is comprised of a main device for signal generation, belts for fixation, and series electrodes. The electronic stimulatory module has the operating elements of ON/OFF Switch, Model Selection knob, Display screen, Mode Selection key and Intensity Modification keys.
The device is chosen function between TENS(BP-313, Mode 1-8) and PMS(TS-212, Mode 1-4) before turning on the system.
The LCD display screen can show selected mode, output intensity of body, and time remaining of an application mode.
The device is equipped with accessories of electrode pads, snap cable, gel sticks, support belt. The snap cable is used to connect the pads to the main unit. All the accessories, including electrode pads, snap cable, gel sticks, support belt can only be changed by special person.
9. Materials
There are two user directly contracting components in the subject device as the following list.
| Patient Contacting
Components | Material | Body Contact
Location | Contact Duration |
|----------------------------------|--------------------------|------------------------------------|------------------|
| Button | ABS PA-757
PMMA-CM211 | Surface-contacting
device: skin | Less than 30 min |
| Connect line | SR8000-70N | Surface-contacting
device: skin | Less than 30 min |
6
| Sponsor: | Tohkai Precision Electrical Manufactory (Shenzhen) Limited |
|---|---|
| Subject Device: | 2-in-1 Abdominal Muscle Training & Back Pain Relief System |
| 510(k) Summary | |
|---|---|
| -- | ---------------- |
| | TPR RN-
100PVC03 | | |
|----------------|---------------------|------------------------------------|----------------------------------------------|
| Belt | conductive fabric | Surface-contacting
device: skin | 5 – 30 min (depends
on patients' setting) |
| Electrode Pads | gel | Surface-contacting
device: skin | 5-30 min (depends
on patients' setting) |
| Unit Housing | ABS plastic | Surface-contacting
device: skin | Less than 30 min |
10. Specification
| Power Source | 1 x 6F22 battery (9 Volt) |
|---|---|
| Number of channels | Two channels |
| Number of programs | TENS (BP-313): 8 |
| PMS (TS-212): 4 | |
| Output intensity level | Blevel |
| Frequency | 2Hz-120Hz |
| Pulse Duration | $16\mu s$ -260 $\mu s$ |
| Contraction and | |
| relaxation time | Adjustable, due to different modes. (See below "Program |
| Specification Table") | |
| Treatment time | 5-30 minutes |
| Indicator display | On/Off Status, Low Battery, Channel, Mode, Time |
| Electrode size | Electrode pad: 50mm(diameter) • 1.5mm(thickness). |
| gel stick : 48.048.01.5mm | |
| Control unit dimension | 125 x 72 x 39.5mm |
| Weight | Approx. 150g (battery included) |
| Environment for | |
| operation | Temperature: +41"Fto+104"F (+5'Cto +40'C); |
| Humidity: 15% to 93% RH | |
| Environment for | |
| storage | Temperature: -13"Fto+158"F (-25'Cto +70'C); |
| Humidity: ,;93% RH |
11. Test Summary
2-in-1 Abdominal Muscle Training & Back Pain Relief System has been evaluated the safety and performance by lab bench testing as following:
- Electrical safety test according to IEC 60601-1 and IEC 60601-2-10 standards .
- . Electromagnetic compatibility test according to IEC 60601-1-2 standard
- Biocompatibility test according to ISO 10993-5 and ISO 10993-10 standards
- Software verification and validation test according to the requirements of the FDA "Guidance for Pre Market Submissions and for Software Contained in Medical Devices"
7
| Sponsor: | Tohkai Precision Electrical Manufactory (Shenzhen) Limited |
|---|---|
| Subject Device: | 2-in-1 Abdominal Muscle Training & Back Pain Relief System |
- The waveform test report has also been conducted to verify the output specifications of the device according to Guidance for Transcutaneous Electrical Nerve Stimulator for Pain Relief Intended for Over the Counter Use and Guidance for Powered Muscle Stimulator for Muscle Conditioning
12. Comparison to predicate device and conclusion
The technological characteristics, features, specifications, mode of operation, and intended use of 2-in-1 Abdominal Muscle Training & Back Pain Relief System is substantially equivalent to the predicate devices quoted above.
The differences between the subject device and predicate devices do not raise new issues of safety or effectiveness.
| Elements of
| Comparison | Subject Device | Predicate Device | Remark | |
|---|---|---|---|---|
| Manufacturer | Tohkai Precision | |||
| Electrical | ||||
| Manufactory | ||||
| (Shenzhen) Ltd. | LETO | |||
| ENTERPRISES | ||||
| INCORPORATION |
Endurance
Therapeutics
Shenzhen OSTO
Technology
Company Limited | -- | |
| Device Name and
Model | 2-in-1 Abdominal
Muscle Training &
Back Pain Relief
System | X2ABS Dual Channel
Fitness Belt
TI 040
Shenzhen OSTO
Technology
Company Limited | -- | |
| 510(k) Number | Applying | K102295
K133929 | -- | |
| Basic Unit Characteristics | | | | |
| Power Source(s) | 1 x 6F22 battery (9
Volt) | 2 x 1.5V AAA
batteries
4.5 Volt battery
Adaptor Input: 100-
240Vac, 50-60Hz,
0.1A
Output: 5Vdc, 1A
Unit Input: 5Vdc, 1A | SE
Note1 | |
| -Method of Line
Current Isolation | Type BF Applied Part | Type BF Applied
Part
Type BF Applied
Part | SE | |
| Patient
Leakage
Current | NC
SFC | Comply with IEC
60601-1 and IEC
60601-2-10
Comply with IEC
60601-1 and IEC
60601-2-10 | AC: 54.5µA, DC:
0.5µA
AC:120.0µA, DC:
0.6µA | SE
Note 1 |
8
| Sponsor: | Tohkai Precision Electrical Manufactory (Shenzhen) Limited |
|---|---|
| Subject Device: | 2-in-1 Abdominal Muscle Training & Back Pain Relief System |
| Average DC
current through
electrodes when
Device is on but
no pulses are
being delivered. | 0A | | 0 A | 10 Hz |
| | 7 | 52mA | 260160 μs | 120Hz |P7 | Cycle |
| | 8 | 84mA | P1
| TS-212(PMS) | 1 | 52mA | 200 μs | 70Hz |
| | 2 | 52mA | 200 μs | 60Hz |
| | 3 | 52mA | 200 μs | 50Hz |
| | 4 | 52mA | 200 μs | 50Hz |
12
| Sponsor: | Tohkai Precision Electrical Manufactory (Shenzhen) Limited |
|---|---|
| Subject Device: | 2-in-1 Abdominal Muscle Training & Back Pain Relief System |
Comparison in Detail(s):
Note 1:
Although the " Power Source(s)", " Patient Leakage Current through electrodes when device is on but no pulses are being applied", "Operating Environment" are a little different from the predicate devices, they all comply with IEC 60601-1 requirements. So the differences will not raise any safety or effectiveness issue.
Note 2:
Although the " Number of Output Intensity Level", " Method of Channel Isolation", " Timer Range", "Vleight" and "Dimensions" of subject device are different from the predicate devices, they are all comply with IEC 60601-1 and IEC 60601-2-10 requirements. So the differences of the function specifications will not raise any safety or effectiveness issue.
Note 3:
Although the "Maximum Output Voltage", "Maximum Output Current", "Maximum pulse frequency", "Net Charge (per pulse)", "Maximum Phase Charge", "Maximum Average Current", "Maximum Current Density", "Maximum Average Power Density of subject device", "ON Time" are a little different from the predicate devices, they all comply with IEC 60601-1, IEC 60601-2-10 requirement for Transcutaneous Electical Nerve Stimulator for Pain Relief and FDA guidance requirement for Powered Muscle Stimulator for Muscle Conditioning. So the differences of function specification will not raise any safety or effectiveness issue.
Finial Conclusion:
The subject device 2-in-1 Abdominal Muscle Training & Back Pain Relief System has all features of the predicate devices. The differences between them do not affectiveness. Thus, the subject device is substantially equivalent to the predicate devices.