K Number
K171722
Device Name
Electrodes with snap / Electrodes with pigtail
Date Cleared
2018-01-10

(212 days)

Product Code
Regulation Number
882.1320
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The proposed device is intended for use as the disposable, conductive interface between the patient's skin and the electrical stimulator to apply electrical stimulation current, and is intended to be used with legally marketed electrical stimulators, i.e. TENS (Transutaneous Electrical Nerve Stimulation) and EMS (Electrical Muscular Stimulation). It's for Over-the-Counter (OTC) use.
Device Description
The proposed Electrodes with snap / Electrodes with pigtail are non-sterile laminated, flexible structures composed of materials commonly used in this application: The electrodes are designed for single-patient application use. Because of the adhesive nature of the biocompatible hydro gel, no securing materials are required to secure the product to the patient's skin. The proposed product mainly consists of electrode pad and snap or pigtail. The electrode pad is available in Round Shape Electrode, Rectangular Shape Electrode, Palm shape Electrode, Elliptical Shape Electrode, and Calabash Shape Electrode.
More Information

Not Found

No
The summary describes a passive electrode device and explicitly states "Not Found" for mentions of AI, DNN, or ML, as well as training and test set descriptions.

No.
This device is an accessory (disposable conductive interface) for therapeutic devices (TENS and EMS), not a therapeutic device itself.

No

This device is an electrode, which serves as a conductive interface for applying electrical stimulation. It is not intended for the purpose of diagnosing a medical condition.

No

The device description clearly states it is a physical, disposable electrode pad with a snap or pigtail, composed of laminated, flexible structures and hydro gel. This is a hardware component, not software.

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In Vitro Diagnostics are devices intended for use in the collection, preparation, and examination of specimens taken from the human body (such as blood, urine, or tissue) to provide information for the diagnosis, treatment, or prevention of disease.
  • Device Function: The described device is an electrode intended to apply electrical stimulation to the patient's skin. It is a conductive interface for external electrical stimulators (TENS and EMS).
  • Lack of Specimen Analysis: The device does not involve the collection, preparation, or analysis of any biological specimens from the patient. Its function is purely to deliver electrical current externally.
  • Intended Use: The intended use is to apply electrical stimulation, not to diagnose or provide information based on analyzing bodily fluids or tissues.

Therefore, based on the provided information, this device falls under the category of an external electrical stimulation accessory, not an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

The proposed device is intended for use as the disposable, conductive interface between the patient's skin and the electrical stimulator to apply electrical stimulation current, and is intended to be used with legally marketed electrical stimulators, i.e. TENS (Transutaneous Electrical Nerve Stimulation) and EMS (Electrical Muscular Stimulation). It's for Over-the-Counter (OTC) use.

Product codes

GXY

Device Description

The proposed Electrodes with snap / Electrodes with pigtail are non-sterile laminated, flexible structures composed of materials commonly used in this application: The electrodes are designed for single-patient application use. Because of the adhesive nature of the biocompatible hydro gel, no securing materials are required to secure the product to the patient's skin. The proposed product mainly consists of electrode pad and snap or pigtail. The electrode pad is available in Round Shape Electrode, Rectangular Shape Electrode, Palm shape Electrode, Elliptical Shape Electrode, and Calabash Shape Electrode.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Adult only

Intended User / Care Setting

Over-the-Counter (OTC) use.

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)

The proposed Electrodes with snap / Electrodes has been evaluated the safety and performance by lab bench testing as following:

  • Biocompatibility test according to ISO 10993-5 and ISO 10993-10 standards
  • The electrode wire is compliance with 21 CFR 898 by construction review according to Sub-Clause 56.3 (c) in IEC 60601-1:1988 + A2:1995 (2nd edition)

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

Not Found

Predicate Device(s)

K160081

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 882.1320 Cutaneous electrode.

(a)
Identification. A cutaneous electrode is an electrode that is applied directly to a patient's skin either to record physiological signals (e.g., the electroencephalogram) or to apply electrical stimulation.(b)
Classification. Class II (performance standards).

0

Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

January 10, 2018

Shenzhen Konmed Technology Co., Ltd % Cecilia Ceng Manager Guangzhou GLOMED Biological Technology Co., Ltd. Suite 306, Kecheng Mansion, No.121 Science Road Guangzhou Science Park Guangzhou, Guangdong, 510006 China

Re: K171722

Trade/Device Name: Electrodes with snap / Electrodes with pigtail Regulation Number: 21 CFR 882.1320 Regulation Name: Cutaneous Electrode Regulatory Class: Class II Product Code: GXY Dated: October 21, 2017 Received: October 30, 2017

Dear Cecilia 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 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

1

requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in 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.

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.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Vivek J. Pinto -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) K171722

Device Name

Electrodes with snap / Electrodes with pigtail

Indications for Use (Describe)

The proposed device is intended for use as the disposable, conductive interface between the patient's skin and the electrical stimulator to apply electrical stimulation current, and is intended to be used with legally marketed electrical stimulators, i.e. TENS (Transutaneous Electrical Nerve Stimulation) and EMS (Electrical Muscular Stimulation). It's for Over-the-Counter (OTC) use.

Type of Use (Select one or both, as applicable)
[Checkbox 1] [Checkbox 2]

| | Prescription Use (Part 21 CFR 801 Subpart D)

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

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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. Submitter's Information

510(k) Owner's Name: Shenzhen Konmed Technology Co., Ltd Establishment Registration Number: Applying Address: 703B, Haide building A, Nanxin Road, Nanshan, Shenzhen, China Tel: +86-755-86704558 Fax: +86-755-86704558 Contact Person: Tony (Manager) Email: 2519021651 @qq.com

Application Correspondent:

Application Correspondent: Contact Person: Ms. Cassie Lee Guangzhou GLOMED Biological Technology Co., Ltd. Address: Suite 306, Kecheng Mansion, No.121 Science Road, Guangzhou Science Park, Guangzhou 510663, China Tel: +86-20-61099984 Email: regulatory@glomed-info.com

2. Subject Device Information

Trade Name: Electrodes with snap / Electrodes with pigtail Model: Model A: Round Shape Electrode; Model B: Rectangular Shape Electrode; Model C: Palm shape Electrode; Model D: Elliptical Shape Electrode; Model E: Calabash Shape Electrode Common Name: Cutaneous Electrode Classification name: Cutaneous Electrode Review Panel: Neurology Models: Round Shape Electrode, Rectangular Shape Electrode, Palm Shape Electrode, Elliptical Shape Electrode, Calabash Shape Electrode Product Code: GXY Regulation Class: 2 Regulation Number: 882.1320

3. Predicate Device Information

510(K) Number: K160081 Company Name: CATHAY MANUFACTURING CORP. Trade/Device Name: TENS Electrodes Requlation Number: 882.1320 Regulatory Class: 2 Product Code: GXY

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Sponsor:Shenzhen Konmed Technology Co., Ltd
Subject Device:Electrodes with snap / Electrodes with pigtail
File No.:510(k) Summary

4. Device Description

The proposed Electrodes with snap / Electrodes with pigtail are non-sterile laminated, flexible structures composed of materials commonly used in this application: The electrodes are designed for single-patient application use. Because of the adhesive nature of the biocompatible hydro gel, no securing materials are required to secure the product to the patient's skin. The proposed product mainly consists of electrode pad and snap or pigtail. The electrode pad is available in Round Shape Electrode, Rectangular Shape Electrode, Palm shape Electrode, Elliptical Shape Electrode, and Calabash Shape Electrode.

5. Intended Use / Indications for Use

The proposed product is intended for use as the disposable, conductive interface between the patient's skin and the electrical stimulator to apply electrical stimulation current, and is intended to be used with legally marketed electrical stimulators, i.e. TENS (Transcutaneous Electrical Nerve Stimulation) and EMS (Electrical Muscular Stimulation). It's for Over-the-Counter (OTC) use.

6. Test Summary

The proposed Electrodes with snap / Electrodes has been evaluated the safety and performance by lab bench testing as following:

  • Biocompatibility test according to ISO 10993-5 and ISO 10993-10 standards �
  • � The electrode wire is compliance with 21 CFR 898 by construction review according to Sub-Clause 56.3 (c) in IEC 60601-1:1988 + A2:1995 (2nd edition)

7. Comparison to predicate device and conclusion

The technological characteristics, features, specifications, materials, mode of operation, and intended use of the proposed Electrodes with snap / Electrodes is substantially equivalent to the predicate devices quoted below. The differences between the subject device and predicate devices do not raise new issues of safety or effectiveness.

| Elements of

ComparisonSubject devicePrimary PredicateRemark
Device NameElectrodes with snap /
Electrodes with pigtailTENS Electrodes--
510(K) NumberApplyingK160081--
Product CodeGXYGXYSE
Intended Use /
Indications for UseThe proposed device is
intended for use as the
disposable, conductive
adhesive interface between
the patient's skin and the
electrical stimulator to apply
electrical stimulation current,
and is intended to be used
with legally marketed
electrical stimulators, i.e.The proposed device is
intended for use as the
disposable, conductive
adhesive interface between
the patient's skin and the
electrical stimulator to apply
electrical stimulation current,
and is intended to be used
with marketed electrical
stimulators, i.e. TENSSE
TENS (Transcutaneous
Electrical Nerve Stimulation)
and EMS (Electrical
Muscular Stimulation). It's
for Over-the-Counter (OTC)
use.(Transcutaneous Electrical
Nerve Stimulation) and EMS
(Electrical Muscular
Stimulation).It's for OTC use.
Models of electrode
padMode A: Round Shape
Electrode
Model B: Rectangular Shape
Electrode
Model C:Palm Shape
Electrode
Model D:Elliptical Shape
Electrode
Model E: Calabash Shape
ElectrodeModel A: Round shape
electrode
Model B: Rectangular shape
Electrode
Model C: Crescent shape
Electrode
Model D: Square shape
Electrode
Model E:Calabash Shape
ElectrodeSE
Note1
Surface area
(Conductive
surface)Model A: 5 cm in diameter
Model B: 5 x 11; 6 x 11
(cm2)
Model C: 7.6 x 4.8 (cm2)
Model D: 3 x 4.3 (cm2)
Model E: 8.4 x 4.8 (cm2)Model A: 5cm in diameter
Model B: 510;610(cm2)
Model C: 2.4*4.2(cm2)
Model D: 3.2*3.2(cm2)
Model E: 8.0*5.5 (cm2)SE
Note1
OTC or prescriptionFor OTC UseFor OTC UseSE
Design featuresSubstrate/Wire/Hydro-Gel
Scrim/Conductive Fiber
Carbon Conductive Film
/linerSubstrate/Wire/Hydro-Gel
Scrim/Conductive Fiber
Carbon Conductive Film /linerSE
Materials:Non-woven fabric+ adhesiveNon-woven fabric+ adhesive
Substrate;
Wire;Wire & Terminal coated PVCWire & Terminal coated PVCSE
Hydro-gel;Hydro-gelHydro-gelNote1
Scrim;nylonPET fabric
Conductive fiber;Silver filamentsCarbon fiber + reinforcing fiber
Carbon conductive
Film;Carbon BlackPoly-isobutylene, Carbon
Black
BiocompatibilityComplied with ISO 10993Conforms to ISO10993SE
LabelingConfirm to 21 CFR Part 801Confirm to 21 CFR Part 801SE
ElectricalIndividual pad impedanceIndividual pad impedanceSE
Note2

5

6

Sponsor:Shenzhen Konmed Technology Co., Ltd
Subject Device:Electrodes with snap / Electrodes with pigtail
File No.:510(k) Summary
impedancebelow 3000 ohms @ 10 Hzbelow 200 ohms @ 60 kHz
Adhesive
performance on To>= No. 14 steel ball
(Diameter: 11.112 mm)
following AS07-003 /
GB/T4852-200>= No. 14 steel ball (Diameter:
11.112 mm) following AS07-
003 / GB/T4852-2002SE
Adhesive
holding strength
performanceA sample pad with 40mm
length and 40 mm width;
Hang a weight of 500g
without detach within 1minA sample pad with 25mm
length and 25 mm width;
Hang a weight of 200g without
detach within 30sSE
Note 2
Tensile StrengthElectrode is held up with a
weight of 500g hung on the
wire, and can hold on at
least 1 minutesElectrode is held up with a
weight of 500g hung on the
wire, and can hold on at least
1 minutesSE
ConformabilityNo more than 10% of the
adhesive area of the device
shall have separated from
the skin surface at 1 h after
applicationNo more than 10% of the
adhesive area of the device
shall have separated from the
skin surface at 1 h after
applicationSE
Impedance
Distribution
uniformity test1) No significant deviation
between resistance
values measured for
each combination mode.
  1. The maximum value
    and the minimum value
    should be within ±10%
    of average value | 1) No significant deviation
    between resistance values
    measured for each
    combination mode.

  2. The maximum value and
    the minimum value should
    be within ±10% of average
    value | SE |
    | Sterility | Non-sterile | Non-sterile | SE |
    | Stability and shelf
    life | 2 years | 2 years | SE |
    | Re-usable | For single patient | For single patient | SE |
    | Intended population | Adult only | No specified population | SE Note 1 |

Comparison in Detail(s):

Note 1:

Although the "Model", " Surface area (Conductive surface)", "Materials" and " Intended population" of the subject device are different from the predicate devices, they are all complying with ISO 10993 requirements. So the differences of the function specifications will not raise any safety or effectiveness issue.

Note 2:

7

Sponsor:Shenzhen Konmed Technology Co., Ltd
Subject Device:Electrodes with snap / Electrodes with pigtail
File No.:510(k) Summary

Although the "Electrical Impedance" and "Adhesive holding strength performance" are not totally same, they all of the subject devices are different from the predicate devices, they are all complying with performance testing. So the differences of the function specifications will not raise any safety or effectiveness issue.

Note 3:

" SE" means substantially equivalent.

Conclusion

The subject device Electrodes with snap / Electrodes with pigtail has all features of the predicate devices. The few differences do not affect the safety and effectiveness of the subject device. Thus, the subject device is substantially equivalent to the predicate devices.

8. Date of the summary prepared: January 5, 2018