(132 days)
No
The description focuses on standard TENS device features like channels, preset programs, intensity adjustment, and time selection. There is no mention of AI/ML terms, image processing, or data training/testing, which are common indicators of AI/ML integration.
Yes.
The device is a TENS device intended for "temporary relief of pain associated with sore or aching muscles," which is a therapeutic purpose.
No
This TENS device is intended for pain relief, not for diagnosing medical conditions. It works by stimulating nerves to alleviate symptoms, rather than identifying or characterizing a disease or condition.
No
The device description explicitly details hardware components including a handheld main unit, electrodes, a charging unit, and electrode cables. It also mentions rechargeable batteries built into the main unit. This indicates it is a physical device with hardware components, not software-only.
Based on the provided information, this device is not an IVD (In Vitro Diagnostic).
Here's why:
- Intended Use: The intended use is for the temporary relief of pain associated with sore or aching muscles. This is a therapeutic use, not a diagnostic one.
- Device Description: The device is described as a TENS (Transcutaneous Electrical Nerve Stimulation) device. TENS devices deliver electrical impulses to the body for pain relief. This is a physical therapy modality, not a method for analyzing biological samples.
- No mention of biological samples: The description does not mention the collection or analysis of any biological samples (like blood, urine, tissue, etc.), which is a core characteristic of IVD devices.
- Anatomical Site: The device is applied to the body (shoulder, waist, back, etc.), not used to test samples taken from the body.
IVD devices are used to examine specimens derived from the human body to provide information for diagnostic, monitoring, or compatibility purposes. This TENS device does not fit that description.
N/A
Intended Use / Indications for Use
This TENS device is to be used for temporary relief of pain associated with sore or aching muscles in the shoulder, waist, back, neck, upper extremities (arm), and lower extremities (leg) due to strain from exercise or normal household work activities.
Product codes
NUH
Device Description
The Counter Pain Therapy Device, Model P.T.S.-IV features two channels and seven (7) preset programs. The output of both channels can be adjusted individually for intensity in sixteen (16) steps and the treatment time is selectable from 20, 30 or 40 minutes. All features are well indicated by large icons on a backlit LCD screen for easy reading.
The device is powered by three (3) rechargeable Lithium Batteries which are permanently built into the main unit and can be recharged with the charging unit supplied for the device.
The Pain Therapy Device consists of the handheld main unit (controller), two pairs of self-adhesive electrodes, a plug-in charging unit (adaptor 120VAC to 5VDC) and two pairs of electrode cables.
Mentions image processing
Not Found
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
Not Found
Anatomical Site
shoulder, waist, back, neck, upper extremities (arm), and lower extremities (leg)
Indicated Patient Age Range
Not Found
Intended User / Care Setting
Clinics, Hospitals 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)
Counter did not conduct, nor rely upon, clinical tests to determine substantial equivalence of the Pain Therapy Device Model P.T.S.-IV. vs. the predicates. Non-clinical testing was performed in the K132993 submission in order to validate the design according to the company's specified design requirements, and to assure conformance with the following voluntary design standards:
IEC 60601-1:1988 + A1:1991 + A2:1995 "Medical electrical Equipment – Part 1: General requirements for basic safety and essential performance".
IEC 60601-2-10: 1987 (first Edition + amendment 1 (2001) for use in conjunction with IEC 60601-1 (1988), Amendments 1 (1991) and 2 (1995) "Medical electrical equipment -Part 2: "Particular Requirements for safety of nerve and muscle stimulators".
IEC 60601-1-2: 2001 + A1: 2004 & IEC60601-2-10: 1987 + A1: 2001 Clause 36 Medical Electrical Equipment, Part1-2: "General requirements for Basic Safety and Essential Performance" Collateral Standard: Electromagnetic Compatibility.
The electrodes are the only body contacting parts. They have been tested for biocompatibility as part of their separate FDA 510(k) clearance.
Based upon the test results it was concluded that the software performs within specifications and is safe to the stated intended use. Since a permanent hazard analysis is implemented in the software development process, and due to the clear software architecture, it is believed that the test protocol sufficiently verifies the software's main functional operation.
The cleaning instructions as described the Instruction Manual have been tested to be sufficient. Testing involved validation of the manual cleaning method as per the instructions. All testing concluded that that the Pain Therapy Device can be cleaned by the use of the methods described in the Instruction Manual.
Performance testing in K132993 has established that, with respect to EMC and electrical safety in its intended operational environment, the device conforms to all applicable requirements of IEC 60601-1 and IEC 60601-1-2.
Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)
Not Found
Predicate Device(s)
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).
0
Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo is circular and contains the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. In the center of the circle is an abstract image of a human figure, represented by three overlapping profiles facing to the right, with a stylized wave or ribbon element below them.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
October 13, 2016
Counter Scientific Development (GZ) Ltd % Guenter Ginsberg President Media Trade Corporation 11820 Red Hibiscus Drive Bonita Springs, Florida 34135
Re: K161537
Trade/Device Name: OTC TENS Device, Model PTS-IV Regulation Number: 21 CFR 882.5890 Regulation Name: Transcutaneous Electrical Nerve Stimulator for Pain Relief Regulatory Class: Class II Product Code: NUH Dated: September 2, 2016 Received: September 7, 2016
Dear Guenter Ginsberg:
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
1
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 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" (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 -A
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) K161537
Device Name OTC TENS Device, Model PTS-IV
Indications for Use (Describe)
This TENS device is to be used for temporary relief of pain associated with sore or aching muscles in the shoulder, waist, back, neck, upper extremities (arm), and lower extremities (leg) due to strain from exercise or normal household work activities.
| Type of Use (Select one or both, as applicable) |
|---|
| ------------------------------------------------- |
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
Date of Summary Prepared: 10/12/2016
- Submitter's Name: Counter Scientific Development (GZ) Ltd.
2nd & 3rd Floor, Blg. 6, DaPian Industrial Zone Address: Tangxia Road, Tianhe District, Guangzhou, China
Contact person: Wendi Poon, Manager
Tel: +86-20 -8328 9980
Fax: +86-20-38339500
E-mail Counter_csd@yahoo.com.cn
2. Proposed New Device:
Trade Name: OTC TENS Device, Model PTS-IV (K161537)
Manufacturer: Counter Scientific Development (GZ) Ltd.
Classification Name: Transcutaneous electrical nerve stimulator for pain relief Regulation Number: 21 CFR 882.5890 Product Code: NUH Device Class: II
3. Predicate (cleared) Devices:
Primary Predicate: (K132993)
Trade Name: Counter Pain Therapy Device, Model P.T.S.-IV
Counter Scientific Development (GZ) Ltd. Manufacturer:
Secondary Predicate: (K121757)
Trade Name: TENS and Powered Muscle Stimulator, Model Pro-8AB
Manufacturer: Healthmate International, LLC
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4. Description of Proposed Device:
The Counter Pain Therapy Device, Model P.T.S.-IV (K161537) is identical to the previous cleared version of the device with the same name (K132993). The purpose of this 510(k) submission is to seek different (expanded) Indications for Use. The only changes are in the 'Indication for Use Statement'.
The Counter Pain Therapy Device, Model P.T.S.-IV features two channels and seven (7) preset programs. The output of both channels can be adjusted individually for intensity in sixteen (16) steps and the treatment time is selectable from 20, 30 or 40 minutes. All features are well indicated by large icons on a backlit LCD screen for easy reading.
The device is powered by three (3) rechargeable Lithium Batteries which are permanently built into the main unit and can be recharged with the charging unit supplied for the device.
The Pain Therapy Device consists of the handheld main unit (controller), two pairs of self-adhesive electrodes, a plug-in charging unit (adaptor 120VAC to 5VDC) and two pairs of electrode cables.
The device was tested to and met the requirements of the following recognized consensus standards in K132993:
IEC 60601-1:1988 + A1:1991 + A2:1995 "Medical electrical Equipment = Part 1: General requirements for basic safety and essential performance".
IEC 60601-2-10: 1987 (first Edition + amendment 1 (2001) for use in conjunction with IEC 60601-1 (1988). Amendments 1 (1991) and 2 (1995) "Medical electrical equipment -Part 2: "Particular Requirements for safety of nerve and muscle stimulators".
IEC 60601-1-2: 2001 + A1: 2004 & IEC60601-2-10: 1987 + A1: 2001 Clause 36 Medical Electrical Equipment, Part1-2: "General requirements for Basic Safety and Essential Performance" Collateral Standard: Electromagnetic Compatibility.
5
5. Indication for Use:
This TENS device is to be used for temporary relief of pain associated with sore or aching muscles in the shoulder, waist, back, neck, upper extremities (arm), and lower extremities (leg) due to strain from exercise or normal household work activities.
6. Environment of Use:
Clinics, Hospitals and home environments
7. Contraindications:
Do not use this device if you have a cardiac pacemaker, implanted defibrillator, or other implanted metallic or electronic device. Such use could cause electrical shock, burns, electrical interference, or death.
Do not use this device together with a life-supporting medical electronic device such as an artificial heart or lung.
Do not use this device together with a body-worn medical electronic device such as an ECG.
8. Technological Characteristics Compared to the Predicate Devices
Both Counter Pain Therapy Devices Model P.T.S.-IV, the subject device K161537 and the primary predicate device K132993 are identical in design, technological characteristics and specifications, except for the "Indication For Use" statement. The subject device has expanded "Indications For Use" that are comparable to the secondary predicate device Pro-8AB (K121757). Both have the same intended use and technology. Both, the subject device and the predicate provide electrically generated pulses applied to the skin via electrodes. There are minor technical differences between the two devices.
The electrical stimulation provided by the Counter device is substantially equivalent to that commonly employed by TENS devices that have been cleared for marketing without
6
prescription labeling; i.e. for OTC sale. Technological characteristics, features, specifications, materials and intended uses of the subject Counter device are substantially equivalent to the quoted predicate device Pro-8AB. The differences that exist between both of the Counter devices and the predicate device Pro-8AB are insignificant in terms of safety or effectiveness.
9. Discussion of Non-Clinical Tests Performed for Determination of Substantial Equivalence is as follows:
Counter did not conduct, nor rely upon, clinical tests to determine substantial equivalence of the Pain Therapy Device Model P.T.S.-IV. vs. the predicates. Non-clinical testing was performed in the K132993 submission in order to validate the design according to the company's specified design requirements, and to assure conformance with the following voluntary design standards:
IEC 60601-1:1988 + A1:1991 + A2:1995 "Medical electrical Equipment – Part 1: General requirements for basic safety and essential performance".
IEC 60601-2-10: 1987 (first Edition + amendment 1 (2001) for use in conjunction with IEC 60601-1 (1988), Amendments 1 (1991) and 2 (1995) "Medical electrical equipment -Part 2: "Particular Requirements for safety of nerve and muscle stimulators".
IEC 60601-1-2: 2001 + A1: 2004 & IEC60601-2-10: 1987 + A1: 2001 Clause 36 Medical Electrical Equipment, Part1-2: "General requirements for Basic Safety and Essential Performance" Collateral Standard: Electromagnetic Compatibility.
a. Biocompatibility
The electrodes are the only body contacting parts. They have been tested for biocompatibility as part of their separate FDA 510(k) clearance.
b. Software
Based upon the test results it was concluded that the software performs within specifications and is safe to the stated intended use. Since a permanent hazard analysis is implemented in the software development process, and due to the clear software architecture, it is believed that the test protocol sufficiently verifies the software's main functional operation.
c. Cleaning
The cleaning instructions as described the Instruction Manual have been tested to be sufficient. Testing involved validation of the manual cleaning method as per the instructions. All testing concluded that that the Pain Therapy Device can be cleaned
7
by the use of the methods described in the Instruction Manual.
d. EMC and Electrical Safety
Performance testing in K132993 has established that, with respect to EMC and electrical safety in its intended operational environment, the device conforms to all applicable requirements of IEC 60601-1 and IEC 60601-1-2.
10. Conclusions:
The cleared Counter Pain Therapy Device, Model P.T.S.-IV (K132993) and the subject Counter device (K161537) are identical and only differ in their "Indications for Use" statements . The subject Counter device (K161537) and the secondary predicate Pro-8AB (K121757) by Healthmate Intl, LLC have the same "Indications for Use" and have very similar technical characteristics.
Moreover, bench testing and safety report documentation demonstrate that the submitted device could maintain the same safety and effectiveness as that of predicate device. In the other words, the differences do not affect the intended use and do not raise any new questions of safety or effectiveness or alter the fundamental scientific technology of the device. Thus, the Counter Pain Therapy Devices, Models P.T.S.-IV (K161537) is substantially equivalent to the predicate device Pro-8AB by Healthmate Intl, LLC.