(142 days)
The device is intended to be used for temporary relief of pain associated with sore and aching muscles in the shoulder, waist, back, upper extremities(arm) and lower extremities (leg) due to strain from exercise or normal household work activities. And to be used for the symptomatic relief and management of chronic, intractable pain and relief of pain associated with arthritis.
The ThermaCare® Quick Therapy TENS device is a wireless, two channels wearable electrotherapy device that is designed to alleviate chronic muscle and joint pain on multiple body locations. It delivers TENS (Transcutaneous Electrical Nerve Stimulation) technology through the simple, convenient use of the dedicated APP (iOS or Android) or remote control. Reusable, self-adhesive pads allow for discreet and convenient placement on multiple pain locations on the body. The ThermaCare® Quick Therapy TENS contains 23 TENS programs. It is designed to be used at home, by adults of all genders.
The ThermaCare® Quick Therapy TENS device contains one main TENS unit which is rechargeable and one remote control which is powered by 2 AAA batteries. The pads with attached TENS unit can then be applied to intact skin at the desired location for pain relief. Control of the ThermaCare® Quick Therapy TENS device is completed through the available TENS APP (iOS or Android)or remote control. The communication is done via Bluetooth Low Energy.
The device will be packaged with an Instruction Manual which provides details on setting up the device for use, installing of the App, setting and controlling therapy programs, and troubleshooting. The ThermaCare® Quick Therapy TENS consists of the following elements:
• Main device: generates the TENS pulses; connects to the electrode; controlled by APP on smart phone and remote control.
• Electrodes: Self-adhesive re-usable hydrogel electrodes connects to the device.
• APP on mobile device: The APP controls the functions of the main device via a Bluetooth (4.0) Low Energy connection between the mobile device and the main device.
• Remote control: The remote controls the functions of the main device via a Bluetooth (4.0) Low Energy connection between the remote control and the main device.
· Adapter (optional): for charging the battery unit via a micro-USB socket which connected with the adapter, and insert the adapter to the supply mains.
Here's an analysis of the provided text regarding the acceptance criteria and study for the ThermaCare® Quick Therapy TENS (Model: TC001):
Based on the provided FDA 510(k) Summary, this document primarily focuses on establishing substantial equivalence to a predicate device (Wireless Pain Relieve Device, Model LT5018C, K173462), rather than detailing acceptance criteria for a novel device and studies proving it meets those criteria in a clinical performance sense.
The document primarily relies on bench testing and compliance with recognized standards to demonstrate the safety and effectiveness of the new device relative to the predicate. There is no evidence of a clinical study with human subjects to evaluate the device's performance against specific acceptance criteria for pain relief.
Therefore, many of the requested sections (sample size for test set, data provenance, ground truth experts, adjudication, MRMC study, standalone performance) are not applicable or cannot be answered from the provided text, as these typically relate to clinical performance studies.
1. A table of acceptance criteria and the reported device performance
The document does not explicitly present a table of "acceptance criteria" for clinical performance. Instead, it demonstrates compliance with safety and technical standards, and shows the technical specifications and outputs are comparable to a legally marketed predicate device.
Here's a summary of the technical specifications and their comparison to the predicate device, which implicitly serve as a form of "acceptance" for substantial equivalence:
| Characteristic | Acceptance Criteria (Predicate / Standard Compliance) | Reported Device Performance (TC001) |
|---|---|---|
| Intended Use | TENS for various pain relief (Predicate's TENS mode) | TENS for various pain relief |
| Power Source | DC 3.7V Li-ion (main), 2xAAA (remote) | DC 3.7V Li-ion (main), 2xAAA (remote) |
| Patient Leakage Current | 0uA (DC), 2.0uA (AC) (Predicate) | 0uA (DC), 29uA max (AC) (Tested to IEC 60601-1) |
| Avg DC current (no pulses) | 0 (Predicate) | 0 |
| Output Modes | 2 (TENS/EMS) (Predicate) | 1 (TENS) |
| Output Channels | N/A (Predicate, implied single) | Alternating (Two channels, tested to IEC 60601-2-10) |
| Channel Isolation | N/A (Predicate) | By Electrical Circuit and Software (Tested to IEC 60601-1) |
| Regulated Current/Voltage | Current control (Predicate) | Current control |
| Software/Firmware Control | Yes (Predicate) | Yes |
| Automatic Overload Trip | Yes (Predicate) | Yes |
| Automatic No Load Trip | Yes (Predicate) | Yes |
| Automatic Shut off | Yes (Predicate) | Yes |
| User Override Control | Yes (Predicate) | Yes (Device, remote, APP controls) |
| On/Off Status Indicator | Yes (Predicate) | Yes |
| Low Battery Indicator | Yes (Predicate) | Yes |
| Voltage/Current Level Indicator | Yes (Predicate) | Yes |
| Timer Range | 30 minutes (Predicate) | 5-30 minutes (Tested to IEC 60601-2-10) |
| Weight | 36g (main), 65g (remote) (Predicate) | 32g (main), 55g (remote, without batteries) (Tested to IEC 60601-1) |
| Dimensions (HWL) | 360x59x11.5mm (main), 115x53x25mm (remote) (Predicate) | 80.5x45x13.5mm (main), 127x48.6x24.4mm (remote) (Tested to IEC 60601-1) |
| Housing Materials | ABS (Predicate) | ABS |
| Compliance 21 CFR 898 | Yes (Predicate) | Yes |
| Compliance Voluntary Standards | IEC 60601-1, -1-2, -2-10, -1-11; ISO 10993-1, -5, -10 (Predicate) | IEC 60601-1, -1-2, -2-10, -1-11; ISO 10993-1, -5, -10 |
| Waveform | Biphasic (Predicate) | Biphasic |
| Shape | Rectangular (Predicate) | Rectangular |
| Max Output Voltage (V) @ 500Ω | 31 (Predicate) | 30.4 (Tested to IEC 60601-2-10) |
| Max Output Voltage (V) @ 2kΩ | 66 (Predicate) | 70 (Tested to IEC 60601-2-10) |
| Max Output Voltage (V) @ 10kΩ | 66 (Predicate) | 70 (Tested to IEC 60601-2-10) |
| Max Output Current (mA) @ 500Ω | 62 (Predicate) | 60.8 (Tested to IEC 60601-2-10) |
| Max Output Current (mA) @ 2kΩ | 33 (Predicate) | 35 (Tested to IEC 60601-2-10) |
| Max Output Current (mA) @ 10kΩ | 6.6 (Predicate) | 7 (Tested to IEC 60601-2-10) |
| Pulse Duration (µsec) | 150-250 (Predicate) | 100-200 (Tested to IEC 60601-2-10) |
| Frequency (Hz) | 2-100 (Predicate) | 2-100 |
| Max Phase Charge (uC) @ 500Ω | 31 (Predicate) | 24.32 (Tested to IEC 60601-2-10) |
| Max Current Density @ 500Ω | 0.48mA/cm² (Predicate) | 0.295mA/cm² (Tested to IEC 60601-2-10) |
| Max Avg Current (mA) @ 500Ω | 1.2 (Predicate) | 1.22 (Tested to IEC 60601-2-10) |
| Max Avg Power Density (mW/cm²) @ 500Ω | 2.88 (Predicate) | 1.8 (Tested to IEC 60601-2-10) |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Sample Size: Not applicable. The "testing" referred to in this document is primarily bench testing and compliance with international standards (biocompatibility, electrical safety, EMC, software V&V, output waveform testing), not a clinical study on human subjects.
- Data Provenance: Not applicable for clinical performance data. The device manufacturer is Shenzhen Dongdixin Technology Co., Ltd. in Shenzhen, China (as seen in the correspondent's address). The testing was likely conducted in laboratories adhering to international standards.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
Not applicable. No clinical ground truth was established by human experts for this submission type.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. No clinical adjudication was performed.
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
Not applicable. This device is a Transcutaneous Electrical Nerve Stimulator (TENS), not an AI-powered diagnostic system involving human "readers."
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
Not applicable. This device is electrotherapy equipment, not an algorithm. Its performance specifications were tested in a standalone manner (bench testing).
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
The "ground truth" for this submission are the international performance and safety standards (e.g., IEC 60601 series, ISO 10993 series) and the specifications of a legally marketed predicate device. The studies performed (biocompatibility, electrical safety, EMC, software V&V, output waveform) aimed to prove that the new device adheres to these standards and has comparable technical characteristics to the predicate.
8. The sample size for the training set
Not applicable. There is no mention of a training set as this is not an AI/machine learning device.
9. How the ground truth for the training set was established
Not applicable.
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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo features the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.
September 15, 2018
Pfizer Inc. % Siping Yuan R.A. Specialist Shenzhen Dongdixin Technology Co., Ltd No. 3 Building, Xilibaimang Xusheng Industrial Estate Nanshan, Shenzhen, Cn 518108
Re: K181102
Trade/Device Name: ThermaCare Quick Therapy TENS, TC001 Regulation Number: 21 CFR 882.5890 Regulation Name: Transcutaneous Electrical Nerve Stimulator For Pain Relief Regulatory Class: Class II Product Code: NUH, NYN Dated: April 20, 2018 Received: April 26, 2018
Dear Siping Yuan:
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 mav, 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 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);
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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 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,
Pamela D. Scott -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) K181102
Device Name ThermaCare® Quick Therapy TENS Model: TC001
Indications for Use (Describe)
The device is intended to be used for temporary relief of pain associated with sore and aching muscles in the shoulder, waist, back, upper extremities(arm) and lower extremities (leg) due to strain from exercise or normal household work activities. And to be used for the symptomatic relief and management of chronic, intractable pain and relief of pain associated with arthritis.
| 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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005_510 (k) Summary Version: 1.1
510(k) SUMMARY
as required by section 21 CFR 807.92
ThermaCare® Quick Therapy TENS
| Date of Submission: | 04/23/2018 |
|---|---|
| Submitter/510(k)Owner's Name: | Pfizer Inc. |
| Address: | 235 East 42nd Street, New York, New York 10017,USA |
| Contact Person: | Nicola Romano |
| E-mail: | nicola.romano@pfizer.com |
| Tel: | 973-660-5858 |
| Correspondent's Name: | Shenzhen Dongdixin Technology Co., Ltd. |
| Address: | No.3 Building Xilibaimang Xusheng Industrial Estate,Nanshan, Shenzhen, CHINA 518108 |
| CorrespondentContact: | Siping Yuan |
| E-mail: | ra@dundex.com |
| Tel: | +86(755) 27652471 |
| FAX: | +86(755) 27652674 |
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1. Proposed Device:
| Device Name: | ThermaCare® Quick Therapy TENS |
|---|---|
| Model: | TC001 |
| Device classification Name: | Stimulator, Nerve, Transcutaneous, Over-The-Counter |
| Regulation Description: | Transcutaneous electrical nerve stimulator for pain relief |
| Regulation Medical Specialty: | Neurology |
| Review Panel: | Neurology |
| Regulation Number: | 882.5890 |
| Product Code: | NUH |
| Device Class: | II |
| Device classification Name: | Stimulator, Electrical, Transcutaneous, For Arthritis |
| Regulation Description: | Transcutaneous electrical nerve stimulator for pain relief |
| Regulation Medical Specialty: | Neurology |
| Medical Specialty: | Neurology |
|---|---|
| Review Panel: | Neurology |
| Regulation Number: | 882.5890 |
| Product Code: | NYN |
| Device Class: | II |
2. Predicate Device:
| Legally Marketed Device: | Wireless Pain Relieve Device |
|---|---|
| LT5018C | |
| 510(k) Number: | K173462 |
| Manufacturer: | Shenzhen Dondixin Technology Co., Ltd. |
3. Description of Proposed Device:
The ThermaCare® Quick Therapy TENS device is a wireless, two channels wearable electrotherapy device that is designed to alleviate chronic muscle and joint pain on multiple body locations. It delivers TENS (Transcutaneous Electrical Nerve Stimulation) technology through the simple, convenient use of the dedicated APP (iOS or Android) or remote control. Reusable, self-adhesive pads allow for discreet and convenient placement on multiple pain locations on the body. The ThermaCare® Quick Therapy TENS contains 23 TENS programs. It is designed to be used at home, by adults of all genders.
The ThermaCare® Quick Therapy TENS device contains one main TENS unit which is rechargeable and one remote control which is powered by 2 AAA batteries. The pads with attached TENS unit can then be applied to intact skin at the desired location for pain relief. Control of the ThermaCare® Quick Therapy TENS device is completed through the available TENS APP (iOS or Android)or remote control. The
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communication is done via Bluetooth Low Energy.
The device will be packaged with an Instruction Manual which provides details on setting up the device for use, installing of the App, setting and controlling therapy programs, and troubleshooting. The ThermaCare® Quick Therapy TENS consists of the following elements:
• Main device: generates the TENS pulses; connects to the electrode; controlled by APP on smart phone and remote control.
• Electrodes: Self-adhesive re-usable hydrogel electrodes connects to the device.
• APP on mobile device: The APP controls the functions of the main device via a Bluetooth (4.0) Low Energy connection between the mobile device and the main device.
• Remote control: The remote controls the functions of the main device via a Bluetooth (4.0) Low Energy connection between the remote control and the main device.
· Adapter (optional): for charging the battery unit via a micro-USB socket which connected with the adapter, and insert the adapter to the supply mains.
4. Proposed Device Intended for Use Statement:
Device Name: ThermaCare® Quick Therapy TENS, Model: TC001
Indications for Use:
The device is intended to be used for temporary relief of pain associated with sore and aching muscles in the shoulder, waist, back, upper extremities(arm) and lower extremities (leg) due to strain from exercise or normal household work activities. And to be used for the symptomatic relief and management of chronic, intractable pain and relief of pain associated with arthritis.
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5. Technological Characteristics and Substantial Equivalence
Both the TC001 and Predicate Device utilize the application of electrical current through electrodes placed on the impulses are generated by the device and delivered through electrodes on the skin in direct proximity to the (painful) muscles to be stimulated. Basic technological characteristics, new device vs. Predicate device.
| New device | Predicate device | S.E. Discussion | ||
|---|---|---|---|---|
| 1 | 510K# | To be assigned | K173462 | N/A |
| 2 | Device Name andModel | ThermaCare® Quick Therapy TENSMode: TC001 | Wireless Pain Relieve DeviceMode: LT5018C | N/A |
| 3 | Applicant | Pfizer Inc. | Shenzhen Dongdixin Technology Co., Ltd | N/A |
| 4 | Manufacturer | Shenzhen Dongdixin Technology Co., Ltd | Shenzhen Dongdixin Technology Co., Ltd | Same |
| 5 | Intended for use | TENS: The device is designed to be usedfor temporary relief of pain associatedwith sore and aching muscles in theshoulder, waist, back, upper extremities(arm) and lower extremities (leg) due tostrain from exercise or normal householdwork activities. And to be used for thesymptomatic relief and management ofchronic, intractable pain and relief of painassociated with arthritis. | TENS: The device is designed to be usedfor temporary relief of pain associatedwith sore and aching muscles in theshoulder, waist, back, neck, upperextremities (arm) and lower extremities(leg) due to strain from exercise ornormal household work activities. Andto be used for the symptomatic reliefand management of chronic, intractablepain and relief of pain associated witharthritis.EMS: The device is designed to be usedfor stimulate healthy muscles in order toimprove and facilitate muscleperformance. | Applicant is not pursuingEMS use statement for thenew device. |
| 6 | Power Source | DC 3.7V Li-ion Battery(main device)DC 3.0V, 2 x AAA Batteries (Remotecontrol) | DC 3.7V Li-ion Battery(main device)DC 3.0V, 2 x AAA Batteries (Remotecontrol) | Same |
| -Method ofLine | N/A | N/A | Same | |
| current isolation | ||||
| - Patient LeakageCurrent (μΑ)-Normal condition-Single faultcondition | d.c:0 uA. a.c.:29 uA maxd.c:0 uA. a.c.:69 uA max | 0uA2.0uA | Different, TC 001 have beenevaluated and passed the testaccording to the requirementof IEC 60601-1. | |
| 7 | Average DC currentthrough electrodeswhen device is on butno pulses are beingapplied (μΑ) | 0 | 0 | Same |
| 8 | Number of OutputModes | 1 (TENS) | 2 (TENS/EMS(including MASSAGE)) | Different, TC001 only hasTENS mode and TC001remove indications for use ofEMS mode accordingly. |
| 9 | Number of Output Channels | |||
| Synchronous orAlternating? | Alternating | N/A | Different, TC001 has twochannels and each channeloutputs have been evaluatedand passed the test accordingto the requirement of IEC60601-2-10. | |
| Method of ChannelIsolation | By Electrical Circuit and Software | N/A | Different, TC001 has twochannels and have beenevaluated and passed the testaccording to the requirementof IEC 60601-1. | |
| 10 | Regulated Current orRegulated Voltage? | Current control | Current control | Same |
| 11 | Software/Firmware/Micro processorControl? | Yes | Yes | Same |
| 12 | Automatic OverloadTrip | Yes | Yes | Same |
| 13 | Automatic No Loadcontact Trip | Yes | Yes | Same |
| 14 | Automatic Shut off | Yes | Yes | Same |
| 15 | User OverrideControl? | YesPower [on/off] button on the devicePower [on/off] button on the remotecontrol[Stop session] button in the APP software | YesPower on/off button on the devicePower on/off on the remote controlPower on/off in the APP software | Same function |
| 16 | Indicator Display: | |||
| On/Off Status? | Yes | Yes | Same | |
| Low Battery? | Yes | Yes | Same | |
| Voltage/CurrentLevel? | Yes | Yes | Same | |
| 17 | TimerRange(minutes) | 5-30 minutes | 30 minutes | Different, new device havebeen evaluated and passedthe test according to therequirement of IEC60601-2-10.User can set the treatmenttime according their needs. |
| 18 | Weight (grams.) | 32grams (Main device)55 grams (Remote control withoutbatteries) | 36grams (Main device)65 grams (Remote control) | Different, the new devicehave been evaluated and |
| 19 | Dimensions(cm.)H*W * L | 80.5(L)x45(W)x13.5(H)mm (Maindevice)127(L)x48.6(W)x24.4(H)mm (Remotecontrol) | 360(L)x59(W)x11.5(H)mm(Maindevice)115(L)x53(W)x25(H)mm(Remotecontrol) | passed the testing accordingto the requirement of IEC60601-1. |
| 20 | Housing Materials & | ABS | ABS | Same |
| Construction | ||||
| 21 | Compliance with 21CFR 898 | Yes | Yes | Same |
| 22 | Compliancewith | IEC 60601-1:2005+A1:2012 | IEC 60601-1:2005+A1:2012 | Same |
| Voluntary Standards? | IEC 60601-1-2:2014 | IEC 60601-1-2:2014 | ||
| IEC 60601-2-10: 2012 | IEC 60601-2-10: 2012 | |||
| IEC60601-1-11: 2015 | IEC60601-1-11: 2015 | |||
| ISO 10993-1:2009 | ISO 10993-1:2009 | |||
| ISO 10993-5:2009 | ISO 10993-5:2009 | |||
| ISO 10993-10:2010 | ISO 10993-10:2010 | |||
| Table 2: Output Specification TENS mode | ||||
| New device | Predicate device | S.E. Discussion | ||
| 1 | 510K# | To be assigned | K173462 | N/A |
| 2 | Device Nameor | ThermaCare® Quick Therapy TENS | Wireless Pain Relieve Device | N / A |
| Program Name | Mode:TC001 | Mode:LT5018C | ||
| 4 | Waveform | Biphasic | Biphasic | Same |
| 5 | Shape | Rectangular | Rectangular | Same |
| 6 | Max Output Voltage (V) ±20% | |||
| 7 | 500Ω | 30.4 | 31 | Similar, the new device have |
| 8 | 2kΩ | 70 | 66 | been evaluated and passed |
| 9 | 10kΩ | 70 | 66 | the test accordingto the |
| requirementIECof | ||||
| 60601-2-10. | ||||
| 10 | Max Output Current (mA) ±20% | |||
| 11 | 500Ω2kΩ | 60.8 | 62 | Similar, the new device havebeen evaluated and passed |
| 1213 | 357 | 336.6 | the test according to the | |
| 10kΩ | requirement of | |||
| IEC60601-2-10 | ||||
| 14 | PulseDuration | 100~200us | 150~250us | Similar, the new device have |
| (µsec) | been evaluated and passed | |||
| the test according to the | ||||
| ofrequirement | ||||
| IEC60601-2-10 | ||||
| 15 | Frequency (Hz) | 2~100Hz | 2~100Hz | Same |
| 16 | Maximum Phase | 24.32 | 31 | Similar, the new device have |
| Charge (uC) 500Ω | been evaluated and passed | |||
| 17 | Maximum Current | 0.295mA/cm2 | 0.48mA/cm2 | the test according to the |
| Density 500Ω | requirement of IEC | |||
| 18 | Maximum Average | 1.22 | 1.2 | 60601-2-10. |
| Current(average | ||||
| absolutevalue), | ||||
| mA, 500Ω | ||||
| 19 | Maximum AveragePower Density,(mW/cm²),500Ω | 1.8 | 2.88 |
Table 1: Substantial Equivalence Comparison Table
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Discussion:
The number of output modes, number of output channels, timer range, weight and dimension of the new device are different from the predicate devices, but the new devices are evaluated and passed the testing according to IEC 60601-1 and IEC 60601-2-10, this difference does not pose any new questions of safety.
The Max Output Voltage/Current, Pulse Duration, Maximum Phase Charge, Maximum Current Density and Maximum Average Power Density are similar with the predicate devices, but the new devices are evaluated and passed the testing according to IEC 60601-2-10, this difference doesn't pose any new questions of safety and effectiveness.
Performance Data: 6.
The following performance data are provided in support of the substantial equivalence determination:
6.1 Biocompatibility testing
The biocompatibility evaluation for the TC001 was conducted in accordance with the International Standard ISO 10993-1 "Biological Evaluation of Medical Devices – Part 1: Evaluation and Testing Within a Risk Management Process". As dictated by the application and duration of contact with the intact skin, the testing included the following tests:
- Cytotoxicity
- Sensitization
- Irritation
6.2 Electrical safety and electromagnetic compatibility (EMC)
Electrical safety and EMC testing were conducted on the TC001. The system complies with the IEC 60601-1, IEC60601-1-11 and IEC 60601-2-10 standards for safety and the IEC 60601-1-2 standard for EMC.
For FCC part 15 RADIO FREQUENCY DEVICES, Subpart C—Intentional Radiators.
6.3 Software Verification and Validation Testing
Main device, Remote control and APP software verification and validation testing were conducted and documentation was provided as recommended by FDA's Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices." The software for this device was considered as a "Moderate" level of concern.
6.4 Output waveform Testing
For each program, oscilloscope tracing diagrams describing the electrical output waveform was provided to verify the output specifications of the device according to IEC 60601-2-10.
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7. Conclusions
The intended use and basic technological characteristics of the ThermaCare® Quick Therapy TENS are equivalent with those of the Predicate device K173462. Any technological differences do not raise new questions regarding safety and effectiveness.
§ 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).